U.S. Branch: ATA LOGISTICS
August 30 2026
IMPORTANT COMPLIANCE NOTICE
U.S. CBP Importer of Record (IOR) Identity Data Verification
Effective Date: September 18, 2026
To:Valued Client
1.Background
Effective September 18, 2026, U.S. Customs and Border Protection (CBP) will begin a comprehensive verification of Importer of Record (IOR) identity information on file in CBP Form 5106 (Create/Update Importer Identity Form), pursuant to Executive Order 14411 “Strengthening Customs Enforcement” (signed June 3, 2026) and Federal Register notice 91 FR 53627 (published August 19, 2026).
Officialsource:https://www.federalregister.gov/documents/2026/08/19/2026-16911/accuracy-of-importer-of-record-data-submitted-to-cbp
2.Key Impact
If CBP determines that the information on Form 5106 is inaccurate or incomplete, CBP willimmediately void the IOR number. A voided IOR number is invalid for any purpose, including entering imported merchandise into the United States. Shipments in transit or at port will not be able to clear customs until the number is reestablished.
3.Focus of Verification(Three Red Lines & Beneficial Owner Status)
CBP will focus on the following items. Each must be accurate, complete and belong directly to the IOR itself:
(1)Physical Address
Must be the IOR's actual place of business. A registered agent, customs broker, freight forwarder,
P.O. box, business service center, or any other person's/entity's address is NOT acceptable (an owner's home address may be used).
(2)Phone Number
Must belong to the IOR itself; third-party numbers are NOT acceptable.
(3)Email Address
Must belong to the IOR itself; third-party email addresses are NOT acceptable. IMPORTANT: CBP will send any void notice to the email most recently submitted. If that email is not controlled by the IOR, the notice may never reach the IOR.
(4)Beneficial Owner Status(effective early December 2026 -NOT a Sept 18 check item,but please self-review now)
Under Section 10 of E.O. 14411: an individual IOR must be a U.S. citizen or lawful permanent resident; an entity IOR must be organized under U.S. law, located in the United States, and havecontrollingbeneficial owner(s) who are U.S. citizens or lawfulpermanent residents.Entities failing this test may be classified as “foreign IORs”, losing access to informal entry (≤$2,500) and required to use a CTPAT-validated customs broker. EXCEPTION: an entity that owns a significant amount of real property in the United States may still qualify as a “U.S. IOR”. Please complete the “Beneficial Owner(s)” and “U.S. Real Property” rows in the self-check sheet below.
4.Additional Risk Notes
·Customs Broker Power of Attorney (POA)
The customs broker filing on behalf of an importer must hold a valid Power of Attorney executeddirectly with the IOR. POAs obtained indirectly through a freight forwarder or other third party are NOT acceptable.
·Legal Liability
Submitting false or misleading information may trigger U.S. federal criminal liability (18 U.S.C. 1001), civil liability (False Claims Act), and broker penalties (19 U.S.C. 1641).
·What's Next (effective early December 2026)
E.O. 14411 further requires importers to maintain minimum tangible domestic assets/bonding, higher minimum bond amounts, and a “good standing” standard. Regulations are expected to take effect in early December 2026, with enforcement continuing to tighten.
5.Action Required
Please importer self-check the following by September 10, 2026:
- Verify all items in the attached IOR Form 5106 Self-Check Confirmation Sheet.
- Confirm the address, phone and email on file belong to the IOR itself, and the email can receive CBP correspondence.
- Confirm your customs broker holds a valid POA executed directly with the IOR.
- If any information is incorrect, update CBP Form 5106 through your customs broker promptly, or contact CBP directly at[email protected](subject line: “Enforcing IOR Accuracy”).
- If you are a shipper/trading company, please forward this notice to your U.S. importer/buyer for confirmation and completion of the attached sheet.
6.Official References
·CBP Federal Register Notice (91 FR 53627, 2026-08-19):https://www.federalregister.gov/documents/2026/08/19/2026-16911/accuracy-of-importer-of-record-data-submitted-to-cbp
·ExecutiveOrder14411(fulltext):https://www.federalregister.gov/citation/91-FR-35125
·CBPOfficialContactEmail:[email protected](Contact:AnitaRivera,+1771-233-2939)
5106 form:https://www.cbp.gov/document/forms/cbp-form-5106-createupdate-importer-identity-form
Thank you for your cooperation. Should you have any questions, please do not hesitate to contact us. Best Regards,
U.S.Branch: ATA LOGISTICS
Please contact with our sales or customer service team.
August 30, 2026
Appendix:U.S. Import Customs Policy Timeline
|
Date |
Event |
Source |
|
2026-06-03 |
President signs Executive Order 14411 “Strengthening Customs Enforcement”. |
E.O.14411,91FR35125 |
|
2026-08-19 |
CBP publishes Federal Register notice on IOR data accuracy. |
91FR53627 |
|
2026-09-18 |
Full IOR Form 5106 verification begins; inaccurate data results in immediate voiding of IOR number. |
91FR53627 |
|
EarlyDec 2026 |
E.O.14411 core provisions take effect: minimum domestic assets/bonding, foreign-IOR restrictions, good standing standard. |
E.O.14411Section2 |
Attachment
IOR Form 5106 Information Self-Check Confirmation Sheet
Importer of Record: please verify each CBP file item and reply by September 10,2026.
|
Item |
CBPRequirement |
Tobefilledbyclient |
|
Legal Name of Importer |
Must match the registered legal name exactly |
Fillin |
|
EIN/SSN/CBP AssignedNo. |
Must be correct and belong to the IOR |
Fillin |
|
MailingAddress |
Must be accurate and valid |
Fillin |
|
PhysicalAddress |
Must be the actual place of business; registered agent / broker / forwarder / P.O. Box / business service center addresses are NOT acceptable |
Fillin |
|
PhoneNumber |
Must belong to the IOR itself; third-party numbers are NOTacceptable |
Fillin |
|
EmailAddress |
Must be long to the IOR and able to receive CBP notices (CBP will send void notices to this email) |
Fillin |
|
BrokerPOA |
Broker must hold avalid POA executed directly with the IOR |
Yes/No/Pending |
|
Beneficial Owner(s) |
Disclose the beneficial owner(s) of the importing entity, including citizenship / status.NOTE:UnderE.O.14411,a“U.S. IOR”entity requires controlling beneficial owner(s) who are U.S. citizens or lawful permanent residents; entities failing this test may be classified as “foreign IORs” with additional restrictions from early December |
Fillin |
|
U.S.RealProperty |
If you / the U.S. importer hold real property in the United States (e.g., warehouse, office premises), please disclose it. UnderE.O.14411,an entity whose beneficial owners are not U.S.citizens/LPRs may still qualify as a“U.S.IOR” if it owns a significant amount of real property in the United States |
Fill in/N/A |
|
Confirmation |
I here by confirm the above information is accurate, complete and up-to-date |
Seesign-off below |
Note:If you are a shipper/trading company,please forward this sheet to your U.S. importer/buyer to complete, stamp and return.