CBP Will Void Importer of Record Numbers for Inaccurate Data Starting September 18, 2026: What Procurement Teams Must Do

Beginning September 18, 2026, CBP will void Importer of Record numbers on the spot whenever it finds inaccurate or incomplete Form 5106 data — and a voided number blocks all future imports until reestablished. For procurement and trade-compliance teams, this converts a paperwork formality that many treated as a one-time filing into an ongoing accuracy requirement with an immediate, no-notice enforcement trigger.

This article summarizes publicly available regulatory reporting for trade-compliance planning purposes and is not legal or customs advice. Confirm your organization’s IOR filings with a licensed customs broker or trade counsel before the September 18, 2026 effective date.

What is the new CBP rule taking effect September 18, 2026?

US Customs and Border Protection will begin immediately voiding Importer of Record numbers whenever it determines the Form 5106 information behind that number is inaccurate or incomplete. Form 5106 is the document that establishes an importer’s identity with CBP and generates the IOR number used on every entry filing, so an error in that underlying data now carries an immediate enforcement consequence rather than a routine correction request.

The rule, formalized through a Federal Register notice on the accuracy of importer-of-record data, gives CBP authority to act as soon as it identifies a discrepancy — there is no described grace period between detection and voiding under the new enforcement posture.

Which three data fields does CBP require to be accurate?

CBP is focused on three specific fields on Form 5106: the importer’s physical address, phone number and email address. Each must genuinely belong to the importer of record itself — using a customs broker’s, freight forwarder’s or registered agent’s contact details in place of the importer’s own information no longer satisfies the requirement.

The physical address must be the importer’s actual business or personal location, which rules out P.O. boxes and third-party business service centers that some importers have historically used as a filing convenience. The phone number and email address face the same standard: both must be reachable channels that belong to the importer, not a broker acting as an intermediary, because CBP’s notification process for a voided number depends on reaching the importer directly.

What actually happens when CBP voids an Importer of Record number?

A voided IOR number becomes invalid for any purpose connected to that importer, which includes the entry of merchandise into the United States. In practice, this means shipments cannot clear customs under that number until it is reestablished, regardless of how routine or compliant the underlying transaction is otherwise.

CBP will issue written notice to the email address most recently on file, explaining the basis for voiding the number and outlining the process for reestablishing it. This makes the accuracy of the email field doubly important: if the address on file is wrong or belongs to a third party, the importer may not learn a number has been voided until a shipment is already blocked at the border.

Why did CBP tighten enforcement on this specific requirement?

CBP has cited a pattern of importer records listing broker, freight-forwarder or shell-address information instead of the importer’s own details, which complicates enforcement, liability tracing and communication when a compliance issue arises. Tying the IOR number’s validity directly to data accuracy closes that gap by making the record self-correcting: an inaccurate filing now carries an automatic consequence instead of requiring a separate enforcement action.

The change fits a broader 2026 pattern of CBP pushing for more reliable, traceable supply-chain data, including separate discussions about expanded country-of-origin documentation and manufacturer identification requirements. Procurement teams should read this rule as one part of a wider tightening on import-data accuracy rather than an isolated administrative update.

What should procurement and trade-compliance teams do before September 18?

First, pull the current Form 5106 for every active Importer of Record number the organization uses and verify the address, phone number and email address are the importer’s own — not a broker’s, forwarder’s or registered agent’s. This includes subsidiaries, related entities and any IOR numbers used for drop-shipped or third-party-fulfilled goods, which are frequently the records most likely to list a service provider’s contact details by default.

Second, confirm the email address on file is actively monitored by someone at the importing entity, since that is the only channel CBP will use to notify the organization if a number is voided. Third, if any field needs correction, file the update with CBP before September 18 rather than after, since a correction made after a number is voided still requires going through reestablishment rather than a simple amendment. Finally, loop in the customs broker of record to confirm which IOR numbers they filed on the importer’s behalf using their own office details, since those are the records most likely to fail the new standard.

What happens if a shipment is in transit when a number is voided?

The publicly available guidance does not describe a blanket exception for goods already in transit when an IOR number is voided, which means procurement and logistics teams should treat any shipment scheduled to arrive on or after September 18 as exposed if the underlying Form 5106 has not been verified. Customs brokers and trade counsel are best positioned to advise on entry timing for shipments already en route.

Given that risk, the safest operational step is to complete the address, phone and email verification well before September 18, rather than treating the effective date itself as the deadline for starting the review.

Should trade-compliance teams build an ongoing verification process, not a one-time check?

Treating this deadline as a single cleanup exercise misses the point of the rule: CBP can void a number for inaccurate data at any point after September 18, not only during an initial review window, which means a Form 5106 that is correct today can trigger enforcement later if an importer’s address, phone number or email changes and the filing is never updated. Companies that relocate offices, change phone systems, or rotate the staff email address used for compliance correspondence are all exposed unless someone owns updating CBP’s records when that happens.

The practical fix is to fold Form 5106 accuracy into the same change-management process that already triggers updates to a company’s registered agent, business license or tax filings — any event that changes a company’s official contact details should now include a step that checks whether an IOR filing needs to be updated too, rather than leaving it as a separate, easily forgotten task owned by whoever filed it originally.

Frequently Asked Questions

When does CBP start voiding Importer of Record numbers for inaccurate data?
September 18, 2026. From that date, CBP voids an IOR number immediately upon determining its Form 5106 data is inaccurate or incomplete.

Can a customs broker’s address be used on Form 5106 instead of the importer’s own address?
No. The address must be the importer’s actual business or personal location — not a broker, freight forwarder, registered agent or P.O. box.

Can a company still import goods with a voided IOR number?
No. A voided number is invalid for any purpose, including bringing merchandise into the United States, until it is reestablished with CBP.

How will an importer know if CBP has voided its number?
CBP sends written notice to the email address most recently on file, which is why that email must genuinely belong to and be monitored by the importer.

Last Updated: September 17, 2026. For related coverage, see kurums.com’s analysis of the US-Canada tariff escalation and import bans, agent appointment and delegated authority controls for forwarder representation, and the kurums.com Procurement hub for ongoing trade-compliance coverage.