CBP Voiding Importer of Record Numbers from 18 September 2026

How Global Import Agent Helps You Stay Cleared to Import

Global Import Agent provides verified importer of record compliance for importers and customs brokers operating in the US market.

We audit your CBP Form 5106 data against independent evidence – legal name registrations, business address records, EIN confirmation, and direct contact verification – so the information CBP holds on file reflects reality and withstands scrutiny under the new enforcement standard.

For customs brokers, we produce documented, evidence-backed verification records for each importer in your client portfolio. That means you can demonstrate the due diligence that FR Doc 2026-16911 now requires, hold proof that the data you transmitted was verified rather than assumed, and protect your licence from broker penalties under 19 USC. § 1641.

For foreign importers who cannot provide a qualifying US physical business address or who no longer wish to stand as their own importer of record under the tightened rules, we can act as a compliant US importer of record on your behalf, keeping your goods moving without interruption. Our services include:

• Pre-deadline Form 5106 accuracy audits for individual importers and broker client portfolios
• Correction and resubmission support where data is found to be non-compliant
• US importer of record service for foreign entities
• Power of Attorney review and direct-execution support for brokers
• Ongoing compliance monitoring to keep records current as business details change

• Form 5106 Accuracy Audit – We check every mandatory field – legal name, EIN/SSN/CBP number, mailing address, physical address, phone, and email – against independent source evidence and flag any discrepancy before CBP does
• For foreign importers who cannot satisfy the physical US address requirement or who need a compliant IOR entity, GIA acts as importer of record, taking on the formal responsibility for duties, entry, and regulatory compliance
• Broker Due-Diligence Documentation – We supply customs brokers with a structured, evidence-referenced verification file for each importer they file for, meeting the ‘documented due diligence’ standard set out in FR Doc 2026-16911 and protecting against broker penalties under 19 USC

• § 1641
• We confirm that each broker holds a valid Power of Attorney executed directly with the importer – not routed through a freight forwarder or intermediary – as CBP now requires
• Reinstatement Support – If a number has already been voided, we compile and present the corroborating identity evidence CBP needs to reinstate it, while working to minimise the time shipments are held
• FSVP and FDA IOR Alignment – For food, beverage, and supplement importers, we align your CBP importer of record data with your FSVP agent designation and FDA registration, ensuring consistency across all federal systems

What CBP's August 2026 Notice Actually Requires — and Why It Changes the Compliance Standard

On 19 August 2026, CBP published Federal Register notice FR Doc 2026-16911, titled Accuracy of Importer of Record Data Submitted to CBP. It is not guidance. It is a formal enforcement notice with a hard start date of 18 September 2026, after which CBP will void any importer of record number whose underlying CBP Form 5106 data it determines to be inaccurate or unverifiable.

A voided number takes effect immediately, blocks entry filing at every US port of entry simultaneously, and carries no automatic reinstatement pathway. The importer must provide corroborating identity evidence to CBP’s satisfaction before the number is restored – during which time all shipments under that number are held.

The notice is the first concrete enforcement mechanism under Executive Order 14411, Strengthening Customs Enforcement, signed in June 2026, which directed CBP to close the identity-verification loopholes that allow bad actors to mis-declare origin, undervalue goods, and evade tariffs. CBP is now reviewing both new and existing Form 5106 records.

That means importers with long-established numbers are equally at risk if their data has drifted, was never accurate, or uses addresses that are now explicitly prohibited.

One aspect of the notice that is underreported in most commentary: the explicit prohibition on freight forwarder addresses as the physical business location is treated with the same weight as the prohibition on registered agent and customs broker addresses. Any address that belongs to a third party – including a business services centre, a P. O.

box, or a virtual office – fails the physical address requirement. Equally, the email address and phone number on file must belong directly to the importer, not to the broker, forwarder, or any intermediary.

For many importers whose records were set up through a forwarder in the normal course of business, this is a hidden non-compliance that will not be visible until a voiding notice arrives.

• Legal name must match the importer's registered business entity exactly - trading names and abbreviations are not sufficient
• EIN, SSN, or CBP-assigned number must be valid, current, and directly attributable to the importing entity
• Physical address must be the importer's actual business location broker, forwarder, registered agent, P

O.

• box, and virtual office addresses are explicitly prohibited
• Phone number and email address must belong to the importer, not to any intermediary or service provider
• Brokers must hold a Power of Attorney executed directly with the importer - forwarder-routed authorisations do not satisfy the requirement
• Submitting unverified data - even without intent to deceive - now constitutes a broker compliance failure under FR Doc 2026-16911
• False statements on Form 5106 can attract False Claims Act liability under 31 USC

§§ 3729–3733 for the importer and the certifying individual.

Our Pre-Deadline IOR Compliance Review: What We Arrange and Manage End to End

1) Initial Portfolio Scoping

We begin by establishing the full scope of importer of record numbers to be reviewed – whether that is a single importer or a broker’s client portfolio of dozens.

We collect existing Form 5106 records and entry-filing history from the CBP ACE system, identify which numbers are actively used, and flag any that show hallmarks of the data patterns CBP has indicated it is targeting: third-party addresses, mismatched contact details, or tax identification numbers that do not align with the legal entity on file.

• Collection of current Form 5106 data for each IOR number in scope
• Cross-reference against active entry filing records in CBP ACE
• Risk-tiering of records by non-compliance probability before detailed audit begins

2) Field-by-Field Data Verification

Each mandatory Form 5106 field is verified against independent primary-source evidence – not simply checked for internal consistency.

We confirm the legal name against state business registry records, the EIN or CBP-assigned number against IRS records or CBP’s own importer number database, the physical address against business registration filings and property records, and the phone number and email address by direct contact with the importer.

This is the documented due-diligence standard that FR Doc 2026-16911 sets for customs brokers, and we apply it to every record regardless of how long it has been on file.

• Legal name verified against state and federal business registration sources
• EIN/SSN/CBP number verified against IRS or CBP records as applicable
• Physical address confirmed as the importer’s actual business location – not a service address
• Direct contact verification of phone number and email with the importer

3) Gap Identification and Correction Filing

Where verification reveals a discrepancy, we document the specific non-compliance – whether it is a prohibited address type, a contact detail that belongs to a third party, or a legal name that has changed following a corporate restructure – and prepare the corrected Form 5106 submission.

Corrections are filed promptly through the appropriate CBP channel, and we retain the full verification evidence file in case CBP requests supporting documentation. We do not amend records without the importer’s explicit confirmation, and we do not file data we have not independently verified.

4) Power of Attorney Review for Customs Brokers

For broker clients, we conduct a parallel review of the Power of Attorney on file for each importer. Under the terms of FR Doc 2026-16911, brokers must hold a valid POA executed directly with the importer. Any POA that was granted by or routed through a freight forwarder, a sourcing agent, or any other intermediary does not satisfy this requirement.

Where a direct POA is absent or has lapsed, we facilitate the execution of a compliant document between the broker and the importer before the 18 September deadline.

5) Documented Compliance Record and Ongoing Monitoring

On completion of the review, we provide a structured compliance record for each importer of record number audited, setting out the fields verified, the evidence sources used, the date of verification, and the outcome. This is the documentation a broker needs to demonstrate due diligence if CBP ever enquires about the basis on which data was filed.

We also set a review schedule, because CBP’s notice makes clear that accuracy must be maintained on an ongoing basis – not simply corrected once before a deadline. Business addresses change, contact details change, and corporate structures are reorganised; each event is a potential trigger for a Form 5106 update obligation.

What's Included in GIA's IOR Compliance Service

Full Form 5106 Data Audit

Field-by-field verification of every mandatory element on CBP Form 5106 against independent primary-source evidence, documented to the standard CBP’s August 2026 notice requires.

US Importer of Record Service

For foreign importers and entities that cannot satisfy the physical US address requirement, GIA acts as a compliant US importer of record, taking formal responsibility for duties, admissibility, and entry.

Broker Due-Diligence File

A structured, evidence-referenced verification record for each importer in a broker’s portfolio, providing the documented due diligence required under FR Doc 2026-16911 and protection against 19 USC. § 1641 penalties.

Correction and Resubmission Support

Where data is found to be non-compliant, we prepare the corrected Form 5106 submission, retain the verification evidence, and file the update through the appropriate CBP channel before the deadline.

Power of Attorney Review

Confirmation that each customs broker holds a valid POA executed directly with the importer — not through a freight forwarder or intermediary — with facilitation of direct execution where gaps are found.

FSVP and FDA Cross-System Alignment

For food, supplement, and regulated-product importers, we align CBP importer of record data with FSVP agent designations and FDA registration records to ensure consistency across all applicable federal systems.

What Is an Importer of Record Number and Why Is CBP Voiding Them?

An importer of record (IOR) number is the identifier CBP assigns to every entity that takes legal responsibility for a shipment entering the United States – for paying applicable duties and taxes, ensuring the goods comply with all US laws and regulations, and maintaining the records that support each entry.

The number is tied to the identity information the importer provides on CBP Form 5106, which is submitted when an importer first registers with CBP or when their details change. For US persons, this number is typically an EIN or SSN; for foreign entities without a US tax identification number, CBP assigns a separate importer number under 19 CFR § 24. 5.

Under Executive Order 14411, CBP has been directed to treat importer identity verification as a front-line customs enforcement tool, not merely an administrative formality.

The concern is specific: fraudulent or inaccurate IOR data has been used to mis-declare the origin of goods, undervalue shipments to reduce duty liability, and obscure the identity of parties subject to trade sanctions or enforcement actions.

By voiding numbers whose underlying data does not hold up, CBP removes the ability to file entry under a false or unverifiable identity – immediately and without a transitional window. The September 2026 enforcement date applies to both new and existing importers. CBP is not limiting its review to recently registered numbers.

Any IOR number in the active CBP database is in scope.

For importers whose records were established years ago through a freight forwarder, a sourcing agent, or a now-departed logistics provider, there is a real and often unrecognised risk that the address, contact details, or legal name on file no longer reflects reality – or, in the case of addresses, was never compliant with the rules CBP is now enforcing.

Fields CBP is verifying on Form 5106:

• Legal name of the importer - must match the registered business entity exactly
• EIN, SSN, or CBP-assigned importer number - must be valid and directly attributable to the importer
• Mailing address - must be accurate and current
• Physical business address — must be the importer's actual location; broker, forwarder, registered agent, P

O.

• box, and virtual office addresses are prohibited
• Phone number - must belong to the importer, not to any intermediary
• Email address - must belong to the importer, not to any intermediary

Our review and remediation process:

• Scope all active IOR numbers and obtain current Form 5106 data from CBP ACE records
• Verify each mandatory field against independent primary-source evidence
• Identify prohibited address types, mismatched contact details, and entity name discrepancies
• Prepare and file corrected Form 5106 submissions where non-compliance is found
• Issue a documented verification record for each number reviewed, suitable for broker due-diligence files

We verify Form 5106 data against independent primary sources – state business registries, IRS records, direct importer contact – rather than accepting data at face value. Every field is checked, every discrepancy is documented, and no information is filed that we have not confirmed. That is the standard FR Doc 2026-16911 sets, and it is the standard we apply.

Customs brokers face a higher compliance bar than before: submitting unverified data is now a regulatory failure in itself, regardless of intent.

We provide brokers with a structured due-diligence file for each importer reviewed – evidence sources cited, verification date recorded, outcome confirmed – so that if CBP ever asks how the broker knew the data was accurate, the answer is on file.

Foreign importers who cannot provide a qualifying US physical business address, or who simply need a compliant US entity to stand as importer of record, can use GIA’s established US importer of record service.

We take on the formal customs, duty, and regulatory obligations, so your goods keep moving under a compliant, verified identity – regardless of where your business is based. If you would like us to audit your importer of record records – or your clients’ records – against CBP’s September 2026 accuracy standard before the deadline, please .

We will tell you where the risks are, what needs to be corrected, and how to close the gaps in the time that remains. The cost of acting now is a fraction of the cost of recovering from a voiding event while shipments wait at the border. We work with importers and customs brokers across the US, UK, and international markets and can begin a review immediately.