If you import into the United States, one date matters more than the one being talked about. From 18 September 2026, CBP may void an importer of record number where the information on CBP Form 5106 is inaccurate or incomplete. That is a live enforcement date, and it arrives before any of the headline changes in the executive order behind it.
On June 3, 2026, President Trump signed an executive order titled “Strengthening Customs Enforcement”. This is not a tariff. It is a structural overhaul of who may act as an Importer of Record, what financial backing they must hold, and how they are vetted, and it draws a line between IORs with genuine US presence and the paper arrangements that have operated on the margins for years.
The distinction that matters throughout, and the one most coverage misses, is between what the order directs CBP to build, when CBP has been told to act, and what an importer must actually do today. This guide keeps those three apart, section by section.
If you read nothing else. Pull your CBP Form 5106 record before 18 September 2026 and confirm the physical address, telephone number and email belong to your business rather than to a broker, forwarder, PO box or service centre. That is the one item on this page with a live enforcement date attached. Everything else in the order is still being implemented.
What has changed since June 2026
Two developments since June have moved this from policy direction into initial implementation.
CBP has announced enhanced enforcement of importer identity data. On 19 August 2026 it published a Federal Register notice on verification of the data importers hold on CBP Form 5106, the form that establishes an importer of record’s legal identity. Beginning 18 September 2026, CBP may immediately void an IOR number where the information on file is inaccurate or incomplete, with notice sent to the most recent email address on the form. The commencement date runs 30 days from publication of the Federal Register notice.
The information must accurately identify the importer itself, including its physical business address and contact details. Using a broker’s or forwarder’s details, a PO box, or a business service centre address where they do not belong to the importer creates an obvious verification problem, and the certifying party carries legal responsibility for what it submits.
Brokers are now being asked to vet you. CBP has issued a CTPAT Alert on broker responsibilities (alert PDF) setting a higher standard of due diligence for CTPAT-validated brokers representing foreign IORs. Those brokers are expected to verify legal identity, ownership structure, business affiliations, US assets, compliance history and ability to pay duties, and to keep records of that vetting. The alert is guidance about implementation rather than the final regulation, but the practical effect is that broker onboarding for foreign IORs is becoming substantially more documentation-intensive.
Important: 18 September is a separate CBP action. It is not the 90-day deadline under Executive Order 14411. It is the date CBP begins enhanced enforcement of importer identity information associated with Form 5106, where inaccurate or incomplete information may result in the IOR number being voided. The order’s 90-day implementation milestone falls on 1 September 2026.
Where each change stands today
Three things get blurred in most coverage of this order: what the order directs DHS and CBP to build, when they have been directed to act, and what an importer actually has to comply with now. This table separates them, as at 24 August 2026.
| Change | Status | Key date |
|---|---|---|
| Form 5106 identity data verification | CBP enforcement announced | 18 September 2026 |
| Legislative recommendations | Order-directed milestone | 18 July 2026 |
| Heightened disclosure and certification | Steps to establish requirement, no fixed date in the order | Not specified |
| Penalty mitigation standards | Order-directed revision | 1 September 2026 |
| Foreign-export documentation | Steps to establish requirement | 1 September 2026 |
| IOR asset and bond standards | Implementation pending | 30 November 2026 |
| Good-standing framework | Implementation pending | 30 November 2026 |
| Foreign IOR restrictions | Implementation pending | 30 November 2026 |
| Risk-based IOR registry | Implementation pending | 30 November 2026 |
| Recurrent vetting | Implementation pending | 30 November 2026 |
What applies today, 24 August 2026.
The executive order does not automatically impose every future IOR requirement today. The immediately actionable CBP measure is the enhanced verification of Form 5106 information, beginning 18 September 2026. The remaining IOR eligibility, asset, bonding, good-standing, risk-tier and recurrent-vetting measures are being implemented through subsequent CBP and DHS actions. Distinguish between current requirements, announced implementation steps, and future requirements still awaiting implementation.
What is actually actionable today
Sorting the order into three categories is the most useful thing an importer can do with it.
- Already actionable: Form 5106 accuracy, your existing reasonable-care obligations, and the customs broker requirements that already apply.
- Implementation underway: CBP’s enhanced verification of Form 5106 data, the CTPAT broker activity, and the agency guidance now being issued.
- Future framework: IOR asset thresholds, increased bonding, good standing, foreign IOR restrictions, risk tiers, and recurrent vetting. These depend on the regulations and policies CBP adopts, so treat them as planning assumptions rather than present obligations.
What the Customs Enforcement Executive Order 2026 Actually Requires
The order rests on a premise stated in its own text: effective customs enforcement ensures importers of record are correctly identified and accountable for the duties they owe. The administration’s position is that loopholes, weak enforcement and outdated processes have let some importers undervalue goods, obscure who the real IOR is, and avoid paying duties through various arrangements. The order responds by tightening the requirements on every IOR, with the heaviest new obligations falling on foreign IORs and on any arrangement designed to obscure who is actually responsible for a shipment.
“Effective customs enforcement prevents the importation of unlawful and dangerous goods; ensures importers of record are correctly identified and accountable for duties owed; and guarantees compliance with numerous Federal laws.”
Strengthening Customs Enforcement, The White House, June 3, 2026
The core changes fall into five areas, each carrying its own compliance weight:
- Minimum assets and bonding: The order directs DHS and CBP to require every IOR to maintain a minimum level of tangible domestic assets, bonding, or both, as determined by CBP. The minimum required bond coverage for an IOR will increase
- Expanded data at registration: IORs must provide CBP with additional data including anticipated import volumes, year the entity was organised, ownership and beneficial ownership disclosures, business affiliation disclosures, and domestic asset disclosures
- Good standing requirement: The order directs DHS and CBP to require all IORs to maintain “good standing” with CBP, defined by the IOR’s and its affiliates’ history of compliance and payment of customs liabilities. The order provides that an IOR not in good standing would not be permitted to import or to designate a customs broker to act as IOR on its behalf
- Recurrent vetting: the order directs CBP to establish enhanced vetting procedures, including recurrent vetting, for all individuals and entities involved in importation, including foreign IORs, affiliates of IORs, customs brokers, custodians of bonded merchandise, and freight forwarders
- Risk-based IOR registry: the order directs CBP to update the IOR registry, remove inactive IORs, confirm active IORs are compliant, and create risk-based tiers based on compliance history, enforcement actions, and audit results
The 45, 90 and 180-Day Milestones Under EO 14411
Most coverage of this order treats it as a single December 2026 deadline. The reality is more complex and more urgent. The order sets separate implementation windows, and the earliest of them fall well before November, so treating this as a single year-end date understates the timeline.
| Deadline | Date | What the Order Directs by That Date | Impact on Importers |
|---|---|---|---|
| 45 days | 18 July 2026 | Legislative recommendations submitted to the President | Signals the scope of permanent statutory change ahead |
| 90 days | 1 September 2026 | Foreign exporter documentation requirement; 50% minimum penalty floor; streamlined seizure and disposal; transparency measures | Once implemented, the cost of a compliance error rises sharply, and origin-to-import documentation needs to align |
| 180 days | 30 November 2026 | IOR asset and bond minimums; foreign IOR informal entry ban; foreign IOR formal entry restrictions; good standing requirement; updated registry; recurrent vetting | Your current IOR arrangement may need to change once CBP implements the new standards |
| 1 year | 3 June 2027 | Effectiveness report to the President | Sets the direction for further tightening and possible legislation |
The 90-day window is the one most importers overlook, and it falls on 1 September 2026. The order directs DHS to take steps to revise penalty-mitigation standards, including a minimum floor of 50 percent of the assessed penalty absent exceptional national security circumstances, and elimination of mitigation for repeat offenders. These are implementation directions rather than a statement that the revised standards automatically become operative on 1 September. Once implemented, however, they could materially increase the financial consequences of a customs violation.
The New Line Between a US IOR and a Foreign IOR
The most consequential part of the order is its definition of a US IOR versus a foreign IOR. That distinction determines which entities could continue filing entries normally and which would face new restrictions, and it is drawn to close the loopholes paper IOR arrangements have used for years.
What Qualifies as a US IOR
Under the order, a US IOR is a US citizen or lawful permanent resident, or an entity organised under US law, located in the United States, whose controlling beneficial owners are US citizens or lawful permanent residents at all times. An entity may alternatively qualify by owning significant US real property, as determined by the Secretary. The order then defines “located in the United States” to prevent gaming: principal place of business in the US, physical presence where significant business activity occurs, and sufficient tangible US assets relative to the scale of operations.
The Anti-Shell-Company Provision
The order instructs the Secretary to issue guidance on “located in the United States” that prioritises preventing shell companies, sham transactions, and artificial corporate structuring from qualifying as a US IOR. A foreign company that set up a thin US shell with no real assets or genuine business activity specifically to file as a US IOR would not meet that standard.
The New Restrictions on Foreign IORs
A foreign IOR, defined as any IOR that does not meet the US IOR test, faces two specific new restrictions that change how it can operate:
- No informal entry: the order directs CBP to prohibit foreign IORs from filing informal entry, the simplified process generally used for low-value shipments, reasoning that such IORs are less familiar with US trade law and face lower penalties
- Restricted formal entry: a foreign IOR would not rely on a continuous bond except where CBP is satisfied revenue is fully protected, and would need CTPAT validation or a CTPAT-validated licensed broker to file
The combined effect of the framework the order directs would make lightweight foreign-IOR arrangements substantially harder to use once the relevant requirements are implemented. Companies currently relying on them should assess their structure before the framework is finalised. It must either meet the substantive US IOR test, work through a CTPAT-validated broker, or partner with a compliant US IOR that holds genuine domestic assets and bonding. For companies that have been importing through a foreign IOR or a thinly capitalised intermediary, this is the point at which those arrangements should be reassessed, before the new framework is implemented.
Is your current IOR exposed to the new foreign entity restrictions? Carra Globe’s Importer of Record structure is designed to provide a genuine US-present importing framework with domestic infrastructure, bonding and compliance controls that can be evaluated against the requirements CBP ultimately implements under Executive Order 14411.
Why This Hits Importers Who Thought Their Compliance Was Settled
The companies most exposed are not the ones cutting corners. They are importers who outsourced the IOR function years ago, were told it was handled, and have not examined it since. Three situations come up repeatedly.
The Importer Using a Foreign IOR Without Realising the Exposure
An IOR arrangement set up through an overseas supplier or logistics intermediary has worked to date. Under the framework the order directs CBP to implement, a foreign IOR would be prohibited from filing informal entries and would face continuous-bond restrictions plus a CTPAT requirement on formal entry. Goods that moved smoothly last quarter could face delay once CBP implements that framework, though the operating requirements depend on the regulations and guidance CBP issues. The importer did nothing wrong. The rules changed underneath the arrangement.
The Company Relying on a Thinly Capitalised IOR
Some IOR providers operate with minimal domestic assets and bonding, pricing aggressively precisely because they carry little financial backing. The requirements the order directs CBP to set could put pressure on providers with limited assets or bonding capacity. An importer relying on such a provider may find it cannot meet whatever minimums CBP eventually sets, which would mean arranging a change of IOR during the implementation window. Risk-based tiering could also make an IOR’s compliance history operationally significant.
The Business Whose IOR Has a Compliance History It Cannot See
The good standing direction would tie your ability to clear goods to the compliance history of your IOR and its affiliates. Many importers may not have visibility into that history, and under this framework it becomes directly relevant to whether their goods clear.
The Heightened Disclosure and Penalty Regime
Beyond the IOR rules, the order points to tighter disclosure and penalties for every importer regardless of how their IOR is structured. Two separate directions matter here, and they carry different timing.
Under Section 3(a) the Secretary is directed to take steps to establish heightened disclosure and certification requirements. These are expected to cover certification of compliance with critical supply chain laws such as CAATSA, disclosure of certain foreign tax and global business identifiers, and detailed supply chain and production information, including the manufacturer’s product identifier, model or style number and key specifications. No 90-day deadline attaches to this direction, so treat it as a requirement CBP has been told to build rather than one that applies on a fixed date.
The 90-day deadline in Section 3(b) applies to something narrower: a requirement for importers to submit documentation or information that the foreign exporter was required to provide to its own customs administration before exporting to the United States. The milestone falls on 1 September 2026. It is an implementation direction, not a statement that the documentation requirement automatically applies on that date, but it points to a significant new evidentiary burden and would give CBP a way to compare export-side and US-import declarations.
For companies managing complex supply chains, the practical preparation is to align the documentation chain from origin export to US import before the requirement is established.
On penalties the order is deliberately severe, directing CBP to enforce liquidated damages claims against bonds, restrict in-bond utilisation, increase audits, and impose maximum penalties on brokers who fail to conduct due diligence or repeatedly represent noncompliant clients. The 50% minimum penalty floor and the elimination of mitigation for repeat offenders mean the financial consequence of any compliance failure rises materially from September 2026. For the broader CBP audit environment that this order intensifies, see our analysis of the CBP customs audit landscape in 2026.
5 Actions US Importers Should Take Before the November 2026 IOR Milestone
- Confirm whether your IOR qualifies as a US IOR under the new definition. Ask directly: is the provider organised under US law, located in the United States with a genuine principal place of business and physical operations, and does it hold sufficient tangible domestic assets? If it is a foreign entity or a thin US shell, you need to know now. Our IOR services operate as a genuine US-present importer of record, with domestic assets, bonding and compliance infrastructure that can be assessed against the standards CBP ultimately sets
- Request written confirmation of your IOR’s bonding level and asset position. CBP is directed to set the thresholds within 180 days. A provider that will not confirm its bonding and asset position in writing makes it difficult to assess whether its structure can meet whatever CBP establishes. Build this into your vendor review before the thresholds are published
- Audit your IOR’s compliance history and good standing. Under the good standing direction, your ability to import would be tied to the compliance record of your IOR and its affiliates. Ask whether either has open enforcement actions, unpaid customs liabilities, or a history of violations. Risk-based tiering could make that history operationally significant
- Align your origin-to-import documentation chain before the September 90-day deadline. The 90-day milestone for establishing the foreign-export documentation requirement arrives first, so prepare for closer alignment between origin-side export documents and US import declarations. Review invoices, product identifiers, valuations and origin declarations across the chain, because any gap between the two becomes an obvious enforcement trigger. Use our landed cost guide to confirm your valuation methodology is documented and defensible
- Build a contingency IOR relationship now, not in November. If there is doubt about whether your current IOR survives, establish a compliant alternative during the implementation window. Companies that wait until the framework is finalised may have less time to evaluate options and complete any transition
How this fits the wider enforcement direction
This order does not stand alone. It is the structural counterpart to the trends already reshaping US imports in 2026: the suspension of de minimis treatment, the sharper CBP focus on valuation and origin fraud, and rising audit activity around misclassification and transshipment. The order explicitly prioritises enforcement against forced labour imports, misclassification, undervaluation and illegal transshipment under the Enforce and Protect Act. Companies that have shifted sourcing away from China should note the same order sharpens the tools CBP uses to challenge origin claims. See our guide to IOR and compliance gaps in the shift to Vietnam, India and Mexico.
Frequently Asked Questions
What is CBP Form 5106 and why does it matter now?
It is the form that creates and updates an importer of record’s identity with CBP. Beginning 18 September 2026, CBP may immediately void an IOR number when the information on file is inaccurate or incomplete.
The address, telephone number and email must belong to the importer itself, not to a broker, forwarder, PO box or service centre, and the certifying party is responsible for the accuracy of the submission.
When do the new IOR rules under the customs enforcement executive order take effect?
Executive Order 14411 directs DHS and CBP to take steps to implement the core IOR changes within 180 days of 3 June 2026, making 30 November 2026 the key implementation milestone.
That does not mean every new requirement automatically becomes legally effective on that date, because the actual operating requirements depend on the implementing regulations, guidance and policies CBP adopts. The order sets staggered deadlines rather than a single date. Legislative recommendations are due within 45 days, disclosure and penalty changes within 90 days, the main IOR overhaul within 180 days, and an effectiveness report within one year. Importers should treat September 2026 as the first hard date, not December.
What is the difference between a US IOR and a foreign IOR under the new order?
A US IOR is a US citizen, lawful permanent resident, or an entity organised under US law genuinely located in the United States, with a principal place of business, physical operations and sufficient tangible domestic assets. A foreign IOR is any IOR that does not meet this test, and it faces a ban on informal entry plus continuous-bond and CTPAT restrictions on formal entry.
The order specifically targets shell companies and artificial structures used to fake US IOR status. A thin US entity with no real assets or business activity would not qualify under the framework contemplated by the order. The distinction determines whether an IOR can continue operating normally or faces the new foreign IOR restrictions.
Can a foreign company still import into the US after this order?
Yes, though not through the lightweight arrangements many have used. Under the framework the order directs, a foreign company would need to qualify as a US IOR, use the foreign-IOR pathway CBP establishes, or restructure through a compliant US IOR.
The foreign-IOR pathway carries the informal-entry prohibition, continuous-bond restrictions, and the CTPAT or CTPAT-validated broker requirement for formal entry. Restructuring through a US-present entity that meets the applicable requirements avoids that pathway by placing that entity in the importer-of-record role.
What does the “good standing” requirement mean for my imports?
Good standing would tie your ability to import to the compliance history of your IOR and its affiliates, defined by CBP on the basis of compliance with customs laws and payment of customs liabilities. An IOR not in good standing would not be allowed to import or to designate a broker to act as IOR on its behalf.
Once implemented, the compliance record of your IOR provider would directly affect whether your goods clear, including where an affiliated company carries unpaid liabilities or enforcement history. That makes auditing your IOR’s standing worth doing during the implementation window rather than after it.
How do the new penalty rules change the cost of a compliance error?
The order directs DHS to revise penalty-mitigation standards within 90 days, including a minimum penalty floor of not less than 50 percent of the assessed penalty, absent exceptional national security circumstances, and eliminates mitigation entirely for repeat offenders. The ability to negotiate penalties down significantly is sharply reduced.
Combined with increased audits, enforcement of liquidated damages against bonds, and maximum penalties for brokers who fail due diligence, the financial consequence of any error rises materially. The practical effect is that proactive compliance is now far cheaper than reactive correction, because the relief that once softened penalties is being removed.
How does this order affect low-value and de minimis shipments?
Low-value flows could be among the most affected. The order directs CBP to prohibit foreign IORs from filing informal entry, the simplified process much low-value freight relies on, compounding the earlier suspension of duty-free de minimis treatment.
Once implemented, companies moving low-value goods through foreign IORs would need to operate within the foreign-IOR framework CBP establishes, rather than relying on informal entry. High-volume, low-value importers are the segment most exposed by the combined effect.
For companies importing IT hardware, medical devices, industrial equipment, and other regulated goods into the United States, the customs enforcement executive order makes the choice of importer of record a board-level supply chain decision.
Carra Globe’s Importer of Record team can help you review your current structure and plan a compliant US IOR arrangement where one is required. The immediate priority is to verify your existing IOR data and understand whether your present structure will remain workable as CBP implements the new requirements. To understand the IOR role in full before reviewing your current arrangement, see our explainer on what an Importer of Record is and does.
Disclaimer: This blog is for informational purposes only and does not constitute legal or customs advice. All details of the executive order are drawn from the official White House text of “Strengthening Customs Enforcement” dated June 3, 2026. Implementation specifics, including exact bond and asset thresholds, will be determined by US Customs and Border Protection through subsequent rulemaking. Always verify current requirements with a licensed customs broker or qualified trade counsel before making compliance decisions. This article reflects the status of publicly available CBP and DHS implementation actions as of 24 August 2026.