CBP Form 5106: Create/Update Importer Identity Form Explained

Key Points

• CBP Form 5106, the Create/Update Importer Identity Form, establishes or updates an importer of record or ultimate consignee identity in ACE under 19 CFR 24.5, using an IRS EIN, an SSN, or a CBP-assigned number.
• The revised CBP Form 5106 has been accepted in ACE since March 16, 2019, with mandatory email and address-type data elements.
• A broker cannot file an entry for a party whose identity record does not yet exist, so CBP Form 5106 sits ahead of the first formal entry or first request for CBP services in the lifecycle.
• Stale CBP Form 5106 data drives returned mail, bond-sufficiency flags, and rejected entries, all of which are avoidable with routine maintenance.
• As of September 2026 CBP Form 5106 is in use and CBP says a further revision is in progress; confirm the current version and filing channel with CBP before you build a process around it.

On this page

1. What CBP Form 5106 is
2. At a glance
3. Who files CBP Form 5106 and when?
4. How is CBP Form 5106 transmitted?
5. What goes on CBP Form 5106?
6. What goes wrong with CBP Form 5106 and what it costs
7. How CBP Form 5106 relates to other CBP forms
8. Frequently asked questions
9. What importers and brokers should do
10. Key references

CBP Form 5106, the Create/Update Importer Identity Form, is the filing that registers a new importer of record or ultimate consignee with U.S. Customs and Border Protection, or updates an existing identity record, by tying a name and address set to an identification number: an IRS EIN, an SSN, or a CBP-assigned number. It is prepared by the importer, usually through its customs broker, and filed in ACE, and it is the first step in the entry lifecycle because no entry can be filed against an identity that does not exist in the system. CBP Form 5106 is a customs identity record governed by 19 CFR 24.5, not an IRS form.

The links in this article go to the primary documents: the regulation, the Federal Register notice, and CBP's own form and program pages themselves. Read the source. This entry is current as of September 2026.

At a glance

• Full name: CBP Form 5106, Create/Update Importer Identity Form.
• Who prepares or uses it: the importer of record or ultimate consignee, in practice usually completed and transmitted by the customs broker on the party's behalf.
• When in the lifecycle: before or with the first formal entry or the first request for CBP services, and again whenever the identity data changes.
• System or channel: ACE, through the ACE Portal or through ABI, or submitted to the applicable CBP Center of Excellence and Expertise; confirm the current accepted channels with CBP.
• Identification numbers accepted: IRS EIN, SSN, or a CBP-assigned number.
• Governing authority: 19 CFR 24.5.
• Status as of September 2026: in use, with a further CBP revision reported to be in progress.
• Related terms: CBP Form 3461, CBP Form 301, CBP Form 28, CBP Form 29, CBP Form 19, CBP Form 7512, CBP Form 214, CBP Form 216, CBP Form 7551, CBP Form 7552.

Who files CBP Form 5106 and when?

CBP Form 5106 is the responsibility of the importer of record or ultimate consignee whose identity is being created or updated, even when a licensed customs broker physically prepares and transmits it. The trigger is simple: a party that has never transacted with CBP needs an identity record in ACE before or with its first formal entry or its first request for CBP services. That includes a domestic buyer named as ultimate consignee on someone else's entry, which is why brokers routinely collect identity data for consignees as well as for the importer of record.

The second trigger for CBP Form 5106 is change. Company names change, legal entities reorganize, mailing addresses move, compliance contacts leave, and the email address CBP holds goes dead. Each of those is a reason to file an update. Treat CBP Form 5106 as a living record rather than a one-time onboarding chore, and put a recurring review on the compliance calendar so that the data CBP holds matches the data on the entry.

Brokers and powers of attorney

When a broker files CBP Form 5106 for a client, the broker is acting on the importer's authority and reporting the importer's own facts. The importer still owns the accuracy of those facts. Brokers should retain the signed source document from the client showing the exact legal name, the identification number in use, and the address set, so that the identity record in ACE can be reconciled against something other than an email thread.

How is CBP Form 5106 transmitted?

CBP Form 5106 is filed electronically in ACE, either through the ACE Portal by a user with the appropriate account access or through ABI by the broker's entry software, and it may also be sent to the applicable CBP Center of Excellence and Expertise. The revised form has been accepted in ACE since March 16, 2019, and that revision made email and address-type elements mandatory rather than optional, which is why records created before that date frequently fail validation when they are next touched.

Because filing mechanics and data element formats are set by the ACE CATAIR and can change between software releases, confirm the current transmission requirements, field lengths, and accepted address-type codes in the current ACE CATAIR or with CBP rather than relying on a stored template. The same caution applies to the further CBP Form 5106 revision reported to be in progress as of September 2026: check the CBP forms page for the operative version before printing or coding anything.

What goes on CBP Form 5106?

CBP Form 5106 collects the identity of the importing party and the identification number under which that party will transact: an IRS EIN, an SSN, or a CBP-assigned number for parties without a U.S. taxpayer number. Around that number, the form carries the party's legal name, its address information broken out by address type, and contact details including the now-mandatory email address.

Two practical points. First, the identification number on CBP Form 5106 is the same number that will appear as the importer of record number on entry filings, so a mismatch between the identity record and the entry is an immediate operational problem. Second, do not confuse CBP Form 5106 with IRS Form SS-4, which is how a business obtains an EIN in the first place. CBP Form 5106 does not issue a tax number; it registers an identity with CBP. For the exact current field list, work from the form itself on CBP's forms page.

What goes wrong with CBP Form 5106 and what it costs

The most common CBP Form 5106 failure is stale data, and its consequences land squarely on the entry desk. Outdated mailing addresses produce returned mail, which means notices and bills from CBP never reach the importer. Mismatched or incomplete identity data can raise bond-sufficiency flags against the party's CBP Form 301, Customs Bond, the surety bond, single transaction or continuous, securing duties, taxes, fees and compliance obligations to CBP under 19 CFR part 113. And an identity record that does not exist or does not validate produces rejected entries: the broker simply cannot file until the identity exists in ACE.

Returned mail is worse than an inconvenience. If a CBP Form 28, Request for Information, CBP's written request to an importer or its broker for documents or facts needed to appraise or classify entered goods, goes to a dead address, the importer never answers. The predictable next step is a CBP Form 29, Notice of Action, CBP's notice that it proposes or has taken action on an entry such as a rate advance, reclassification or value change, arriving after the window to respond usefully has narrowed. The fix for that chain of events is a current email address and a current mailing address on CBP Form 5106.

One myth to retire: do not assume an identification number is purged after a period of inactivity. That is not something to state as fact. If a dormant importer is about to resume importing, verify the record's status with CBP or through the ACE Portal rather than guessing.

How CBP Form 5106 relates to other CBP forms

CBP Form 5106 is the identity layer beneath every other document in the entry file. Once the identity exists, CBP Form 3461, Entry/Immediate Delivery, the release request asking CBP to release imported cargo from custody before the entry summary and now transmitted as ACE Cargo Release data, can name the importer of record and the ultimate consignee. Our companion entry on CBP Form 3461 walks through that release step.

Downstream, the address and contact data on CBP Form 5106 determines whether the importer actually receives a CBP Form 28 or a CBP Form 29, and whether it learns of a liquidation in time to consider CBP Form 19, Protest, the form, on paper or through the ACE Protest module, for contesting a CBP decision under 19 U.S.C. 1514.

The identity created by CBP Form 5106 also carries into specialized filings: CBP Form 7512, Transportation Entry and Manifest of Goods Subject to CBP Inspection and Permit, the now-electronic in-bond application for moving unentered goods under bond as IT, T&E or IE; CBP Form 214, Application for Foreign-Trade Zone Admission and/or Status Designation, which admits merchandise into an FTZ and elects zone status such as privileged foreign, nonprivileged foreign, domestic or zone-restricted; and CBP Form 216, Application for Foreign-Trade Zone Activity Permit, which requests CBP approval to manipulate, manufacture, exhibit or destroy merchandise inside a foreign-trade zone. Drawback claimants need a valid identity too, though the paper CBP Form 7551, Drawback Entry, was abolished with TFTEA drawback and claims are now filed electronically in ACE under 19 CFR part 190, and CBP Form 7552, Delivery Certificate for Purposes of Drawback, was likewise abolished and replaced by transfer records under 19 CFR 190.10.

Frequently asked questions

Is CBP Form 5106 an IRS form?

No. CBP Form 5106 is a CBP identity filing under 19 CFR 24.5. It uses an IRS EIN, an SSN, or a CBP-assigned number as the identifier, but it does not create a tax number and it is not IRS Form SS-4.

Does the ultimate consignee need a CBP Form 5106?

Yes, an ultimate consignee needs an identity on file, and CBP Form 5106 is how that identity is created or updated. Brokers commonly collect the data from the consignee even when the consignee is not the importer of record.

How often should CBP Form 5106 be updated?

CBP Form 5106 should be updated whenever the legal name, address, identification number, or contact information changes. Because email and address-type elements became mandatory with the version accepted in ACE since March 16, 2019, older records often need a refresh the first time they are touched.

Does CBP Form 5106 replace the customs bond?

No. CBP Form 5106 establishes identity; CBP Form 301, Customs Bond, secures the financial and compliance obligations. Both are needed, and weak identity data can trigger bond-sufficiency flags against the bond.

What importers and brokers should do

• Verify that every importer of record and ultimate consignee you file for has a current CBP Form 5106 identity in ACE, with a live email address and correct address types, before the next entry is transmitted.
• Add a periodic identity review to the compliance calendar, and file a CBP Form 5106 update immediately on any legal name, address, number, or contact change.
• Check the CBP forms page for the operative CBP Form 5106 version and confirm transmission requirements in the current ACE CATAIR, since CBP reports a further revision in progress as of September 2026.
• Keep the signed client source document behind each CBP Form 5106 filing so the ACE record can be reconciled to an auditable original.

Key references

• 19 CFR 24.5: the regulation governing the identification of importers and the filing of CBP Form 5106.
• CBP forms page: the authoritative source for the current CBP Form 5106 and its instructions.
• Federal Register: search for the notice of May 24, 2024 extending the Paperwork Reduction Act information collection for CBP Form 5106.
• 19 U.S.C. 1514: the protest statute behind CBP Form 19, relevant because notices reach importers through the address on CBP Form 5106.
• Harmonized Tariff Schedule: the official tariff schedule used on entries filed under the identity registered by CBP Form 5106.