Insurance Cancellation and Authority Revocation: What Carriers Must Do
If your insurer cancels your policy, it files a cancellation notice with FMCSA, and your coverage on file ends 30 days after FMCSA receives that notice. If no replacement filing reaches FMCSA by then, your operating authority is revoked and you cannot legally run for-hire in interstate commerce. To fix it, you get a new insurance filing on record, make sure your BOC-3 is in place, and request reinstatement.
Key takeaways
- For-hire carriers of general freight in trucks of 10,001 pounds or more need at least $750,000 in liability coverage under 49 CFR 387.9. Some loads and vehicles need more.
- Your insurer, not you, files proof of coverage with FMCSA, usually on Form BMC-91 or BMC-91X.
- Under 49 CFR 387.313T(d), a filed policy can't be canceled until 30 days after FMCSA receives the insurer's Form BMC-35. That is your window to act.
- Once authority is revoked, you must stop for-hire interstate operations until it is reinstated.
- FMCSA charges $80 to request reinstatement of revoked authority, per 49 CFR 360.3T. Your insurance and BOC-3 must be on file first.
Minimum insurance FMCSA requires
49 CFR 387.7 says a motor carrier may not operate a motor vehicle until it has the minimum financial responsibility set in 387.9, and the coverage must stay in effect continuously. The minimums for property carriers are:
| Who | What you haul | Vehicle weight (GVWR) | Minimum |
|---|---|---|---|
| For-hire, interstate | Nonhazardous property | 10,001 lbs or more | $750,000 |
| For-hire and private | Oil, hazardous waste, and hazardous materials not in the $5 million group | 10,001 lbs or more | $1,000,000 |
| For-hire and private | Certain hazardous materials in bulk, certain explosives and poison gases, and highway route controlled quantities of radioactive material | 10,001 lbs or more | $5,000,000 |
| For-hire and private | Certain explosives, poison gases and radioactive material in the same high-hazard group | Under 10,001 lbs | $5,000,000 |
The table above comes from 49 CFR 387.9. Hazmat categories are detailed, so read the rule itself if you haul hazardous materials.
For-hire carriers running smaller trucks have a separate minimum. 49 CFR 387.303T sets $300,000 for for-hire carriers of nonhazardous property using vehicles under 10,001 pounds GVWR.
Passenger carriers fall under different rules. Under 49 CFR 387.33T, the minimum is $1,500,000 for vehicles seating 15 or fewer (including the driver) and $5,000,000 for vehicles seating 16 or more.
These are federal minimums. Shippers, brokers and lenders often ask for more.
How insurance filings work: BMC-91 and BMC-91X
Having a policy is not enough. For-hire carriers must have proof of coverage filed with FMCSA. FMCSA's FAQ is clear that insurance forms must be filed by the insurance company, not by the carrier or broker.
Under 49 CFR 387.313T:
- BMC-91 is the certificate an insurer uses when it covers the full required limits.
- BMC-91X is used for full limits or when several insurers combine to reach the limit. Each insurer makes its own filing.
- BMC-34 is used for cargo liability coverage, and BMC-83 is a cargo surety bond.
- Surety bonds use BMC-82 or MCS-82, depending on the type.
- The certificate must show your full, correct legal name. For a partnership, every partner must be named.
FMCSA has said in revocation decisions that a copy of your MCS-90 endorsement or a regular "certificate of insurance" is not acceptable proof. Only the filing from the insurer counts.
Brokers have a different requirement. They file a surety bond (BMC-84) or trust fund agreement (BMC-85), as listed in 49 CFR 365.109T.
How cancellation works: BMC-35 and the 30-day window
When an insurer wants to end a policy that is on file with FMCSA, it files a cancellation notice.
49 CFR 387.313T(d) says a certificate of insurance or surety bond on file can't be canceled or withdrawn until 30 days after FMCSA actually receives written notice. The notice goes on:
- Form BMC-35 for motor carrier insurance policies
- Form BMC-36 for surety bonds
The original section, 387.313, is suspended. The T version is the one in force, so cite 387.313T.
There is a second, separate notice rule. Under 49 CFR 387.7(b)(1), the insurer or the carrier can cancel the policy by giving the other 35 days' written notice. So you may hear from your insurer before FMCSA hears anything.
What FMCSA does next
In a 2017 notice, FMCSA described sending a first notice to the carrier a few days after receiving the insurer's cancellation, and issuing a final decision revoking authority if the carrier did not comply within 30 days. The exact steps may have changed since FMCSA moved registration to Motus, so check FMCSA's current instructions. Either way, don't count on a letter reaching you in time. Watch your record yourself.
What "revoked" means
When your authority is revoked:
- Your operating authority (MC or FF number) shows as inactive or revoked on your FMCSA record.
- You may not operate as a for-hire carrier in interstate commerce.
- Brokers and shippers who check your record will stop tendering loads.
- Running anyway exposes you to enforcement, including civil penalties and out-of-service orders. For new carriers, operating without required insurance is also one of the automatic-failure violations in a new entrant safety audit.
Your USDOT number may still be active, but that alone does not let you haul for-hire across state lines. You can check both with our USDOT check tool.
Common causes of insurance cancellation
Most revocations come from paperwork and timing problems, not from carriers choosing to go without insurance.
- Non-payment. A missed premium or a bounced payment is the most common cause.
- Switching insurers with a gap. The old insurer files a cancellation, but the new insurer's filing is late or never made.
- Policy changes. A rewrite, new policy number or change in named insured can trigger a cancellation and a new filing. If the new filing doesn't post, you have a gap.
- Name mismatch. If the filing doesn't match your legal name on your FMCSA record, it may not be accepted.
- Underwriting changes. An insurer may non-renew or cancel because of losses, violations or a change in operations.
- Financed premiums. If you finance your premium and miss a payment to the finance company, it may ask the insurer to cancel, which can lead to a cancellation filing.
Under 387.313T(e), when a new filing is accepted, the old insurer's liability ends on the replacement's effective date. That is how a clean switch is supposed to work. The key is making sure the new filing is on record before the old one drops off.
Ask your new insurer for proof the filing was made
When you change insurers, ask the new company to confirm that it filed your BMC-91 or BMC-91X with FMCSA, and on what date. Then check your record a few days later. Don't assume an agent handled it.
What to do if you get a cancellation notice
Act the same day. The 30-day window goes fast.
- Call your insurance agent. Find out why the policy is being canceled and whether it can be saved by paying a balance or fixing a problem.
- If you can't save it, get a new policy now. Line up a replacement that starts on or before the cancellation date.
- Make sure the new insurer files with FMCSA. It must be a BMC-91 or BMC-91X (or the right form for your type of authority) in your exact legal name.
- Check your FMCSA record. Confirm the new filing has posted before the old one ends.
- Check your BOC-3 too. Make sure your process agent designation is still active. See our BOC-3 guide.
- If you cannot get covered in time, park for-hire interstate operations until coverage is back on file.
How to reinstate revoked authority
If your authority has already been revoked, you need to fix the cause and ask FMCSA to reinstate it.
Step 1: Get a new insurance filing on record
Your insurer must file proof of coverage with FMCSA. Reinstatement cannot move forward without it.
Step 2: Confirm your BOC-3 is on file
FMCSA's reinstatement guidance says you must have your BOC-3 and your insurance filing in place before you request reinstatement. If they are not, the request is put on hold.
Step 3: Make sure your USDOT number is active
FMCSA's guidance says its systems will not accept a reinstatement request if your USDOT number is inactive or out of service. Your contact information should be current. If your number was deactivated, deal with that first. Our MCS-150 biennial update guide covers updating your record.
Step 4: Request reinstatement and pay the fee
FMCSA's fee schedule at 49 CFR 360.3T lists $80 for a petition for reinstatement of revoked operating authority. FMCSA's FAQ lists the same amount. Check FMCSA's site before you pay in case it has changed.
FMCSA's April 29, 2026 Federal Register notice on Motus lists reinstating an operating authority you held before as one of the things you can do in Motus. See our Motus registration guide for help getting into the system.
When reinstatement is not available
FMCSA's guidance says you can't request reinstatement if you were placed out of service as an imminent hazard or because of a final Unsatisfactory safety rating. Those cases follow a different path. Our guide to out-of-service order reinstatement explains them.
Household goods carriers: cargo insurance and BMC-34
Household goods (HHG) movers have an extra requirement. Besides liability coverage, they must carry cargo coverage.
Under 49 CFR 387.303T, HHG carriers must have cargo security of at least:
- $5,000 for loss or damage to household goods on any one vehicle, and
- $10,000 for loss or damage at any one time and place.
49 CFR 365.109T says HHG motor carriers and HHG freight forwarders show cargo coverage with Form BMC-34 (insurance) or Form BMC-83 (surety bond). A cargo filing that lapses can cause the same kind of authority problems as a liability lapse, so watch both.
How JMM Compliance can help
We can review your FMCSA record, spot a pending cancellation or missing filing, and walk you through what needs to happen and in what order. If your authority has been revoked, our out-of-service order service helps you line up the insurance filing, BOC-3 and reinstatement request. To catch problems before they become revocations, our compliance management service monitors your filings. We are not an insurance company or a law firm, so we don't sell policies or give legal advice, and FMCSA makes the final decision on reinstatement.
Need help with this?
We handle this for carriers every week. Get a free review of your USDOT record.
This page is general information, not legal advice. Requirements depend on your operation; confirm details with FMCSA or a qualified professional.
Related guides
- FMCSA Out-of-Service Order: How to Get ReinstatedGot an FMCSA out-of-service order? Learn why it happened, your deadlines, and the exact steps to reinstate your USDOT number for each type of order.
- How to Upgrade a Conditional Safety Rating (FMCSA 385.17)Stuck with a Conditional safety rating? Learn how to request a rating change under 49 CFR 385.17, what evidence FMCSA expects, and how long reviews take.
