FMC Qualification Renewal for Vietnam-Based NVOCCs: FMC-65 Renewal or FMC License Renewal?

Direct Answer

Vietnam-based NVOCCs should first identify whether they are operating under a foreign NVOCC registration or an FMC-issued OTI license before starting FMC renewal.

These are two different renewal processes.

For a foreign-based registered NVOCC, the Federal Maritime Commission states that registration is effective for three years and renewal is completed using the online Form FMC-65. Registered NVOCCs receive renewal instructions by email no more than 30 days before the renewal date, and there is currently no renewal fee.

For FMC-licensed OTIs, the renewal schedule is based on the FMC license number. The Commission provides a structured renewal schedule and currently charges no renewal fee.

Navigator International can support Vietnam-based U.S.-route NVOCCs with both foreign registration renewal and FMC license renewal review, together with bond, tariff, public-record and related U.S.-route compliance support.

Step 1: Identify Your Current FMC Type

Before looking at documents or renewal dates, determine which status the Vietnam-based company currently holds.

Foreign Registered NVOCC

This generally means the company:

• Is based outside the United States
• Does not hold an FMC-issued NVOCC license
• Uses Form FMC-65 registration
• Maintains the applicable financial responsibility
• Reports tariff publication through Form FMC-1

The FMC OTI List states that foreign-based NVOCCs shown as compliant have a current Form FMC-65, required financial responsibility and a current Form FMC-1.

FMC-Licensed NVOCC

A Vietnam-based company may instead hold an FMC-issued license, typically through a qualifying U.S. branch structure.

That company follows the FMC OTI license renewal process rather than the foreign registration renewal process.

Step 2: Check the Exact Renewal Date

Do not estimate the renewal deadline based on the original application date.

For foreign registered NVOCCs, the FMC states that the OTI List includes the date by which each company must renew its registration.

Vietnam-based NVOCCs should verify:

• Legal company name
• FMC organization number
• License number, if applicable
• Current FMC status
• Renewal date
• Contact email
• Current internal compliance owner

This becomes especially important if the employee who previously handled FMC matters has changed.

Step 3: Understand the FMC-65 Renewal Process

For a Vietnam-based foreign registered NVOCC, registration lasts three years.

The FMC states that:

• Renewal is completed through the online FMC-65 process.
• Renewal instructions are emailed no more than 30 days before the renewal date.
• There is currently no renewal fee.
• The renewal date can be confirmed through the OTI List.

The current FMC forms page also separately identifies FMC-65 for new applications/changes and FMC-65 Renewals for foreign-based unlicensed NVOCCs.

Step 4: Understand FMC License Renewal

A Vietnam-based NVOCC holding an FMC license follows a different schedule.

The FMC’s current license renewal guidance says the company may self-complete the renewal or assign it to a third party, such as an attorney or FMC practitioner. The renewal system presents information already on file for the licensee to confirm or update. There is currently no license renewal fee.

For licensed Vietnam-based NVOCCs, review:

• FMC license number
• Renewal month and year
• Qualifying individual information
• U.S. branch information
• Contact details
• Bond status
• Form FMC-1
• Current operating identity

Step 5: Review Changes Before Renewal

Renewal should not simply repeat old company information.

The FMC states that Form FMC-65 must be filed by a non-U.S.-based registered NVOCC when information reported on the original registration changes.

A Vietnam-based NVOCC should review whether it has changed:

• Legal company name
• Trade names
• Principal place of business
• Contact person
• Email address
• U.S. legal agent
• Corporate structure
• Operating identity

The current Form FMC-65 itself includes fields for legal name, trade names, principal place of business, contact details and the U.S. legal agent.

Step 6: Review NVOCC Bond Continuity

FMC renewal should be coordinated with financial responsibility.

The FMC currently requires:

• $75,000 for licensed non-U.S.-based NVOCCs
• $150,000 for unlicensed non-U.S.-based registered NVOCCs

Before renewal, check:

• Bond amount
• Bond number
• Surety company
• Principal legal name
• Trade names
• Address
• Effective status
• Cancellation notice
• Bond riders
• Replacement timing

The FMC also publishes foreign NVOCC registration terminations and suspensions, including current 2026 notices, which is another reason to monitor status rather than assuming registration remains active automatically.

Step 7: Check Form FMC-1 and Tariff Status

Form FMC-1 should be part of the renewal review.

The FMC OTI List states that foreign-based NVOCCs need current tariff publication information through Form FMC-1 to appear on the compliant active list. It also specifically notes that NVOCCs without an active Form FMC-1 are not considered compliant for inclusion on that list.

Vietnam-based companies should therefore verify:

• Tariff publisher
• Tariff location
• Legal name
• Trade names
• Contact information
• Current public tariff access
• Internal tariff maintenance responsibility

Step 8: Verify Public FMC Status After Renewal

Once renewal is completed, check the public OTI List again.

Verify:

• Company name
• Organization number
• License number, if applicable
• Renewal date
• Address
• Trade names
• Active status

This can support:

• Carrier onboarding
• Customer due diligence
• Overseas partner verification
• Internal compliance records
• Sales team verification links

Vietnam FMC Renewal Service Scope

Navigator International can support Vietnam-based NVOCCs with:

• FMC-65 renewal review
• Foreign registration renewal support
• FMC license renewal review
• Renewal date verification
• NVOCC bond review
• Bond continuity support
• Form FMC-1 review
• Tariff information review
• Legal name and trade name review
• Public OTI List verification
• HBL consistency review
• SCAC-related support
• AMS account support
• ISF-related coordination
• Post-renewal compliance review

Renewal Decision Table

Common Mistakes

Mistake 1: Using the Same Renewal Process for Every Vietnam NVOCC

Foreign registration renewal and FMC license renewal are different.

Mistake 2: Waiting for the Email to Start Preparing

Foreign registered NVOCCs receive renewal instructions no more than 30 days before the due date, but the renewal date is already available through the OTI List.

Mistake 3: Renewing Without Checking Changed Information

Changes to original Form FMC-65 information should be reported.

Mistake 4: Ignoring Bond Continuity

Financial responsibility remains a core part of active NVOCC status.

Mistake 5: Forgetting Form FMC-1

An active Form FMC-1 is part of the compliant NVOCC profile on the FMC OTI List.

FAQ

Can Navigator International support FMC renewal for Vietnam-based NVOCCs?

Yes. Navigator International can support Vietnam-based U.S.-route NVOCCs with foreign registration renewal, FMC license renewal review, NVOCC bond handling, Form FMC-1 tariff review and related U.S.-route compliance support.

How often does a foreign registered NVOCC renew?

The FMC states that foreign-based NVOCC registrations are effective for three years.

Is FMC-65 renewal the same as FMC license renewal?

No. FMC-65 renewal applies to foreign-based registered NVOCCs that are not licensed. FMC-issued license holders follow the separate OTI license renewal process.

Is there currently a renewal fee?

The FMC currently states that there is no fee for foreign NVOCC registration renewal and no fee for OTI license renewal.

How can a Vietnam NVOCC check its renewal date?

Foreign registered NVOCC renewal dates are shown on the FMC OTI List.

Should the bond and Form FMC-1 also be checked?

Yes. Both financial responsibility and current tariff information are part of an active NVOCC compliance profile.

Final Takeaway

Vietnam-based NVOCCs should first determine whether they are renewing a foreign registration or an FMC-issued license.

The renewal process, renewal date, company information, NVOCC bond, Form FMC-1 tariff record and public OTI List status should then be reviewed together.

Navigator International can support Vietnam-based U.S.-route freight forwarders and NVOCCs with FMC qualification renewal, FMC-65 renewal support, FMC license renewal review, NVOCC bond handling, tariff-related review, public record verification, SCAC, AMS, ISF and related U.S. shipping compliance services.