Naomie Halioua
Co-founder & CRO, AI Research
On 19 August, CBP announced it will immediately void importer numbers over inaccurate paperwork: enforcement starts in two days, and a broker’s power of attorney routed through a freight forwarder no longer satisfies the rule
On 19 August 2026, U.S. Customs and Border Protection published a general notice in the Federal Register, “Accuracy of Importer of Record Data Submitted to CBP” (document 2026-16911), implementing a directive from Executive Order 14411, “Strengthening Customs Enforcement,” which the President signed on 3 June 2026. The notice sets 18 September 2026, two days from publication of this article, as the date CBP begins immediately voiding any Importer of Record (IOR) number tied to inaccurate or incomplete information on CBP Form 5106, the Importer Identity Form every business needs on file to bring goods into the United States. CBP names the fields it is checking: legal name, physical business address, tax ID or EIN, phone, email, and Customs power of attorney. On that last point, CBP has been explicit that a power of attorney executed with, or routed through, a freight forwarder, sourcing agent or other intermediary rather than directly between the broker and the importer does not satisfy the requirement, a detail that touches how a large share of first-time and overseas importers actually operate today. A voided IOR number becomes invalid for every customs purpose, including entering merchandise into the country, and CBP has flagged that inaccurate Form 5106 data can carry False Claims Act exposure on top of the operational disruption.
What CBP actually changed on 19 August
CBP Form 5106 is not new: it is the standard form that assigns and maintains an importer's identity in CBP's systems, usually tied to an IRS Employer Identification Number, and it is a prerequisite for holding an active Importer of Record number. What changed on 19 August is enforcement, not the form. Acting on Executive Order 14411's directive to strengthen customs enforcement and tighten accountability across importers, brokers, freight forwarders and bonded custodians, CBP announced that it has undertaken a comprehensive review of all Form 5106 data on file and will, from 18 September 2026, immediately void an IOR number the moment it determines that the importer, or a broker filing on the importer's behalf, has failed to keep that data complete and accurate. The review is not limited to the paperwork's existence: CBP is checking whether the physical business address, phone number and email on file are current and reachable, and whether the customs power of attorney supporting the filing was executed directly between the importer and its broker. A power of attorney signed by, or routed through, a freight forwarder or other intermediary rather than the importer itself does not meet that bar, even where the underlying import activity is entirely legitimate. Because a voided number cannot support any entry, including one already in transit, the notice effectively makes ordinary contact-detail housekeeping a condition of being able to clear goods through a U.S. port.
Three details behind the 18 September deadline
01
Voiding is immediate, not a warning
CBP describes the action as an immediate void once inaccurate or incomplete data is found: there is no separate notice-and-cure period built into the 18 September mechanism itself.
02
A common broker arrangement is now disqualifying
A customs power of attorney executed with, or routed through, a freight forwarder or sourcing agent rather than directly with the importer does not satisfy the rule.
03
This is the first tripwire of a longer rollout
Executive Order 14411 also directs CBP to raise minimum bond and asset thresholds and to build a compliance-history-based “good standing” requirement for every IOR by 30 November 2026.
3 Jun 2026
The President signs Executive Order 14411, “Strengthening Customs Enforcement,” directing CBP to tighten accountability for importers of record, brokers, freight forwarders and bonded custodians.
19 Aug 2026
CBP publishes general notice 2026-16911 in the Federal Register, “Accuracy of Importer of Record Data Submitted to CBP,” announcing a full review of Form 5106 data on file.
18 Sep 2026
Enforcement begins: CBP immediately voids any IOR number tied to inaccurate or incomplete Form 5106 data, including an indirect customs power of attorney.
30 Nov 2026
Under Executive Order 14411, CBP is due to establish and enforce a compliance-history-based “good standing” requirement for every importer of record.
The numbers behind the notice
One number is how little runway CBP gave importers between publication and enforcement. One is how many data points on a single form now decide whether a company can clear goods at all. The third points past this week, to the deadline that makes 18 September the opening move rather than the whole story.
30 days
the gap between the 19 August 2026 Federal Register publication and the 18 September 2026 date enforcement begins
6 fields
the Form 5106 data points CBP is checking: legal name, physical address, tax ID or EIN, phone, email and customs power of attorney
30 Nov 2026
the deadline set by Executive Order 14411 for CBP to establish and enforce a “good standing” requirement for every importer of record
The real subject: a paperwork check-up is the first filter in a longer campaign
Most coverage of the 18 September deadline treats it as a self-contained task: check Form 5106, fix the address, confirm the power of attorney is direct, move on. That framing is correct as far as it goes, but it understates what the notice actually is. It is one implementing action under Executive Order 14411, a June 2026 order that separately directs CBP to raise minimum bond coverage and tangible-asset requirements for importers of record, tighten the definition of who qualifies as a U.S. importer of record at all, and, by 30 November 2026, stand up a compliance-history-based “good standing” requirement that every IOR will need to meet on an ongoing basis, not just at onboarding. CBP has also stated that inaccurate or misleading Form 5106 data is material to an obligation to pay money to the government, which opens potential False Claims Act exposure, a statute carrying treble damages and third-party qui tam suits, on top of the immediate operational risk of a voided number. Read against that backdrop, the Form 5106 review is best understood as CBP building the clean, current data layer that its later, more consequential compliance-history rule will need to function. A brand that treats 18 September as a one-time fire drill and moves on has fixed the most mechanical filter in the pipeline; it has not yet dealt with the bonding, asset and standing requirements arriving behind it.
Why it matters for brands
Three groups of importers should treat this week as urgent, not routine. First, any brand that holds its own U.S. Importer of Record number, whether through a U.S. subsidiary or a direct registration, should confirm today that the legal name, physical address, tax ID, phone and email on file with CBP are current, and that the customs power of attorney on record was executed directly with the broker rather than inherited from a freight forwarder or sourcing agent relationship, a setup that is common precisely among overseas brands entering the U.S. market through a logistics partner. Second, any brand that ships on a delivered-duty-paid basis or relies on a third party to act as importer of record on its behalf should ask that party directly, this week, whether its Form 5106 filing has been reviewed against these criteria: a voided IOR number stops that party's entries, and by extension the brand's shipments, with no separate warning built into the mechanism. Third, and more durably, any compliance or trade-operations team should read the 18 September deadline as the leading edge of Executive Order 14411 rather than its conclusion: the bonding and asset thresholds still being finalised, and the compliance-history-based good standing requirement due by 30 November 2026, will judge importers on an ongoing record, which means the accurate, well-governed importer data a brand assembles to survive this week's check is also the foundation it will need for the requirements still to come.
Two ways to read the 18 September deadline
The narrow read
From 18 September 2026, CBP will void Importer of Record numbers over inaccurate Form 5106 data, so importers should confirm their address, contact details and power of attorney this week.
The structural read
This is the data-accuracy layer of a broader Executive Order 14411 campaign that will also raise bond and asset thresholds and, by 30 November 2026, judge every importer on an ongoing compliance-history standard. Passing this week's check is necessary but not sufficient for what follows.
Frequently asked questions
When does CBP start voiding Importer of Record numbers over Form 5106 data?
From 18 September 2026. CBP set that date in a general notice published in the Federal Register on 19 August 2026, “Accuracy of Importer of Record Data Submitted to CBP” (document 2026-16911), issued under Executive Order 14411, “Strengthening Customs Enforcement,” which the President signed on 3 June 2026. From the effective date, CBP immediately voids any IOR number tied to inaccurate or incomplete Form 5106 data, and a voided number is invalid for any customs purpose, including entering merchandise into the United States.
Does a customs power of attorney signed through a freight forwarder still satisfy CBP’s requirement?
No. CBP has stated that a customs power of attorney must be executed directly between the customs broker and the Importer of Record. A power of attorney granted by, or routed through, a freight forwarder, sourcing agent or other intermediary does not meet that requirement, and CBP treats that gap the same way it treats an outdated address or phone number: as inaccurate or incomplete Form 5106 information that can trigger the immediate voiding of the IOR number from 18 September 2026.
What should a brand importing into the United States do before 18 September 2026?
Confirm, before the deadline, that the legal name, physical business address, tax ID or EIN, phone number, email and customs power of attorney on file with CBP under Form 5106 are current and accurate, and that any power of attorney was executed directly with the broker rather than through a freight forwarder or sourcing agent. Brands that rely on a third party to act as Importer of Record, including delivered-duty-paid arrangements, should ask that party directly whether its own Form 5106 filing has been reviewed, since a voided IOR number stops that party's entries with no separate warning. Questions and requests to reestablish a voided number can be sent to IORProgram@cbp.dhs.gov with the subject line “Enforcing IOR Accuracy.” Because Executive Order 14411 separately directs CBP to raise bond and asset thresholds and to build a compliance-history-based “good standing” requirement by 30 November 2026, brands should treat this deadline as the first of several rather than a one-time fix.
Sources
- The White House: Executive Order 14411, “Strengthening Customs Enforcement,” signed 3 June 2026
- Federal Register: “Accuracy of Importer of Record Data Submitted to CBP,” general notice 2026-16911, published 19 August 2026
- U.S. Customs and Border Protection: “Strengthening Customs Enforcement”, CBP’s own hub page for Executive Order 14411 implementation
- U.S. Customs and Border Protection: Create/Update Importer Identity Form (CBP Form 5106) programme page
- Akerman LLP: “CBP Will Void Importer of Record (IOR) Numbers for Inaccurate Data Starting September 18”
- Stinson LLP: “Importers Must Confirm Accuracy of Importer of Record Information With CBP”
- Diaz Trade Law: “CBP Will Void Importer of Record Numbers Beginning September 18, 2026”, including the False Claims Act exposure CBP flagged for inaccurate Form 5106 data
- GDLSK, via the European American Chamber of Commerce New York: “CBP Announces Enhanced Enforcement of IOR Requirements and Voiding of Importer Numbers for Inaccurate Form 5106 Information,” including the IORProgram@cbp.dhs.gov contact for reestablishment requests
- Morrison Foerster: “New Executive Order Signals Broad Customs Enforcement Overhaul,” on Executive Order 14411’s 45/90/180-day rollout
- RSM US: “Executive Order 14411 tightens rules for foreign importers of record,” on the bonding, asset and 30 November 2026 good-standing provisions
Note on verification: this session's network access allows search but blocks direct page retrieval from whitehouse.gov, federalregister.gov, cbp.gov, govinfo.gov and every law-firm domain listed above. The 3 June 2026 signing date for Executive Order 14411, the 19 August 2026 publication and document number of Federal Register notice 2026-16911, the 18 September 2026 enforcement date, the six Form 5106 data points CBP is checking, the requirement that a customs power of attorney be executed directly with the importer rather than through a freight forwarder, and the 30 November 2026 good-standing deadline were each confirmed through search-indexed excerpts of the primary Federal Register, White House and CBP pages, cross-checked against independent reporting from Akerman LLP, Stinson LLP, Diaz Trade Law, GDLSK (via the European American Chamber of Commerce New York), Morrison Foerster and RSM US, all of which describe the same dates, document number and requirements. The False Claims Act exposure CBP flagged for inaccurate Form 5106 data, and the IORProgram@cbp.dhs.gov contact for questions and reestablishment requests, were independently corroborated across at least two of those sources. Where a figure or claim could not be cross-checked across at least two independent sources, it has been left out.
Frequently asked questions
When does CBP start voiding Importer of Record numbers over Form 5106 data?
From 18 September 2026. CBP set that date in a general notice published in the Federal Register on 19 August 2026, “Accuracy of Importer of Record Data Submitted to CBP” (document 2026-16911), issued under Executive Order 14411, “Strengthening Customs Enforcement,” which the President signed on 3 June 2026. From the effective date, CBP immediately voids any IOR number tied to inaccurate or incomplete Form 5106 data, and a voided number is invalid for any customs purpose, including entering merchandise into the United States.
Does a customs power of attorney signed through a freight forwarder still satisfy CBP’s requirement?
No. CBP has stated that a customs power of attorney must be executed directly between the customs broker and the Importer of Record. A power of attorney granted by, or routed through, a freight forwarder, sourcing agent or other intermediary does not meet that requirement, and CBP treats that gap the same way it treats an outdated address or phone number: as inaccurate or incomplete Form 5106 information that can trigger the immediate voiding of the IOR number from 18 September 2026.
What should a brand importing into the United States do before 18 September 2026?
Confirm, before the deadline, that the legal name, physical business address, tax ID or EIN, phone number, email and customs power of attorney on file with CBP under Form 5106 are current and accurate, and that any power of attorney was executed directly with the broker rather than through a freight forwarder or sourcing agent. Brands that rely on a third party to act as Importer of Record, including delivered-duty-paid arrangements, should ask that party directly whether its own Form 5106 filing has been reviewed, since a voided IOR number stops that party's entries with no separate warning. Questions and requests to reestablish a voided number can be sent to IORProgram@cbp.dhs.gov with the subject line “Enforcing IOR Accuracy.” Because Executive Order 14411 separately directs CBP to raise bond and asset thresholds and to build a compliance-history-based “good standing” requirement by 30 November 2026, brands should treat this deadline as the first of several rather than a one-time fix.
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