What causes FMCSA to revoke an MC number?
The most common causes of MC revocation are insurance lapse (BMC-91 cancels and is not replaced), failure to maintain a current BOC-3 process-agent designation, failure to update USDOT biennially via MCS-150, failure to pay UCR (Unified Carrier Registration), unsatisfactory new-entrant audit, and serious safety violations resulting in §385 unfit fitness rating. Voluntary revocation (carrier requests deactivation) is also possible and follows the same procedural path.
Insurance lapse is the leading cause of involuntary MC revocation. When the BMC-91 cancels and the carrier fails to file replacement coverage, FMCSA initiates the §387 enforcement process: the operating authority is suspended, then revoked if the carrier does not remedy within the §387 timeline. Most insurance-lapse revocations happen within 60 days of the original cancellation effective date if no replacement is filed.
BOC-3 lapse is less common but does happen, typically when a carrier's process-agent provider loses Form BOC-91 standing and the carrier doesn't notice. The §366.4 obligation to maintain a current designation never goes away; if SAFER shows the BOC-3 status as expired or the named provider as unauthorized, FMCSA enforcement follows the §366 procedural path to revocation.
MCS-150 biennial updates under §390.19 are required every two years on the schedule keyed to the last digit of the USDOT number. Failure to update is treated by FMCSA as a sign of carrier non-existence; deactivation precedes revocation in this case. Carriers caught in the deactivation cycle file a fresh MCS-150 to reactivate; longer lapses may trigger more comprehensive reinstatement requirements.
UCR non-payment under 49 USC §14504a is another common cause. The UCR fees are due annually based on fleet size. Non-payment triggers state-level enforcement (registration suspension in the carrier's base state) which propagates to FMCSA via the SAFER federal-state coordination.
Safety-driven revocation under §385 is the most severe path — an unsatisfactory fitness rating after a compliance review, repeated OOS violations on PSP, or serious crashes leading to FMCSA out-of-service orders. These are rare for most carriers but always loom for high-volume operators with thin safety margins.