A company importing through three subsidiaries has three importer identities to look after: three IOR numbers, three Form 5106 records, and often three different people who set up ACE Portal access years ago.
This page is written for trade compliance, logistics, and finance teams keeping US CBP importer identity records current. Bond terms and renewals are tracked on customs bond tracking, and partner government agency licenses and permits on import license tracking. (General information only - not legal or customs advice. See Sources.)
Remindax tracks importing entities, IOR numbers you enter, Form 5106 dates, ACE account owners and users, update triggers, status, and documents you upload. It does not file forms, connect to ACE, contact CBP or your customs broker, or decide what your record needs. Check with your licensed customs broker or CBP.
1. What is customs registration tracking?
It is a dated record of every importing entity your company uses, one row per entity: the legal name, the IOR number, when CBP Form 5106 was first filed, when it was last updated, who owns the record internally, who owns the ACE Portal account, and which business changes since then have not been reflected yet.
CBP describes Form 5106, Create/Update Importer Identity, as the form used to create or update an importer identification number, also known as an Importer of Record number. CBP also says an individual or entity must have an IOR number to make entry or request certain CBP services that may result in a bill or refund.
1.1 What sits on each row
Legal name and IOR number
The entity as CBP knows it, its IOR number type (EIN, SSN, or CBP-assigned), and any division suffix.
Filed and last updated
When the record was created, when it was last updated, and who submitted the update.
Portal account owner and users
Who controls the ACE Portal account, the backup, and the date access was last reviewed.
Changes waiting on an update
Name, address, ownership, or EIN changes, each with the date it happened.
2. What does an importer register look like?
One row per importing entity, with the IOR details, the Form 5106 dates, the owners, and the status. The example is illustrative.
| Entity | IOR type | 5106 last updated | ACE account owner | Open trigger | Status |
|---|---|---|---|---|---|
| Parent Co. Inc. | EIN, suffix 00 | Mar 4, 2025 | Trade compliance lead | None | Current |
| Parent Co. - Tools division | EIN, suffix A1 | Mar 4, 2025 | Trade compliance lead | None | Current |
| West Coast Subsidiary LLC | EIN | Jun 18, 2021 | Former logistics manager | Warehouse moved Aug 3, 2026 | Update needed |
| Acquired Brand Ltd. (foreign) | CBP-assigned | Not on file | Unknown | Ownership change Sep 1, 2026 | Needs owner |
Illustrative register only. Entities, owners, and dates are invented.
Two problems stand out. The subsidiary moved its warehouse two months ago, its record has not been touched in five years, and its ACE account belongs to someone who left. The acquired brand has an ownership change and no known record owner at all.
3. Which Form 5106 dates and update triggers should you track?
CBP says it is the responsibility of the trade community to make sure the information on Form 5106 is accurate and complete, and that the information on file should remain accurate and up to date. CBP lists the required information as the name, the EIN, SSN, or CBP-assigned number, the mailing address, the physical location address, a phone number, an email address, and a signed certification.
Name change
A rename, rebrand, or new legal name. Record the effective date on the entity row.
Address change
A new mailing address or physical location. CBP says the physical address must be the actual location, not a broker, forwarder, registered agent, or P.O. box.
Ownership change
An acquisition, merger, or new officers. Record the closing date.
EIN or contact change
A new EIN, phone number, or email address. CBP says the email and phone must be valid and belong to the IOR.
Remindax records the change date, reminds the record owner, and keeps the row open until the update confirmation is uploaded. What the change means for your record is a question for your licensed customs broker or CBP.
3.1 Is there a renewal date?
The CBP pages checked for this article do not state a fixed renewal period for an IOR number or Form 5106. What CBP does publish is a list of reasons it may void an importer record, including inaccurate data, duplicate records, an EIN or SSN that cannot be verified, and returned mail. In an August 19, 2026 Federal Register notice, CBP said it will void IOR numbers when it finds the information provided is incomplete or inaccurate. CBP's FAQ also refers to inactive importer records that can be reactivated. Set your own review date on each row and confirm status with your customs broker or CBP.
4. How do you track ACE Portal account owners and users?
CBP describes the Automated Commercial Environment (ACE) as the centralized system for processing imports and exports, and the ACE Secure Data Portal as the web-based entry point that gives account holders access to their data. CBP also says a company must first set up an ACE Portal account and grant user access before using it.
| Field | Example | Why it matters |
|---|---|---|
| Account owner | Trade compliance lead | The person who controls access |
| Backup owner | Finance controller | Someone who can act if the owner is away or leaves |
| Users | 3 internal, 1 broker contact | Who can see the data today |
| Last access review | Apr 15, 2026 | Starts the next review reminder |
Illustrative fields only. Review cadence is your team's choice, not a CBP rule.
Track who holds access, not passwords; keep credentials in your password manager.
5. Which related renewals should be linked to the importer row?
The importer identity is the anchor. Other import and export records with their own clocks can sit as linked rows on the same entity, so a change to the entity shows everything it touches:
Customs bond
Bond term and renewal dates live on customs bond tracking, linked to the importer row.
Import licenses and permits
Partner government agency licenses and permits live on import license tracking.
6. Which owner model works for importer records?
Split the work by who hears about changes first, then give one person the full view of every entity:
Trade compliance lead
Owns the register, the broker relationship, and update status.
Legal or finance
Logs name, ownership, and EIN changes as trigger dates.
Logistics manager
Logs warehouse and address moves, and reviews ACE users.
6.1 An example escalation ladder
- ✓Trigger date logged: the record owner is reminded the same day to check whether the importer record needs an update.
- ✓14 days with no update confirmation uploaded: the trade compliance lead is reminded again and the logistics director is copied.
- ✓ACE access review due: the account owner is reminded by Email, SMS, or WhatsApp.
- ✓Account owner leaves: the row turns to needs owner and escalates until a new owner is named.
Offsets are examples your team sets. Logistics teams can keep these rows next to carrier and warehouse dates in logistics tracking, and compliance teams alongside other regulatory dates in compliance tracking software.
7. How Remindax tracks importer records
Remindax is date-and-status tracking - not a customs filing system, broker portal, or ACE connection:
Every entity on one register
IOR details, Form 5106 dates, owners, and documents, grouped by parent company.
Changes as trigger dates
Name, address, ownership, and EIN changes, each with an owner and an open status.
Access owners with review dates
ACE account owner, backup, users, and the next access review.
Linked import and export rows
Bonds, licenses, and registrations attached to the entity they belong to.
Remindax does not file or check Form 5106, connect to ACE, verify your record with CBP, or tell you whether a change needs an update. It holds the dates, owners, status, and documents you choose to upload, on AWS hosting with encryption. GDPR-ready.
Manufacturers that import parts and materials through several entities can see these rows with plant and supplier dates in manufacturing management software.
8. Why spreadsheets fail for importer records
A spreadsheet can list every IOR number. It cannot tell you the warehouse moved and nobody updated the record.
- xNo alert when a business change is logged
- xLast-updated dates go stale for years
- xACE access stays with former staff
- xAcquired entities never get a row
- xNo proof of when an update was made
- ✓Reminders the day a trigger is logged
- ✓Review dates on every entity row
- ✓Named ACE owners with access reviews
- ✓Needs-owner status for new entities
- ✓Update confirmations uploaded to the row
9. Key takeaways
- ✓Track one row per importing entity, including each EIN division suffix, with IOR type, Form 5106 filed and last-updated dates, and a named record owner.
- ✓Log name, address, ownership, and EIN changes as trigger dates so the record owner is reminded to raise them.
- ✓Record the ACE Portal account owner, backup, users, and the next access review date.
- ✓Do not assume a renewal cycle for the IOR record; set your own review date and confirm status with CBP or your customs broker.
- ✓Remindax tracks dates and status and reminds by Email, SMS, and WhatsApp. It does not file forms, connect to ACE, or give legal or customs advice. Free to start.
10. Frequently Asked Questions
It covers the dates and owners behind each importing entity's CBP identity: the importer of record (IOR) number, when CBP Form 5106 was filed and last updated, the ACE Portal account and its account owner and users, and the business changes that should trigger an update. Each entity gets one row, with related records such as the customs bond and import licenses linked to it.
CBP describes Form 5106, Create/Update Importer Identity, as the form used to create or update an importer identification number, also known as an Importer of Record number. CBP says an individual or entity must have an IOR number to make entry or request certain CBP services that may result in a bill or refund.
The CBP pages checked for this article do not state a fixed renewal period for an IOR number or Form 5106. CBP does say it can void importer records, for example for inaccurate data, duplicate records, identifiers that cannot be verified, or returned mail. Confirm the status of your record with CBP or your customs broker, and track the date you last confirmed it.
This page covers the importer identity record and who owns it. Bond terms, amounts, and renewals are tracked on customs bond tracking, and partner government agency licenses and permits on import license tracking. Both can sit as linked rows on the same entity.
No. Remindax tracks dates, owners, status, and documents you upload, and sends reminders. It does not file forms, connect to ACE, or contact CBP or your customs broker, and it does not give legal or customs advice. Data sits on AWS hosting with encryption, and Remindax is GDPR-ready.
Yes - a forever-free plan, no credit card required.
Sources & References
Public reference material for US CBP importer identity records - not legal or customs advice. Sources checked October 12, 2026. CBP is revising Form 5106 and its requirements can change, so confirm the current position with CBP or your licensed customs broker. This page does not provide filing instructions.
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