How to Check Form 5106 Before CBP Voids Your Importer Number

U.S. Customs and Border Protection (CBP) is tightening enforcement of the identity information behind every importer of record (IOR) number. Beginning September 18, 2026, inaccurate or incomplete information on CBP Form 5106 can lead to the IOR number being immediately voided.

This matters beyond future cargo. The same importer identity record supports Automated Commercial Environment (ACE) access, broker authorization, entry visibility, and coordination of Consolidated Administration and Processing of Entries (CAPE) refund work. Importers should review the record now instead of waiting for a failed entry or a notice sent to an outdated email address.

This guide explains what CBP will check, how voiding works, and how to protect both current import operations and IEEPA refund readiness.

What Changes on September 18, 2026

CBP published its general notice, Accuracy of Importer of Record Data Submitted to CBP, in the Federal Register on August 19, 2026. The notice implements initial parts of Executive Order 14411, Strengthening Customs Enforcement.

CBP says it is comprehensively reviewing Form 5106 information for existing IORs, not only new applications. Starting September 18, if CBP determines that an importer or a broker acting for the importer failed to provide complete and accurate information, the agency will void the IOR number and may take other enforcement action.

Source: CBP, Federal Register Doc. 2026-16911, August 19, 2026.

A voided number becomes invalid for any purpose, including entering imported merchandise into the United States. This is not merely an ACE profile warning: it can stop new entry activity until the identity record is reestablished.

The Form 5106 Fields CBP Will Verify

Form 5106 is the Create/Update Importer Identity Form used to establish or update an IOR number. Compare the information CBP currently holds with verified company records.

The physical address cannot be a registered agent, customs broker, freight forwarder, P.O. box, business service center, or the address of another person or entity. CBP also says a broker or third party may not substitute its own email address or telephone number for the importer’s information.

These rules make the importer-controlled contact fields especially important. If the last Form 5106 update used a former employee’s mailbox, a broker’s general address, or a disconnected telephone number, the record needs attention.

Why Form 5106 Matters for ACE and CAPE

An IOR number identifies the party responsible for entries and duties. It is also part of the identity chain used when an importer applies for ACE Portal access or asks an authorized broker to work with entries.

For the automated single-IOR ACE account application, CBP sends a verification code to the point-of-contact email associated with the Form 5106 importer record. An inaccurate email can therefore block account setup before an importer even reaches the CAPE tab. See our ACE Portal account setup guide for the current application and ACH workflow.

CAPE declarations may be submitted only by the importer of record or the authorized customs broker that filed the underlying entry summaries. A clean Form 5106 record does not by itself make an entry CAPE-eligible, but inconsistent importer identity information can complicate account access, broker coordination, and correction of refund issues.

CBP’s Form 5106 notice does not say that an accepted CAPE declaration is automatically canceled when an IOR number is voided. Do not overstate that risk. If an accepted claim is connected to a record that CBP questions, monitor the declaration through ES-022 and the ACE refund reports and request claim-specific guidance from CBP.

Seven Steps to Review Your IOR Record

1. Identify Every IOR Number in Use

Create a list for the legal entity and each affiliate that acts as an importer of record. Do not assume that reviewing the parent company’s record also covers subsidiaries or related entities.

For each IOR, record the legal name, tax identifier, ACE top account, assigned Center of Excellence and Expertise, active brokers, and the internal owner responsible for customs data.

2. Retrieve the Current Form 5106 Information

Ask the customs broker that maintains the importer record to confirm what CBP currently has on file. If an update is needed, Form 5106 may be submitted through the Automated Broker Interface (ABI) or by email to the importer’s assigned Center, following CBP instructions.

Do not send sensitive tax or identity information to an unverified requestor. Confirm the broker relationship and use official CBP channels. Refund scams remain active; review our IEEPA refund scam verification guide before sharing company data.

3. Verify the Legal Entity and Identification Number

The company name and EIN, SSN, or CBP-assigned number must refer to the same importer. Check punctuation, legal suffixes, reorganizations, mergers, and name changes against current tax and formation records.

If the importer structure changed, do not simply replace one entity’s details with another entity’s information. Ask a licensed customs broker or trade counsel which record and supporting documents CBP requires.

4. Replace Prohibited Address Information

Confirm that the physical location is the importer’s actual business or individual location. Do not use a broker, freight forwarder, registered agent, P.O. box, business service center, or another company’s address as the physical location.

The mailing address may differ from the physical location, but both should be current and supported. Document why each address belongs to the importer.

5. Confirm Importer-Controlled Email and Phone Details

Use a monitored business mailbox and telephone number that belong directly to the importer. A durable role-based mailbox can reduce the risk created when one employee leaves, provided the address is controlled by the importer and monitored by responsible staff.

This is also the address CBP may use to send a voidance notice. An obsolete Form 5106 email can turn a correctable data problem into an operational surprise.

6. Validate Every Broker Power of Attorney

A broker submitting Form 5106 information must have a valid power of attorney (POA) executed directly with the IOR. CBP says the POA cannot be obtained indirectly through a freight forwarder or another third party.

Compare the name and identifier on each POA with the Form 5106 record. Our customs broker authorization guide explains how filing authority and CAPE eligibility fit together.

7. Preserve an Audit Record

Keep a dated copy of the reviewed data, the supporting documents used to verify it, the broker communication, and confirmation of any update submitted to CBP. Assign an internal owner to repeat the review after changes to the company name, address, responsible personnel, phone number, email, or broker relationship.

What Happens if CBP Voids the IOR Number

CBP says it will send a written notice to the most recent email address provided on Form 5106. When applicable, CBP will copy the customs broker that last filed an entry for the importer. The notice should identify the basis for voiding and explain what information is required to request reestablishment.

Questions and reestablishment requests may be sent to IORProgram@cbp.dhs.gov with the subject line Enforcing IOR Accuracy. An importer or a customs broker with a valid POA may contact that address.

If a number is voided:

1. pause new filings under that number until CBP confirms its status;
2. preserve the CBP notice and all related emails;
3. identify the inaccurate or incomplete field;
4. gather documents that corroborate the importer’s identity;
5. coordinate the correction with the authorized broker and CBP; and
6. separately review active entries, bonds, ACE access, CAPE declarations, and approaching liquidation deadlines.

Do not create a replacement identity or switch an entry to another affiliate merely to bypass the voidance. The correction should match the actual legal importer and CBP’s instructions.

CAPE and Protest Deadlines Still Need Separate Attention

Form 5106 compliance and IEEPA refund preservation are related operationally, but they are not the same legal process. Correcting an importer record does not extend the generally applicable 180-day protest period under 19 USC § 1514.

Continue to:

• file eligible CAPE Phase 1 or Phase 2 entries through the correct importer or original filing broker;
• verify ACH refund information before payment reaches Treasury;
• monitor liquidation and reliquidation dates;
• consider a timely protective protest where that remedy remains available; and
• obtain trade-counsel review for material finally liquidated entries or disputed importer identity issues.

Use our CAPE, protest, and CIT decision guide to keep those deadlines separate from the account remediation work.

Form 5106 Review Checklist

• Legal name matches the tax and entity records
• EIN, SSN, or CBP-assigned number belongs to that legal entity
• Mailing address is current
• Physical address is the importer’s actual location
• Physical address is not a broker, forwarder, agent, P.O. box, or service center
• Email is active, monitored, and controlled by the importer
• Phone number is active and belongs to the importer
• Each customs broker holds a direct, current POA
• ACE Portal point-of-contact information is reachable
• ACH refund banking and refund recipient settings are current
• CAPE and protest deadlines are tracked separately
• The completed review and any correction are documented

Primary Sources and Disclaimer

• CBP, Accuracy of Importer of Record Data Submitted to CBP, 91 FR 53627, August 19, 2026
• CBP, Form 5106: Create/Update Importer Identity Form
• CBP, IEEPA Duty Refunds and CAPE guidance

CAPE Portal Guide is not a law firm, customs broker, or government agency. This guide provides educational information and does not guarantee that CBP will accept an update, reestablish an IOR number, or issue a refund.

If inaccurate importer data could affect your ACE access or CAPE refund work, request a confidential assessment so the Form 5106 record, entry status, and protest deadlines can be reviewed together.