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Tracker. Last updated: October 10, 2026

The 2026 Customs Enforcement Order, and what it means for your Importer of Record

Container truck at a port inspection gate under a gantry crane at dusk, the enforcement environment the 2026 customs executive order addresses

On June 3, 2026, Executive Order 14411, Strengthening Customs Enforcement, published at 91 FR 35125 on June 10, 2026, directed the Department of Homeland Security and U.S. Customs and Border Protection to undertake a comprehensive overhaul of customs enforcement.

If your company imports into the United States, the part that matters most is this: the order tightens who may act as Importer of Record and what that party must be able to demonstrate.

In effect since September 18, 2026

Importer of Record data accuracy enforcement under the August 19, 2026 Federal Register notice. CBP voids the IOR number where the Form 5106 address, contacts, or power of attorney do not meet the notice. Details below.

In rulemaking, no effective date

The asset and bonding minimums, the formal and informal entry restrictions, the good standing requirement, the certification regime, and the 50 percent penalty floor. CBP’s advance notice of proposed rulemaking on supply chain disclosures, opened September 2, 2026, takes comments through December 1, 2026. A separate proposed rule on informal entries of $2,500 or less, published October 8, 2026, takes comments through December 7, 2026 and is not in effect.

What the order directs

Assets and bonding

Importers of Record must maintain at all times a minimum level of tangible domestic assets, bonding, or both. Bonding requirements are being increased.

Restrictions on foreign entities

Foreign entities face heightened requirements for formal entry. Only United States Importers of Record are authorized to file informal entry.

Good standing and vetting

All Importers of Record must meet a new good standing requirement. The order directs increased vetting procedures for all individuals and entities that conduct activities directly related to the importation of goods.

Disclosure and certification

DHS and CBP are directed to establish disclosure and certification requirements designed to combat duty evasion and noncompliance with supply chain rules.

Penalties

CBP must establish a 50 percent minimum penalty floor, limiting CBP’s discretion to reduce penalties assessed on importers who violate customs laws. The order also authorizes enhanced seizure and disposal of non-compliant imports.

What has NOT happened yet

This is the part most coverage gets wrong.

The asset, bonding, formal entry, informal entry, good standing, certification, and penalty floor provisions directed in the order are not in effect. DHS and CBP will engage stakeholders through standard rulemaking processes. CBP opened an advance notice of proposed rulemaking on supply chain disclosures on September 2, 2026, with comments due December 1, 2026 and no effective date. Affected parties are being given time to adjust operations.

Anyone telling you those requirements are in force today is either mistaken or selling urgency. What the order does is set direction, and that direction is unambiguous.

One implementation step under the order is in effect. It is described in the next section.

What is in effect, and when

Importer of Record data accuracy enforcement, in effect since September 18, 2026. On August 19, 2026 CBP published a Federal Register notice, Accuracy of Importer of Record Data Submitted to CBP, implementing Section 2(e) of Executive Order 14411. CBP is reviewing the CBP Form 5106 information on file for every active Importer of Record. The notice stated that enhanced enforcement, including immediate voiding of IOR numbers with inaccurate information on the Form 5106, would commence on September 18, 2026. That date has arrived. The enforcement described in the notice is in effect.

The notice is specific about what the Form 5106 must contain:

  • The physical address must be the actual physical location of the business or individual. It cannot be a registered agent, customs broker, freight forwarder, P.O. box, business service center, or the address of another person or entity.
  • The email address and phone number must be valid and must belong to the Importer of Record. A broker or other third party cannot substitute its own.
  • A customs broker filing the Form 5106 must hold a power of attorney executed directly with the Importer of Record, not through a freight forwarder or other third party, under 19 C.F.R. §111.36(c)(3).

Where CBP finds the information inaccurate or incomplete, it voids the associated IOR number and sends written notice to the email address most recently submitted. A voided number cannot be used to enter merchandise. Reestablishment is requested by contacting CBP with information corroborating the importer’s identity, as described in the voiding notice, using the subject line Enforcing IOR Accuracy.

The notice also states that CBP is taking steps to revise importer eligibility regulations, guidance, and policies under Section 2 of the order, with further announcements to come on the CBP website and in the Federal Register. A post on this site covers the notice and the first court decision to describe one of these accuracy reviews.

Related rulemaking, not in effect

Low-Value Shipments proposed rule, published October 8, 2026. CBP published a notice of proposed rulemaking at 91 FR 64532 that would change how informal entries of merchandise valued at $2,500 or less are filed. Under proposed 19 C.F.R. §143.26(a), a consignee that is not the owner or purchaser, such as a carrier, a freight forwarder, or a postal operator, would have to appoint a licensed customs broker to act as Importer of Record for the entry. Under new 19 C.F.R. §143.29, no informal entry would be released until a single transaction or continuous bond with the conditions of 19 C.F.R. §113.62 is on file. Informal entry would be due at or before importation rather than within 15 days, and filed electronically only. Comments are due December 7, 2026, and nothing in the proposal has an effective date.

CBP lists the proposal on its Strengthening Customs Enforcement page. The document itself does not cite Executive Order 14411 and does not address the order’s direction to limit informal entry to United States Importers of Record. That direction still has no proposed rule. The post on the proposal covers each provision.

Why the window matters anyway

Rulemaking takes months. It does not take forever, and the direction of travel is already clear from the text of the order.

Two things follow from that:

If your supplier or a foreign entity currently acts as your Importer of Record, that arrangement is squarely in the path of the heightened formal entry requirements. Worth confirming now whether it survives.

If you are a foreign company importing into the United States without a US entity, the informal entry route is being closed to you, and the asset and bonding minimums will apply to whoever acts as your IOR. Finding a qualified US Importer of Record is going to get more competitive, not less.

Companies that sort this out during the rulemaking period will be doing it calmly. Companies that wait will be doing it against a deadline, alongside everyone else.

What a qualified IOR will need to demonstrate

Reading the order’s direction, an Importer of Record will need to show:

  • Tangible domestic assets, adequate bonding, or both
  • Good standing under whatever standard CBP establishes
  • The ability to pass increased vetting
  • Compliance and documentation practices that survive a disclosure and certification regime
  • Records that hold up under a penalty environment with a 50 percent floor

That last point changes the calculus on documentation quality. When CBP’s discretion to reduce a penalty is capped, the value of getting the entry right the first time goes up accordingly.

Where the Importer of Record comes from

A Service-Disabled Veteran-Owned Small Business operates as a legally structured Importer of Record under 19 U.S.C. §1484. It assumes responsibility for entry accuracy, valuation methodology, and duty payment, with entries filed through licensed United States customs brokers.

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Sources

This page summarizes publicly available federal actions for general information. It is not legal advice. Requirements are subject to rulemaking and change. Verify current requirements against the Federal Register and CBP guidance.