How to Start an NVOCC in Florida: Licensing, Bond, Tariff and Systems


By GDZ Computer Services · Updated 2026-10-21 · 8 min read · Blog › Florida and Caribbean trade

To start an NVOCC in Florida you form a business entity with the state, obtain an Ocean Transportation Intermediary license from the Federal Maritime Commission, furnish $75,000 in financial responsibility, and publish a tariff before you offer service. Then you need the people and systems to issue bills of lading, file with U.S. Customs and bill your customers correctly from the first shipment.

Key takeaways
  • Under 46 CFR 515.3, a person in the United States may not advertise, hold itself out or act as an OTI without a valid FMC license.
  • The license requires a qualifying individual with at least three years of OTI experience in the United States (46 CFR 515.11).
  • A U.S. NVOCC must furnish evidence of financial responsibility of $75,000 (46 CFR 515.21); an ocean freight forwarder needs $50,000.
  • Before service, an NVOCC submits Form FMC-1 and keeps its tariff open to the public in an automated tariff system (46 CFR 520.3).
  • The Florida entity, the FMC license and your operating systems should be planned together, because each depends on the others.

What an NVOCC is, and why the license comes first

A non-vessel-operating common carrier (NVOCC) is a common carrier that does not operate the vessels. It issues its own bills of lading to shippers, takes responsibility for the transportation, and buys space from the ocean carriers that do run ships. Together with ocean freight forwarders, NVOCCs are grouped as ocean transportation intermediaries (OTIs) under 46 CFR part 515.

The key rule is in 46 CFR 515.3: except as otherwise provided, no person in the United States may advertise, hold oneself out, or act as an ocean transportation intermediary unless that person holds a valid license issued by the Commission. A company is "in the United States" for this purpose if it is resident in, or incorporated or established under, U.S. law. In practice that means a Florida company should not quote ocean freight as an NVOCC, put up a website offering NVOCC service, or issue house bills until the license process is complete. The FMC's OTI page states it directly: U.S.-based companies or sole proprietors operating as ocean freight forwarders or NVOCCs are required to obtain a license.

Because the license is issued to a specific legal entity, the order of the steps matters. Form the company first, then apply for the license in that company's name.

Step 1: Register your business in Florida

Florida businesses are registered with the Florida Department of State, Division of Corporations, through Sunbiz. The Sunbiz e-filing page lists online filings for a Florida limited liability company, a profit corporation, a non-profit corporation, a limited partnership, and a fictitious name registration if you will trade under a name other than the legal entity name.

The choice between an LLC and a corporation is a tax and legal decision, so discuss it with your accountant and attorney. For FMC purposes it also determines who can be your qualifying individual: under 46 CFR 515.11(b) that is the sole proprietor, an active managing partner, an active corporate officer, or for an LLC one of the members or managers (or an equivalent position named in the operating agreement). Make sure the person with the required experience will hold one of those positions in the entity you form.

The FMC issues one license per applicant, in the applicant's name, regardless of how many trade names it uses (46 CFR 515.14(b)). Register any trade name you plan to use in Florida, and make sure the names on Sunbiz, your FMC application, your bond and your tariff all match.

Step 2: Apply for the FMC OTI license

The license application is Form FMC-18, submitted electronically through the FMC's filing system with the required fee (46 CFR 515.12). The FMC publishes notice of each application on its website, including the applicant's name and address and the name of the qualifying individual. The main eligibility tests are in 46 CFR 515.11:

  • Experience. The qualifying individual must have a minimum of three years' experience in OTI activities in the United States.
  • Character. The FMC may consider shipping-law violations, operating without a license, criminal history, undischarged bankruptcies, tax liens and judgments, and other information relevant to character.
  • Qualifying individual. The QI must hold the right position in the company, as described above.

Applications that are incomplete on their face may be rejected, and if the FMC asks for information you do not provide by its deadline, the application can be closed. Prepare employment history, references and company documents before you file. The current fee and form instructions are on the FMC website; this article does not quote the fee because it can change.

Step 3: Furnish the bond, insurance or other surety

Under 46 CFR 515.21, no person may act as an OTI unless it furnishes a bond, proof of insurance or other surety in the form and amount the Commission requires. The amounts in the regulation are:

Type of OTIFinancial responsibility (46 CFR 515.21)
Ocean freight forwarder in the United States$50,000
NVOCC in the United States (licensed)$75,000
Registered NVOCC (primary place of business outside the U.S.)$150,000
Amounts as published in the eCFR, read October 2026. Group bonds for associations are covered separately in 515.21(b).

A Florida company acting as an NVOCC therefore needs the $75,000 level, and one that also acts as an ocean freight forwarder should ask the FMC and its surety how the requirements apply to its combination of services. Timing matters too: under 46 CFR 515.14(a)(2), if proof of financial responsibility and, for an NVOCC, the Form FMC-1 are not received within 120 days of notice of conditional approval, the conditional approval becomes invalid and you must file a new FMC-18 with a new fee.

Step 4: Publish your tariff and file Form FMC-1

NVOCCs are common carriers, so they must keep tariffs open for public inspection in automated tariff systems showing their rates, charges, classifications, rules and practices (46 CFR 520.3). Before starting service under a published tariff, each common carrier electronically submits Form FMC-1 through the FMC website, giving its organization details and the location of its tariff and any publisher. Changes must be sent to the FMC within 30 calendar days. The regulation is blunt about the consequence of neglect: failure to maintain a tariff will result in revocation of an NVOCC's license.

Most small NVOCCs use a tariff publisher rather than building their own system. Many also use NVOCC Negotiated Rate Arrangements (NRAs) under 46 CFR part 532, which exempt qualifying rates from tariff rate publication. An NRA must be in writing, name the parties, and be agreed before the NVOCC receives the cargo, among other conditions in 46 CFR 532.5. The rules tariff, with your terms, surcharges and practices, still matters, so review both with your tariff publisher.

Step 5: Set up operations and systems from day one

Once licensed, the work is daily and detailed. Each shipment needs a booking with the underlying carrier, your own house bill of lading, U.S. Customs manifest data, export filing information where it applies, and an invoice that matches your tariff or NRA. Starting on spreadsheets is tempting, but the license renewal, audits and customer disputes all depend on records you can retrieve.

  1. Choose how you will issue and number house bills of lading.
  2. Decide how you will transmit manifest data to CBP through ACE, directly or through a provider.
  3. Link rating to your tariff and NRAs so invoices match what you published or agreed.
  4. Set up accounting so each bill of lading posts receivables and payables without retyping.
  5. Keep license, bond and FMC-1 dates in a calendar; licenses renew for sequential three-year periods under 46 CFR 515.14(c).

NVOCC software such as GDZ-ISIS was built for exactly this flow, from quotes and bookings to bills of lading, ACE manifest filing and accounting, and GDZ has supported it from Miami-Dade since 1985. If you are comparing options, our article on the NVOCC software features that matter is a good checklist.

Common mistakes new Florida NVOCCs make

Most problems for new NVOCCs come from doing the right things in the wrong order, or letting one piece lapse while focusing on sales:

  • Advertising or quoting NVOCC service before the license is issued.
  • Forming the company with a qualifying individual who does not hold an eligible position.
  • Letting the 120-day window after conditional approval pass without the bond and FMC-1.
  • Charging rates that are neither in the tariff nor in a valid NRA.
  • Missing a license renewal date or an FMC-1 update after moving offices or changing publishers.

None of this is legal advice. The FMC's Bureau of Certification and Licensing, your surety, your tariff publisher and a maritime attorney are the right people to confirm how the rules apply to your company.

Frequently asked questions

Do I need an FMC license to operate as an NVOCC in Florida?

Yes, if your company is in the United States. 46 CFR 515.3 says no person in the United States may advertise, hold itself out or act as an ocean transportation intermediary without a valid FMC license.

How much is the NVOCC bond?

46 CFR 515.21 requires a U.S. NVOCC to furnish evidence of financial responsibility of $75,000 by bond, insurance or other surety. An ocean freight forwarder needs $50,000, and a registered foreign NVOCC $150,000. The premium you pay is set by your surety, not the FMC.

How much experience do I need to get an NVOCC license?

The qualifying individual must have at least three years of experience in OTI activities in the United States (46 CFR 515.11). The QI must also hold an eligible position, such as an active corporate officer or an LLC member or manager.

Do NVOCCs have to publish a tariff?

Yes. 46 CFR 520.3 requires common carriers, including NVOCCs, to keep tariffs open for public inspection in automated tariff systems and to file Form FMC-1 before starting service. Failure to maintain a tariff results in license revocation. Qualifying NRAs under part 532 are exempt from rate publication.

How long is an FMC OTI license valid?

Under 46 CFR 515.14(c), the initial license period is between one and four years based on the license number, and licenses are then renewed for sequential three-year periods through the FMC's renewal process.

Sources

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