Importer of Record Numbers: CBP Deactivating Inactive Numbers and Voiding Inaccurate Form 5106 Records
CONCORD SOLUTIONS GROUP — TRADE COMPLIANCE UPDATE
CBP is enforcing two separate controls on importer of record (IOR) numbers. Under CSMS No. 69241265, ACE has applied an "Inactive for Entry Purposes" status since July 16, 2026 to any IOR number that has not been used to file an entry in 366 days. Under a Federal Register notice on the accuracy of IOR data (91 FR 53627, August 19, 2026), CBP has voided IOR numbers with inaccurate or incomplete CBP Form 5106 information since September 18, 2026.
Scale
International Trade Today reported on October 1, 2026, citing records obtained under the Freedom of Information Act, that CBP deactivated about 5.3 million IOR numbers for inactivity between June 30 and September 10, 2026. As of September 10, 599 had been reactivated. Those figures do not include numbers voided for inaccurate Form 5106 data.
Effect on entries
An inactive IOR number cannot be used to transmit ACE cargo release or entry summary transactions. Other functions, such as acting as consignee, filing drawback, securing bonds and filing ISF, are not affected. An importer that has not imported in the past year may first learn of the status when its broker's entry is rejected.
Reactivation and reestablishment
Under CSMS No. 69056621, a broker can reactivate an inactive number through ABI by retransmitting complete Form 5106 data. An importer without a broker can email a revised Form 5106 to a CBP Center Entry Specialist Team with "IOR reactivation request" in the subject line. A voided number is handled differently: CBP sends written notice to the email address on the Form 5106, and the importer reestablishes the number through IORProgram@cbp.dhs.gov with the subject line "Enforcing IOR Accuracy."
Form 5106 accuracy
The physical address must be the importer's own business location. It cannot be a registered agent, customs broker, freight forwarder, P.O. box or business service center. The email address and phone number must belong to the importer, not to its broker or another third party. Importers that import occasionally, or whose Form 5106 was filed years ago, should confirm their information with their broker before their next shipment.
For more information, visit: Accuracy of IOR data, 91 FR 53627
For more information, visit: CBP Trade Information Notice, Inactive for Entry Purposes
This update is provided by Concord Solutions Group for informational purposes and does not constitute legal advice.
