Do I need to reapply or can I reinstate?
Reinstate if FMCSA will still reinstate your existing authority once the cause is cured. Re-apply if it won't. Reinstatement keeps the original MC number; a new application issues a new MC number and goes through FMCSA's new-applicant review.
Reinstatement fits when the revocation cause can be cured: insurance lapses, BOC-3 lapses, and unpaid penalties are fixed by getting the filing on record or paying, then paying the $80 reinstatement fee and submitting the reinstatement. FMCSA controls the timing. A missed MCS-150 is different: it deactivates the USDOT number (49 CFR 390.19T(b)(4)) and is fixed by filing the update. FMCSA has temporarily suspended enforcement and USDOT inactivation for biennial updates due on or after June 1, 2026; the update is still required.
A new application is needed when FMCSA will not reinstate the old authority. FMCSA makes that determination for the specific record.
The trade-off matters. Re-application means a new $300 OP-1 fee and a new MC number (losing the history shippers and brokers know), and a new application goes through FMCSA's new-applicant review, including the 10-day protest period after the FMCSA Register notice (49 CFR 365.203T); FMCSA controls the timing. Reinstatement keeps the existing MC number.
To see where you stand, look up the carrier in FMCSA's Motus public search (by USDOT number or company name) to check the current authority status in FMCSA's records.