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Authority Reinstatement Process: 2026 Walkthrough After Revocation or Inactivation

When operating authority is revoked or inactive, the cure path depends on why the authority lapsed. Walking through the reinstatement request, BMC-91 cure, and BOC-3 cure.

When authority lapses

FMCSA authority lapses for a few common reasons: (1) BMC-91 insurance lapse - registration stays in effect only while the carrier keeps its required insurance on file (49 USC §13906(a)(1)); (2) BOC-3 process-agent designation lapse; (3) a final Unsatisfactory safety rating, which leads to revocation (49 CFR §385.13(e)); (4) broker authority suspended when the BMC-84 bond or BMC-85 trust falls below $75,000 (49 CFR §387.307(e)); (5) voluntary revocation. A missed MCS-150 biennial update is different: it can lead to deactivation of the USDOT number (49 CFR 390.19T(b)(4)), and FMCSA's guidance is to file the missing update to reactivate it.

Each cause has a different cure path. The reinstatement request carries an $80 fee (49 CFR §360.3T), but the underlying issue must also be cured - FMCSA holds a reinstatement request until the insurance and BOC-3 filings are in place.

The cure paths

BMC-91 lapse - have your insurer file a new BMC-91, then request reinstatement. BOC-3 lapse - have a process agent file a new BOC-3, then request reinstatement. FMCSA controls the timing on both. MCS-150 deactivation - file the overdue MCS-150 (no separate fee); filing the update reactivates the USDOT number.

Compliance Review Unsatisfactory rating - this is the hardest path. The carrier must request a rating change in writing with evidence of corrective action (49 CFR §385.17); FMCSA reviews the request within 30 days for passenger and placardable hazmat carriers and 45 days for others, and the rating must be upgraded before operations resume.

During the lapse

A motor carrier with NOT AUTHORIZED status cannot legally operate. Operating as a for-hire property carrier without the required registration exposes the carrier to civil penalties under 49 USC §14901 - a minimum of $13,676 per violation under the current inflation-adjusted schedule in 49 CFR part 386, Appendix B.

Brokers check authority status before tendering loads, so a NOT AUTHORIZED carrier typically loses freight quickly after a lapse.

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Authority Reinstatement Process

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