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U.S. Customs and Border Protection (CBP) has increased its enforcement efforts regarding the accuracy of Importer of Record (IOR) information maintained on CBP Form 5106. As part of the implementation of Executive Order 14411, CBP is actively validating importer identity information for both new and existing importers and may immediately void an IOR number if information on file is found to be inaccurate, incomplete, or outdated.
Any company acting as an Importer of Record (IOR) is responsible for ensuring its Form 5106 data accurately reflects its business information. Importers should review key data elements, including legal business name, IRS Employer Identification Number (EIN), U.S. Customs Assigned Number (if applicable), physical and mailing addresses, contact information, and email addresses. Inaccurate, outdated, or incomplete information may result in customs clearance delays, rejected filings, shipment holds, requests for additional documentation, or the voiding of an Importer of Record number.
CBP has also advised CTPAT partners to verify that the information maintained within the CTPAT Portal is active and matches the information reported on Form 5106. Discrepancies between Form 5106 records and CTPAT account information will affect CTPAT benefits.
As part of this review, importers should confirm the accuracy of all taxpayer identification information associated with their import activities, including both the Importer of Record and Ultimate U.S. Buyer, where applicable. Incorrect or invalid tax identification numbers can lead to rejected filings, delayed cargo releases, and the need for corrective action before entries can be processed.
To help minimize potential disruptions, companies that act as an Importer of Record, particularly those participating in CTPAT, should conduct an immediate review of their Form 5106 data and CTPAT Portal information to ensure all records are accurate, current, and aligned. If discrepancies are identified, importers should expedite an update to their information through their ACE Portal or submit an updated CBP Form 5106 to the appropriate CBP Center for review and processing.
If you need assistance reviewing or updating your importer information, please contact us.
https://www.federalregister.gov/documents/2026/08/19/2026-16911/accuracy-of-importer-of-record-data-submitted-to-cbp
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