US Customs and Border Protection (CBP) published a notice in the federal register August 19, 2026 regarding the implementing enhanced enforcement measures to ensure the accuracy of the information provided to identify and verify importers of record (IOR) on CBP Form 5106. IORs, or customs brokers providing information on the IOR’s behalf, must ensure that all information, including the physical addresses, email addresses, phone numbers, Internal Revenue Service (IRS) employer identification (EIN), and any Social Security Number (SSN) provided on the CBP Form 5106 are accurate and complete, and that each one belongs directly to the IOR. Customs brokers submitting the CBP Form 5106 on behalf of a client must have a valid Power of Attorney (POA) executed directly with the IOR, as required by CBP regulations.
CBP is comprehensively reviewing the CBP Form 5106 information on file for IORs for accuracy. 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. CBP may also take other enforcement actions, as appropriate.
To ensure compliance with legal requirements and avoid potential voiding of IOR numbers, the IOR, or customs broker providing information on the IOR’s behalf, must provide accurate and complete information when submitting entity details via CBP Form 5106, and ensure that the information on file remains accurate and up-to-date. Customs brokers must exercise due diligence to ensure this information is accurate. Customs brokers should not transmit information to CBP that they know or should know is false or misleading, including unverified information. This includes, but is not limited to:
• Physical Address: 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.
• Email Address: The email address submitted must be valid and belong to the IOR. Customs brokers or third parties may not supply their own email address, or the email address of another person or entity, in place of the IOR’s email address.
• Phone Number: The phone number provided must be valid and belong to the IOR. Numbers not associated with the IOR should not be submitted. Customs brokers or third parties may not supply their own phone number, or the phone number of another person or entity, in place of the IOR’s phone number.
When updating this and all other information on CBP Form 5106, the party certifying the CBP Form 5106 must take appropriate steps to verify the information prior to submission. The certifying party may be subject to fines or imprisonment under 18 U.S.C. 1001 or other legal consequences for making an intentional false statement or committing deception or fraud on the CBP Form 5106. Additionally, because IOR data is an important identifier for liability for payment of duties, the provision of inaccurate or misleading information on CBP Form 5106 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.
Customs brokers submitting inaccurate or invalid information on a CBP Form 5106 may also be subject to broker penalties or other consequences pursuant to 19 U.S.C. 1641. Furthermore, customs brokers must have a valid POA with the IOR that authorizes the customs broker to submit information to CBP on the IOR’s behalf. Customs brokers must execute the POA directly with the IOR, not via a freight forwarder or other third party.
The Federal Register Publication may be found here.
If you have any additional question, please reach out to the JSC Compliance Department.
