CBP begins voiding IOR numbers over inaccurate Form 5106 data on Sept 18, 2026
Q: What happens if my Form 5106 is wrong?
A: From September 18, 2026, CBP will immediately void the associated IOR number if it determines the Form 5106 information is inaccurate or incomplete. A voided IOR number is invalid for any purpose, including entering imported merchandise — so entries cannot be made under it. CBP issues a written notice of the voiding to the email address the IOR most recently submitted and copies the last filing broker, but that notice comes with the action, not before it, and the notice publishes no cure period. Reinstatement is requested by email: the notice routes it to [email protected] with the subject line Enforcing IOR Accuracy, while CBP's own Voided Importer Record FAQs route a voided record to [email protected] and publish 5 business days to process a reinstatement application.
Key takeaways
- The date is Friday, September 18, 2026. That is 30 days after the Federal Register notice was published (August 19, 2026) — CBP's own page describes the start of enforcement that way.
- Voiding is triggered by the data, not by the entry. CBP determines that the Form 5106 information is inaccurate or incomplete, and voids the associated IOR number immediately.
- Six data elements are required: importer name, EIN/SSN/CBP-assigned number, mailing address, physical location address (if different), phone number and email address — all six must be current and belong to the IOR.
- Officer and beneficial-ownership data is optional. CBP's own Form 5106 FAQ says every field in section 3 is optional except when a CBP-assigned number is requested instead of an SSN — so it is not one of the six elements CBP enumerates.
- There is a written notice, but no pre-void notice and no stated cure period. CBP determines, voids, and then notifies, copying the broker that last filed entry.
- Re-establishment has two published routes that CBP has not reconciled. The notice directs requests to
[email protected]; CBP's voided-record FAQ directs them to[email protected]and publishes a 5-business-day processing time. - A voided IOR is not an inactive one. CBP also runs a separate inactive-record status — 366-day non-filing deactivation under 19 CFR 24.5(e) and ABI reactivation of a 20-Inactive record — which is a different mechanism from the September 18 action.
What changed: EO 14411, the August 19 notice, and the September 18 date
On June 3, 2026, the President signed Executive Order 14411, "Strengthening Customs Enforcement," published in the Federal Register on June 10, 2026 (FR doc 2026-11595, 91 FR 35125). The order directs DHS, among other things, to confirm that active IORs are compliant with all applicable regulations and disclosures, and gives the Secretary 180 days to update the IOR registry by removing inactive IORs, confirming active IORs are compliant, and creating risk-based compliance tiers.
The trade-level instrument is the notice CBP published on Wednesday, August 19, 2026: "Accuracy of Importer of Record Data Submitted to CBP", Federal Register document 2026-16911, at 91 FR 53627 (docket USCBP-2026-1024), signed by Susan S. Thomas, Executive Assistant Commissioner, Office of Trade. Its DATES line sets the clock: "This enhanced enforcement, including immediate voiding of IOR numbers with inaccurate information on the CBP Form 5106, will commence on September 18, 2026." That is 30 days after publication, which is how CBP's own campaign page puts it — and the literal date is the one to diary.
| Item | Value |
|---|---|
| Primary document | Accuracy of Importer of Record Data Submitted to CBP — FR doc 2026-16911 (Notice, CBP / DHS) |
| Citation and docket | 91 FR 53627 (pages 53627-53628), docket USCBP-2026-1024. Archival copy: govinfo PDF, FR-2026-08-19 |
| Published | August 19, 2026 (Volume 91, No. 159) |
| Enforcement begins | Friday, September 18, 2026 — 30 days after publication |
| Authority behind it | EO 14411, signed June 3, 2026, published June 10, 2026 (FR doc 2026-11595, 91 FR 35125) |
| Form at issue | CBP Form 5106, Create/Update Importer Identity Form (rev. 06/26), the form CBP's own pages currently name. It is the record behind the IOR number, not the entry itself. |
| What it says CBP gets | Written notice of the action to the IOR's most recent email, copying the broker that last filed entry; questions and re-establishment requests to [email protected], subject line Enforcing IOR Accuracy |
The notice also flags the liability layer: providing inaccurate or misleading information on the form "is material to an obligation to pay money to CBP and could subject the IOR or associated individuals to liability under the False Claims Act or other laws", and the certifying party may face fines or imprisonment under 18 U.S.C. 1001 for an intentional false statement.
This is the transaction-level end of a compliance stack this site already tracks. If you are modelling the remedy level rather than the record level, start with the Section 338 import ban and its legal challenges and what changes on September 15 and September 29, 2026; for the tariff layers that sit on top of an entry, see the Section 301 expansion to 60 countries, Section 301 tariffs on China and Section 232 metals tariffs. None of those duties can be paid at all if the IOR number on the entry is void.
Who is exposed
The notice reaches new and existing importers of record — and, in its own words, a broker acting for one: "Beginning on September 18, 2026, if CBP determines that an IOR or customs broker acting on behalf of an IOR has failed to provide complete and accurate information, CBP will void the IOR number, rendering it invalid for any purpose, including entering imported merchandise into the United States." The form is not a one-time registration: CBP is verifying what it already holds, so a record that was accurate when it was filed is exposed if the underlying facts have moved on.
The notice enumerates six data elements the form requires. Every one of them has to be right:
- Importer name (block 1A) — the legal name, as your IRS records carry it.
- EIN, SSN or CBP-assigned number (block 1B) — and it must belong to the IOR entity itself, not a parent, an affiliate or a third party.
- Mailing address (block 2A).
- Physical location address (block 2B) if it differs from the mailing address. CBP is specific: "The physical address provided for the IOR must be the actual physical location of the business or individual." "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." If the mailing address is a P.O. box, the physical address must be given.
- Phone number (block 2C) — "must be valid and belong to the IOR."
- Email address (block 2E) — "must be valid and belong to the IOR." CBP's notice adds that customs brokers and third parties may not substitute their own address. This is the field that decides whether you learn about a voiding at all, because the void notice goes to the address most recently submitted.
Two corrections to the common shorthand are worth stating plainly, because getting them wrong sends people to fix the wrong thing. First, officer and beneficial-ownership data in section 3 of the form is optional — CBP's own Form 5106 FAQ says all the data elements in the third section are optional except when an individual requesting a CBP-assigned number has an SSN. Second, anything you did submit must still be accurate: the exposure is inaccurate or incomplete information, whatever the field.
Brokers are exposed on a second axis: the notice states that "Customs brokers must execute the POA directly with the IOR, not via a freight forwarder or other third party." A power of attorney obtained through an intermediary is a defect in the record, not a technicality.
What a voided IOR number actually does
Start with CBP's own words, because the practical framing around them is louder than the text. A voided IOR number is "invalid for any purpose, including entering imported merchandise into the United States." That single clause is the operative consequence: the number cannot be used to make an entry.
- Entries cannot be made under the number. The number is invalid for any purpose; entering imported merchandise is the purpose CBP names.
- Notice comes with the action, not before it. CBP's sequence in the notice is determine, void, then notify: "CBP will issue a written notice of this action to an IOR to the email address the IOR most recently submitted to CBP, that notifies the IOR of the basis for voiding the IOR number", and "If applicable, CBP will copy the customs broker that last filed entry on behalf of the IOR when issuing the notice." There is no pre-void notice, response window or cure period anywhere in the notice — an absence in the text, not a CBP statement that no cure exists.
- The re-establishment timeline lives somewhere else. The notice itself publishes no processing time and no document list; it says only that "The notice will include information on how to request reestablishment of the IOR number, including what information must be submitted to CBP to corroborate the identity of the requesting IOR." CBP's live Voided Importer Record FAQs page, by contrast, does publish one: "Please allow 5 business days to process an application to reinstate a voided importer record."
- What this means for freight in motion is commentary, and should be read as such. The Federal Register text is about the validity of the number; it does not say what happens to a shipment already moving. Trade counsel read the practical effect the same way CBP's clause points — GDLSK's assessment (September 3, 2026) is that inaccurate importer information "could prevent entry processing and disrupt an importer's shipments until the IOR number is reestablished." Treat that as counsel's characterisation, and plan for it accordingly.
- Mind the modal verb. The notice says CBP will void the number; CBP's own campaign page says CBP may immediately void it. Both are CBP's; neither should be silently upgraded into the other. Plan against what the notice says CBP will do.
Pre-deadline checklist: what to verify before Friday, September 18
Ten actions, in the order they are useful. Most of them are about checking the record CBP holds rather than the copy in your own file drawer.
- Pull the Form 5106 data CBP actually has on file — not your file copy. A licensed customs broker with ABI or ACE access can read the current record; if you cannot reach one, go through your assigned Center of Excellence and Expertise.
- Match block 1A legal name to your IRS records exactly, including suffix and punctuation. The EIN must belong directly to that IOR entity.
- Verify block 1B EIN/SSN/CBP number belongs to the IOR entity — not to a parent, an affiliate or a third party.
- Confirm block 2B physical address is the actual place of business. It cannot be a registered agent, a customs broker, a freight forwarder, a P.O. box, a business service center, or another entity's address.
- Confirm block 2C phone number belongs to the IOR. A broker's or forwarder's number is not a substitute.
- Confirm block 2E email belongs to the IOR and is actively monitored. The void notice goes to the address most recently submitted — a stale inbox is how an importer finds out last.
- If the mailing address is a P.O. box, make sure 2B is filled in. The physical location address is what makes a P.O. box acceptable.
- Check the type-of-address selections in 2A and 2B. They are mandatory on the current form and are a known rejection source.
- Brokers: confirm the POA was executed directly with the IOR — not obtained through a freight forwarder or other third party — and is current.
- File corrections now and re-check the record afterwards. CBP publishes its own turnaround: roughly 2 business days to input and activate a new IOR, and 5 business days to update an existing one. An update filed on September 17 will not be reflected by September 18.
If your IOR number is already voided
CBP runs more than one record status and more than one channel, and the August 19 notice covers only one of them. Do not merge the two routes below — CBP's campaign page and its Voided Importer Record FAQs do not cross-reference each other, and CBP has not stated how they relate.
| Situation | What to do |
|---|---|
| Voided for inaccurate or incomplete Form 5106 data (the September 18 notice) | The notice directs questions about the enforcement and requests for re-establishment to [email protected] with the subject line Enforcing IOR Accuracy. The notice publishes no processing time and no document list; it says the void notice itself will explain what to submit. Wait for that notice, and act on the basis it states. |
| Voided under CBP's standing void process — duplicate records, an unverifiable EIN or SSN, undeliverable mail, no response to CBP, or a requested void | CBP's voided-record FAQ gives the concrete recipe: email a completed CBP 5106 plus importer-record proof plus a power of attorney no more than one year old (where an attorney-in-fact signs) to [email protected] with the subject line Void IR#. Allow 5 business days for processing. EIN proof must be pre-printed IRS or DOT documentation issued in the last 12 months — a W-9 or a state document is not accepted. |
| Reactivated, but nobody tells you | CBP's FAQ is blunt: "We do not contact importers or agents once an account is reactivated." If no CBP representative has corresponded within 2 business days of your submission, query CBP systems yourself to confirm the reactivation before you book freight. The Surety Bonds & Accounts helpdesk is (317) 614-4880. |
| Not voided, merely inactive | A separate mechanism. A 20-Inactive record is reactivated by an ABI broker sending a Transaction Processing message with Action Code A to move the status to 10-Active; importers without ABI can email a revised 5106 to their Center Entry Specialist Team with "IOR reactivation request" in the subject. Separately, CBP's Inactive for Entry Purposes status auto-deactivates IOR accounts that have not filed an entry within 366 days under 19 CFR 24.5(e) — such records cannot transmit ACE Cargo Release or Entry Summary. Neither is the September 18 action. |
Read the FAQ's own list of void reasons before assuming which fork you are in: duplicate records, unverifiable or missing identifiers, undeliverable mail, and a failure to respond to CBP all produce a voided record outside the September 18 enforcement. The fix in that case is the standing process in the second row above.
FAQ
Q: What happens if my Form 5106 is wrong?
A: From September 18, 2026, CBP will immediately void the associated IOR number if it determines that the information on the form is inaccurate or incomplete. The notice states that a voided number is invalid for any purpose, including entering imported merchandise into the United States, so an entry cannot be made under it. CBP issues a written notice of the voiding to the email address the IOR most recently submitted and copies the broker that last filed entry. That notice comes with the action, not before it.
Q: Is there any notice or cure period?
A: CBP does issue a written notice, but for the action rather than before it: the notice sequence is that CBP determines the information is inaccurate or incomplete, voids the IOR number, and then notifies the IOR of the basis. The Federal Register notice contains no pre-void notice, no response window and no cure period. That is an absence in the text, not a CBP statement that no cure exists. Because the notice goes to the email address most recently submitted, keeping block 2E current is what keeps you informed.
Q: How long until my IOR number is re-established?
A: CBP publishes two answers on two different surfaces, and has not reconciled them. The August 19, 2026 notice publishes no processing time at all, and says the void notice will explain how to request re-establishment and what to submit; requests go to [email protected] with the subject line Enforcing IOR Accuracy. CBP's live Voided Importer Record FAQs page publishes a timeline for reinstatement of a voided record: allow 5 business days to process an application, and note that CBP does not contact importers or agents once an account is reactivated, so query CBP systems yourself. Print both routes and confirm with your broker which one CBP applies to your record.
Q: Which fields on Form 5106 must be accurate?
A: The notice enumerates six data elements the form requires: (1) importer name, (2) EIN, SSN or CBP-assigned number, (3) mailing address, (4) physical location address if different from the mailing address, (5) phone number and (6) email address. The physical address must be the actual place of business and cannot be a registered agent, customs broker, freight forwarder, P.O. box, business service center or another entity's address. The phone number and email address must be valid and belong to the IOR. Officer and beneficial-ownership data in section 3 of the form is optional under CBP's own Form 5106 FAQ, except where a CBP-assigned number is requested instead of an SSN.
Q: What does Executive Order 14411 have to do with the September 18 date?
A: EO 14411, Strengthening Customs Enforcement, was signed on June 3, 2026 and published on June 10, 2026. It directs DHS to confirm that active IORs are compliant with all applicable regulations and disclosures, and gives the Secretary 180 days to update the IOR registry by removing inactive IORs, confirming active IORs are compliant and creating risk-based compliance tiers. CBP's August 19, 2026 notice implements the order at the record level, and sets enforcement to begin 30 days after publication: Friday, September 18, 2026.
Q: Is a voided IOR number the same as an inactive one?
A: No, they are different statuses. A voided IOR number is invalid for any purpose, including entering imported merchandise. An inactive record is a separate mechanism: a 20-Inactive record is reactivated by an ABI broker sending a Transaction Processing message with Action Code A to move it to 10-Active, and CBP's Inactive for Entry Purposes status automatically deactivates IOR accounts that have not filed an entry within 366 days under 19 CFR 24.5(e), which blocks ACE Cargo Release and Entry Summary transmission. Neither is the September 18 voiding action.
Q: Does the physical address on our Form 5106 have to be our place of business?
A: Yes. The notice states that the physical address provided for the IOR must be the actual physical location of the business or individual, and that 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. The physical location address only has to be given if it differs from the mailing address, but if the mailing address is a P.O. box then the physical address must be provided.
Q: Can our customs broker use its own email address on the form?
A: No. The notice states that the email address submitted must be valid and belong to the IOR, and that customs brokers or third parties may not supply their own email address, or the address of another person or entity, in place of the IOR's address. The phone number rule is the same: it must be valid and belong to the IOR. The practical reason is that the void notice is sent to the address most recently submitted, so a third-party inbox is not a substitute for one the importer monitors.
Q: Do existing importers of record have to re-verify, or is a Form 5106 already on file grandfathered?
A: Nothing is grandfathered. The notice covers both new and existing importers of record: if CBP determines that the information provided on a CBP Form 5106 is inaccurate or incomplete, CBP will, as of September 18, 2026, immediately void the associated IOR number. The practical step is to check what CBP actually holds rather than your own file copy, because any licensed customs broker with ABI or ACE access can read the current record on file for a given importer number, and then to correct anything that has drifted before the entry that depends on it is filed.
Related: Section 338 import ban and the legal challenges · Section 338: what changes Sept 15 and Sept 29 · Section 301 expansion to 60 countries · Section 301 tariffs on China · USMCA qualification requirements · Import duty calculation explained · Tariff news & client advisories
Sources (primary first, verified 2026-09-15): Federal Register: Accuracy of Importer of Record Data Submitted to CBP, 91 FR 53627 (Notice, Aug 19, 2026) · govinfo archival PDF of FR doc 2026-16911 · Executive Order 14411, Strengthening Customs Enforcement (91 FR 35125, June 10, 2026) · CBP: Strengthening Customs Enforcement · CBP: Voided Importer Record FAQs · CBP: Form 5106 guidance · CBP Form 5106, Create/Update Importer Identity Form (rev. 06/26) · CBP: Create/Update Identity 5106 FAQ · CBP CSMS bulletin: reactivating an inactive IOR (ABI Action Code A) · CBP CSMS bulletin: Inactive for Entry Purposes status, 19 CFR 24.5(e) · counsel and broker commentary, attributed as such: Clark Hill (Aug 20, 2026) · GDLSK (Sept 3, 2026) · Sharretts Paley (Aug 20, 2026) · Shapiro, Shap Talk #381 (Sept 3, 2026). Informational summary, not legal or customs advice — confirm entry treatment with a licensed customs broker.