DOT deactivation vs revocation: two different severity levels
USDOT deactivation and operating authority revocation are two different things. USDOT deactivation affects the USDOT number and can follow a missed MCS-150 biennial update under 49 CFR §390.19T: a missed biennial update can lead to civil penalties and deactivation of the USDOT number (49 CFR 390.19T(b)(4)). Note: FMCSA has temporarily suspended enforcement of biennial updates and USDOT inactivation for updates due on or after June 1, 2026, until further notice. It is addressed by filing an updated MCS-150 through FMCSA's Motus system (motus.dot.gov). Operating authority revocation affects operating authority under 49 CFR Part 365 (insurance on file under Part 387 and a BOC-3 under Part 366) and happens for other reasons - for example, when required insurance lapses or a BOC-3 (FastBOC3Filing) is no longer on file. Fixing revoked authority means fixing that underlying cause and going through a separate reinstatement with FMCSA. Both statuses can be checked in FMCSA's Motus public search by USDOT number or company name.
Side-by-side comparison
| Dimension | Deactivation | Revocation |
|---|---|---|
| What it affects | USDOT number | Operating authority (49 CFR Part 365) |
| Typical cause | Missed §390.19T biennial MCS-150 update | Other reasons, e.g. insurance lapse (Part 387) or no BOC-3 on file (Part 366) |
| Caused by a missed MCS-150? | Can be (§390.19T(b)(4)) | No |
| How it is resolved | File an updated MCS-150 in Motus | Fix the underlying cause, then a separate reinstatement with FMCSA |
Deactivation in detail
USDOT deactivation is tied to the USDOT number and the §390.19T biennial MCS-150 update. A missed biennial update can lead to civil penalties and deactivation of the USDOT number (49 CFR 390.19T(b)(4)). Note: FMCSA has temporarily suspended enforcement of biennial updates and USDOT inactivation for updates due on or after June 1, 2026, until further notice. The biennial due month is set by the last digit of the USDOT number and the odd or even year by the next-to-last digit; the update is due by the last day of that month.
To address it, the carrier files an updated MCS-150 in FMCSA's Motus system. Filing with FMCSA is free. FMCSA controls when the update shows in its records.
Revocation in detail
Revocation applies to operating authority under 49 CFR Part 365, which depends on insurance on file under Part 387 and a BOC-3 under Part 366. FMCSA revokes operating authority for reasons other than the MCS-150 - for example, when required insurance on file lapses and is not replaced, or when no BOC-3 is on file. It is a separate process from USDOT deactivation.
Revoked MC authority requires a separate reinstatement: the carrier fixes the underlying cause (for example, getting required insurance filed again) and then goes through FMCSA's reinstatement process. Filing an MCS-150 alone does not reinstate revoked authority.
How to check your status
You can look up a carrier in FMCSA's Motus public search by USDOT number or company name. Check both the USDOT status and any operating authority status - they are separate records and can differ.
Frequently asked questions
What is the difference between USDOT deactivation and authority revocation?
They apply to different registrations. USDOT deactivation affects the USDOT number and can follow a missed MCS-150 biennial update: a missed biennial update can lead to civil penalties and deactivation of the USDOT number (49 CFR 390.19T(b)(4)). Note: FMCSA has temporarily suspended enforcement of biennial updates and USDOT inactivation for updates due on or after June 1, 2026, until further notice. Operating authority revocation affects operating authority under 49 CFR Part 365 and happens for other reasons, such as required insurance on file under Part 387 lapsing or a BOC-3 under Part 366 not being on file.
Does a missed MCS-150 revoke my operating authority?
No. The MCS-150 is about the USDOT number, not operating authority. A missed biennial update can lead to civil penalties and deactivation of the USDOT number (49 CFR 390.19T(b)(4)). Note: FMCSA has temporarily suspended enforcement of biennial updates and USDOT inactivation for updates due on or after June 1, 2026, until further notice. Operating authority revocation is a separate action tied to other requirements, such as insurance.
How is each one resolved?
A USDOT number deactivated for a missed biennial update is addressed by filing an updated MCS-150 in FMCSA's Motus system; FMCSA controls when the update shows in its records. Operating authority revoked for another reason, such as an insurance lapse, requires fixing the underlying cause and a separate reinstatement with FMCSA.
Related comparisons
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