On September 18, 2026, U.S. Customs and Border Protection begins voiding Importer of Record (IOR) numbers whose CBP Form 5106 information is inaccurate or incomplete. That is the first step under Executive Order 14411, Strengthening Customs Enforcement, to carry a fixed date. It is narrower than the order’s headline provisions, and it is not a new rule. It is enforcement of an existing filing, with a consequence that stops entries.
This post explains what the August 19, 2026 Federal Register notice says, what it does not do, and what the one court decision to date shows about how a Form 5106 accuracy review proceeds. It is written from the notice, the executive order, and the opinion, all linked under Sources.
What the notice says
CBP published the notice, Accuracy of Importer of Record Data Submitted to CBP, on August 19, 2026. It implements Section 2(e) of Executive Order 14411, which directs the Secretary of Homeland Security to confirm that active Importers of Record are compliant with all applicable regulations and disclosures. The order was signed June 3, 2026 and published at 91 FR 35125 on June 10, 2026.
CBP Form 5106 is the Importer Identity Form. It is how an importer obtains an IOR number and how that number’s identifying information is kept current. The notice states that CBP is comprehensively reviewing the Form 5106 information on file for all Importers of Record, and it sets out what that information must be:
- Physical address. The physical address must be the actual physical location of the business or individual. In the notice’s words, it cannot be a registered agent, customs broker, freight forwarder, P.O. box, a business service center, or an address of another person or entity.
- Email and phone. Both must be valid and must belong to the Importer of Record. A broker or other third party cannot substitute its own.
- Power of attorney. A customs broker filing a Form 5106 on an importer’s behalf 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).
The DATES section is explicit: enhanced enforcement, including immediate voiding of IOR numbers with inaccurate information on the CBP Form 5106, commences on September 18, 2026.
What happens to a voided number
Where CBP finds the Form 5106 information inaccurate or incomplete, it will void the associated IOR number and issue written notice to the email address the importer most recently submitted. A voided number cannot be used for any purpose, including entering merchandise. To request reestablishment, the importer contacts CBP and provides the information the voiding notice describes to corroborate its identity, using the subject line Enforcing IOR Accuracy.
The notice cites 19 U.S.C. §1484 and 19 U.S.C. §4320 on entry and importer identification, 19 U.S.C. §1641 and 19 C.F.R. §111.29(a) and §111.32 on broker responsibilities, 19 C.F.R. §24.5 on importer numbers, and 18 U.S.C. §1001 and 31 U.S.C. §3729 on false statements and false claims.
What the notice does not do
It does not impose the asset or bonding minimums, the formal entry restrictions on foreign entities, the informal entry limitation, the good standing requirement, or the 50 percent penalty floor that the executive order directs. Those remain subject to rulemaking. The notice says that CBP is taking steps to revise importer eligibility regulations, guidance, and policies under Section 2 of the order, and that further announcements will follow on the CBP website and in the Federal Register. Separately, 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.
The tracker page now carries a section on what is in effect and when, alongside the provisions that are not.
What the first court decision shows
On September 16, 2026, the Court of International Trade denied a licensed customs broker’s motion for a preliminary injunction against CBP’s deactivation of his entry filer code, in Forrest Xu v. U.S. Customs and Border Protection, Slip Op. 26-115. The case predates the September 18 date, but it is the first published account of a Form 5106 accuracy review from start to finish.
According to the opinion, CBP wrote to the broker on April 24, 2026 that it was conducting a compliance review of the accuracy of the Form 5106 data he had certified and transmitted for more than thirty Importer of Record numbers. It asked for his communications with those importers and the supporting records. CBP’s May 4, 2026 letter, quoted in the opinion, found that he had provided no evidence of direct communication with 13 of the importers and no response at all for seven, only partial correspondence for 15, and that 15 of the powers of attorney he supplied were not fully filled out. CBP also confirmed that at least two of the government-issued identifications he provided were invalid. On June 1, 2026, CBP suspended his entry filer code, described an alternate method for filing entries, and set out the information he would need to provide for CBP to consider reinstatement after a minimum of 180 calendar days.
The court held that the broker was not likely to succeed on his due process claim. The government’s position, which the court found supported by the record, was that the process due before suspension of a filer code is governed by 5 U.S.C. §558(c): written notice of the facts or conduct that may warrant the action, and an opportunity to demonstrate or achieve compliance. The court found CBP had given both. It found no irreparable harm shown, noting the alternate filing method and the absence of evidence of lost clients. On the public interest, it cited the government’s point that dozens of IOR numbers had been issued without accurate and complete information, and the significant public interest in protecting the revenue.
Two features of that record map directly onto the September 18 notice: the power of attorney executed directly with the importer, and identity information that CBP can verify.
The facts that decide whether an IOR number is at risk
For any company that holds an IOR number, or relies on a supplier or forwarder that holds one on its behalf:
- What physical address is on the Form 5106, and whose address it is
- Whether the email and phone on file belong to the importer or to a broker, forwarder, or agent
- Whether the broker who filed the form holds a power of attorney executed directly with the importer
- Whether the identifying information on file can be corroborated if CBP asks
An importer whose Form 5106 lists a forwarder’s warehouse, a broker’s inbox, or a registered agent’s suite is the profile the notice describes. The breakdown by situation covers who tends to be in that position and why.
Sources
- CBP, Accuracy of Importer of Record Data Submitted to CBP, Federal Register, August 19, 2026
- Executive Order 14411, Strengthening Customs Enforcement, 91 FR 35125, June 10, 2026
- CBP, Heightened Import Disclosures for Supply Chain Visibility, advance notice of proposed rulemaking, September 2, 2026
- Forrest Xu v. U.S. Customs and Border Protection, Slip Op. 26-115, Court of International Trade, September 16, 2026
- 19 U.S.C. §1484, entry of merchandise
- 19 C.F.R. §111.36, relations with unlicensed persons