A New Era of Importer Verification

U.S. Customs and Border Protection (CBP) has announced that it is implementing enhanced enforcement procedures to verify the accuracy of information submitted on CBP Form 5106, Create/Update Importer Identity Form. The initiative is one of the first public actions taken to implement Executive Order 14411, "Strengthening Customs Enforcement," signed on June 3, 2026. 

According to CBP, the objective is straightforward: ensure that Importers of Record (IORs) are accurately identified and accountable for their customs obligations. CBP emphasized that accurate importer information is critical to national security, revenue collection, supply chain transparency, and enforcement of U.S. trade laws, including requirements related to forced labor, country of origin, intellectual property, and product safety. 

What Is Form 5106?

CBP Form 5106 is used to establish or update an importer's identity and establish IOR accounts within CBP systems. The form serves as the foundation of an importer's account and contains key information such as legal business name, employer Identification Number (EIN) or CBP-assigned number, physical and mailing addresses, contact information and company type and business details. 

 What Is Changing? 

CBP announced that it will begin actively verifying information submitted by both new and existing Importers of Record. During these reviews, CBP may examine whether importer information is accurate, complete, and current.

Most significantly, CBP stated that inaccurate information on Form 5106 may result in: 

• Immediate voiding of an Importer of Record number 
• Additional enforcement actions
• Disruption of import activities until deficiencies are corrected 

The agency has encouraged importers and customs brokers to review existing Form 5106 information now and ensure that all data on file with CBP remains accurate. 

Effective Date 

CBP's enhanced enforcement procedures are scheduled to begin on September 18, 2026. Beginning on that date, CBP may immediately void IOR numbers associated with inaccurate Form 5106 information.

Why This Matters

Historically, many importers completed Form 5106 when first establishing their importer account and did not revisit it unless a specific business change occurred. Over time, however, companies may experience:

• Changes in legal entity names 
  
• Corporate restructurings 
• Address changes
• New operating locations
• Personnel changes
• Mergers or acquisitions
  

If these changes are not reflected in CBP's records, importers could find themselves exposed to compliance risks under the enhanced enforcement framework.

For foreign importers and non-resident importers, maintaining accurate registration information may become especially important as CBP increases scrutiny of importer eligibility and accountability. The agency's focus aligns with broader enforcement initiatives aimed at improving transparency and ensuring that responsible parties can be identified when trade violations occur. 

Recommended Actions for Importers

Importers should consider taking the following steps before the September 18 implementation date: 

1. Review Existing Form 5106 Information

   Confirm that the legal name, importer number, business addresses, and contact information on file with CBP are current and accurate.

2. Validate Corporate Structure Information

   Ensure that any mergers, acquisitions, name changes, or reorganizations have been properly reported to CBP.

3. Coordinate with Your Customs Broker

   Many brokers submit Form 5106 information on behalf of importers. Importers should verify that the information maintained by their broker matches current corporate records.

4. Maintain Supporting Documentation

   Keep records supporting your legal entity, ownership structure, addresses, and contact information readily available in the event CBP requests verification.

5. Update Records Promptly

   If discrepancies are identified, submit appropriate Form 5106 updates before CBP identifies the issues through enforcement activities.

These recommendations are prudent compliance practices based on CBP's announcement and the increasing focus on importer accountability.

Final Thoughts

CBP's enhanced enforcement procedures signal that Importer of Record data is no longer simply an administrative requirement. Instead, importer identity information is becoming a key component of CBP's broader customs enforcement strategy.

Importers that proactively review their Form 5106 information and correct any inaccuracies now will be better positioned to avoid disruptions when the new enforcement measures take effect. With CBP specifically warning that inaccurate information may lead to immediate voiding of IOR numbers, businesses should treat Form 5106 compliance as a priority item within their trade compliance programs.

If you have questions about these changes, please reach out. We’re here to help.