U.S. Customs Tightens Importer of Record Rules

Key Takeaways

• CBP cancels IOR numbers starting March 20, 2026.
• New verification requires CBP 5106, ID, EIN, broker authorization.
• SAFE Act proposes stricter IOR eligibility, citizenship, physical presence.
• Compliance costs rise as customs intensifies entity authentication.
• Dual clearance models face uncertainty over responsibility boundaries.

Summary

U.S. Customs and Border Protection announced that, effective March 20, 2026, it will begin canceling Importer of Record (IOR) numbers for declarations submitted after 12:01 a.m. ET. Importers must now provide an updated CBP 5106 form, government‑issued photo ID, EIN verification and a broker authorization, with possible video or in‑person identity checks. The move follows recent “5H” inspections and aligns with the pending SAFE Act, which would further tighten IOR qualifications by requiring U.S. citizenship or physical presence and verified U.S. bank accounts. The heightened scrutiny targets the authenticity of the legal entities behind imports rather than the goods themselves.

Pulse Analysis

The U.S. customs landscape is undergoing a fundamental shift from inspecting individual shipments to scrutinizing the entities that file them. The recent wave of “5H” inspections exposed gaps in accountability, prompting CBP to tighten its focus on the Importer of Record. By treating the IOR as the legal gatekeeper for every entry, regulators aim to curb fraud, enforce tariff compliance, and ensure that the party responsible can be reliably identified.

Effective March 20, 2026, importers will be required to submit a refreshed CBP 5106 form, a government‑issued photo ID, proof of an EIN, and a signed authorization with a licensed customs broker. In some cases, CBP may demand video conferencing or in‑person verification to confirm the individual’s identity. Logistics providers are already reporting a surge in compliance queries, as the new documentation adds administrative overhead and may delay customs clearance for firms that lack a fully vetted IOR. Companies that rely on third‑party brokers or operate dual‑clearance models must reassess their contractual arrangements to avoid unexpected cancellations.

Legislatively, the SAFE Act—still pending Congress—signals an even tighter regime, mandating U.S. citizenship or verifiable physical presence for IORs and requiring duties to flow through U.S. bank accounts. While the bill is not yet law, its provisions are shaping industry expectations. Importers should proactively audit their IOR structures, invest in robust identity‑verification processes, and consider establishing a domestic legal entity if they lack one. Early adaptation not only mitigates the risk of shipment holds but also positions businesses to benefit from any “trusted trade partner” exemptions that may emerge.