CTPAT Importers: CBP Warns IOR Numbers May Be Voided November 18 Over Form 5106 Accuracy
CONCORD SOLUTIONS GROUP — TRADE COMPLIANCE UPDATE
CBP has sent letters to numerous CTPAT-certified importers stating that their importer of record (IOR) numbers may be voided for entries filed starting at 12:01 a.m. Eastern Time on November 18, 2026, unless CBP's concerns about the accuracy of the importer's CBP Form 5106 information are resolved first. The NCBFAA Customs Committee reported the letters to its members on November 4, 2026 and asked brokers to alert their importer clients.
Required action
According to the letters, CBP has directed each affected importer to review its Form 5106 record in the ACE Secure Data Portal, correct any inaccurate information, and confirm that the IOR number listed in the CTPAT Portal is active and matches the ACE record. A voided IOR number cannot be used to file entries, so an unresolved letter would stop cargo release and entry summary filings under that number from November 18.
Background
The letters follow CBP's Federal Register notice on the accuracy of IOR data (91 FR 53627, August 19, 2026), under which CBP has voided IOR numbers with inaccurate or incomplete Form 5106 data since September 18, 2026. The physical address on Form 5106 must be the importer's own business location, not a registered agent, broker, forwarder, P.O. box or business service center, and the email address and phone number must belong to the importer.
Importers, particularly CTPAT members, should check whether they received a CBP letter, including at the email address on file in Form 5106, and contact their broker before November 18 if a correction or retransmission is needed.
For more information, visit: Accuracy of IOR data, 91 FR 53627
This update is provided by Concord Solutions Group for informational purposes and does not constitute legal advice.