DOT compliance guide for motor carriers

Does FMCSA apply to you?

The Federal Motor Carrier Safety Regulations (FMCSRs, 49 CFR Parts 350–399) apply to companies that operate commercial motor vehicles (CMVs) in interstate commerce. Interstate means the trip, or the cargo's journey, crosses a state line, even if your truck never leaves your state. 49 CFR 390.5

For these rules a vehicle is a CMV if it:

• has a gross vehicle weight or weight rating (or combination) of 10,001 pounds or more;
• is designed or used to carry 9 to 15 passengers (including the driver) for compensation, or 16 or more passengers not for compensation; or
• carries hazardous materials in a quantity that requires placards.

Purely intrastate carriers usually fall under their state's rules instead, and most states have adopted much of the federal standard. See state requirements.

USDOT number & Motus

Interstate motor carriers that operate CMVs must register with FMCSA and get a USDOT number, which identifies your company in inspections, audits, crash records, and safety data. Many states also require a USDOT number for intrastate carriers. 49 CFR 390.19T

Operating authority, insurance & BOC-3

A USDOT number alone is not enough if you are for-hire in interstate commerce (hauling other people's regulated goods or passengers for pay), or if you are a broker or freight forwarder. You also need operating authority from FMCSA, which today is still tracked by an MC, FF, or MX docket number.

• Insurance filing. Your insurer files proof of financial responsibility with FMCSA. For-hire carriers of general (non-hazardous) freight in vehicles of 10,001 pounds or more need at least $750,000 in coverage; higher minimums apply to certain hazardous materials and to passenger carriers. 49 CFR Part 387
• BOC-3. You must designate a process agent in each state where you operate, usually through a blanket BOC-3 filing by a process agent company. 49 CFR Part 366
• Brokers must also keep a $75,000 surety bond or trust fund on file. 49 CFR 387.307

Authority does not become active until the required filings are in place. FMCSA: Get Registered

MCS-150 biennial update

Every entity with a USDOT number must update its registration (Form MCS-150, or MCS-150B/C) every 24 months, even if nothing has changed, the company stopped interstate operations, or it is no longer in business. Updating is free. 49 CFR 390.19T(b)

The next-to-last digit sets the year: odd digit, file in odd-numbered years; even digit, file in even-numbered years. An update filed in the 12 months before your due date counts. Missing it can lead to USDOT deactivation and civil penalties.

Unified Carrier Registration (UCR)

UCR is a separate annual registration and fee for interstate motor carriers, brokers, freight forwarders, and leasing companies, run by the UCR Plan and participating states. It is not the same as your USDOT number or MCS-150. Fees are set by fleet size (brokers, freight forwarders, and leasing companies pay the lowest bracket). Registration for the next year opens October 1, and states begin enforcing the new year on January 1.

Current UCR fee brackets · UCR Plan

Drug & alcohol testing

Employers of drivers who need a CDL must run a DOT drug and alcohol testing program that follows 49 CFR Part 382 and the DOT testing procedures in Part 40. 49 CFR Part 382 The program includes:

• Pre-employment drug test, with a verified negative result before the driver performs safety-sensitive work.
• Random testing. For 2026 the FMCSA minimum annual rates are 50% for drugs and 10% for alcohol of the average number of driver positions. 49 CFR 382.305
• Post-accident, reasonable suspicion, return-to-duty, and follow-up testing.
• A written policy, driver education materials, and a Designated Employer Representative (DER).
• Supervisor training: supervisors who make reasonable-suspicion decisions need at least 60 minutes of training on alcohol misuse and 60 minutes on controlled substances. 49 CFR 382.603

Owner-operators with no other drivers cannot run a random program on themselves; they must join a consortium/third-party administrator (C/TPA). DOT random testing rates

Drug & Alcohol Clearinghouse

The FMCSA Clearinghouse is a national database of CDL drivers' drug and alcohol program violations. 49 CFR 382.701

• Before hiring a CDL driver, run a full query; the driver must give electronic consent in the Clearinghouse.
• At least once a year, query every CDL driver you employ. A limited query (with the driver's written general consent) satisfies this; if it shows information exists, you must run a full query within 24 hours or take the driver off safety-sensitive work.
• Employers (or their C/TPA) must report violations such as refusals and actual-knowledge violations; MROs report verified positives.
• Employers must buy a query plan and register; a C/TPA can run queries for you if you designate it.

Since November 18, 2024 (“Clearinghouse II”), states must remove the commercial driving privilege of drivers in “prohibited” status until they complete the return-to-duty process. FMCSA Clearinghouse

CDL & entry-level driver training

A commercial driver's license is required for vehicles with a gross combination weight rating of 26,001 pounds or more (when towing over 10,000 pounds), single vehicles of 26,001 pounds or more, vehicles designed for 16 or more passengers, and placarded hazmat loads. 49 CFR Part 383

Since February 7, 2022, people getting a Class A or B CDL for the first time, upgrading, or adding a passenger, school bus, or hazmat endorsement must first complete entry-level driver training from a provider listed on FMCSA's Training Provider Registry. 49 CFR Part 380

Driver qualification (DQ) files

You must keep a qualification file for every CMV driver you employ, including part-time drivers. 49 CFR 391.51 It generally contains:

• The driver's employment application 391.21
• A motor vehicle record (MVR) from every state the driver held a license in the past 3 years, requested within 30 days of hire 391.23
• Safety performance history from DOT-regulated employers in the previous 3 years, including drug and alcohol history 391.23
• A road test certificate or an accepted equivalent, such as a valid CDL 391.31 / 391.33
• The medical examiner's certificate (and, for CDL drivers, the MVR showing medical certification status) 391.43 / 391.51
• An annual MVR review, at least once every 12 months, with a note of who reviewed it 391.25

Keep the file for as long as the driver works for you, plus 3 years. Drivers must also be able to read and speak English well enough to do the job; since mid-2025, roadside inspectors place drivers out of service for failing this requirement. 391.11(b)(2)

DOT physicals & medical cards

CMV drivers must pass a DOT physical from a medical examiner listed on FMCSA's National Registry of Certified Medical Examiners. A medical certificate is valid for up to 24 months; the examiner can issue a shorter one to monitor conditions such as high blood pressure. 49 CFR 391.41–391.45

Since June 23, 2025, examiners' results for CDL and CLP holders are sent electronically from the National Registry to the state licensing agency in states that have implemented the change. Drivers of non-CDL CMVs still need their paper card, and you still need a copy in the DQ file. National Registry

Hours of service

Hours-of-service rules limit how long drivers can drive and work. 49 CFR Part 395 For property-carrying drivers:

Passenger-carrying drivers have different limits: 10 hours of driving after 8 consecutive hours off, and no driving after 15 hours on duty. Keep records of duty status and supporting documents for 6 months. FMCSA: Hours of Service

Electronic logging devices (ELDs)

Drivers who must keep records of duty status generally must use an ELD that is on FMCSA's registered list. 49 CFR Part 395 Subpart B Common exceptions are drivers using the short-haul exception, drivers who keep logs no more than 8 days in any 30-day period, driveaway-towaway operations, and vehicles with engines older than model year 2000.

Drivers should carry the ELD user manual, data-transfer instructions, malfunction instructions, and at least 8 days of blank paper logs. Check FMCSA's revoked-device list periodically; if your device is revoked you have a limited time to replace it. FMCSA ELD site

Inspection, repair & maintenance

Carriers must systematically inspect, repair, and maintain every vehicle they control. 49 CFR Part 396

• Maintenance records for each vehicle (identification, inspection and maintenance schedule, and records of work done), kept for 1 year and for 6 months after the vehicle leaves your control. 396.3
• Driver vehicle inspection reports (DVIRs) at the end of each day's work. Property carriers need a written report only when a defect is found or reported; passenger carriers must always complete one. Keep DVIRs for 3 months. 396.11
• Annual (periodic) inspection of every CMV by a qualified inspector, with proof carried on the vehicle and the report kept for 14 months. 396.17 / 396.21
• Brake work and brake inspections must be done by qualified brake inspectors. 396.25

Also keep an accident register of DOT-recordable crashes for 3 years. 390.15

CSA, SMS & safety ratings

FMCSA's Compliance, Safety, Accountability (CSA) program uses the Safety Measurement System (SMS) to rank carriers using roadside inspections, violations, and crashes from the past 24 months. Today SMS groups data into seven BASICs: Unsafe Driving, Crash Indicator, Hours-of-Service Compliance, Vehicle Maintenance, Controlled Substances/Alcohol, Hazardous Materials Compliance, and Driver Fitness. Carriers over a BASIC's intervention threshold can get warning letters, investigations, or audits.

You can challenge incorrect inspection or crash data through DataQs. Investigations can lead to a safety rating of Satisfactory, Conditional, or Unsatisfactory. 49 CFR Part 385

New entrant safety audit

New interstate carriers are in FMCSA's New Entrant Safety Assurance Program for their first 18 months. FMCSA conducts a safety audit within the first 12 months of operation (sooner for passenger carriers) to check that basic safety management controls are in place. 49 CFR Part 385 Subpart D

Certain violations mean an automatic failure, for example:

• no drug and alcohol testing program, or using a driver who tested positive or refused a test;
• using a driver without a valid CDL, or a disqualified or medically unqualified driver;
• not having the required insurance;
• operating a vehicle placed out of service before it is repaired;
• missing hours-of-service records or periodic inspections for at least 51% of the drivers or vehicles checked.

If you fail, you get a notice and must submit a corrective action plan, generally within 45 days for passenger and hazmat carriers and 60 days for others, or your registration can be revoked. FMCSA New Entrant Program

Have these ready: DQ files, drug and alcohol program records and Clearinghouse queries, records of duty status and supporting documents, maintenance files and annual inspections, the accident register, and proof of insurance.

Hazardous materials

• PHMSA registration: companies that offer or transport certain quantities of hazardous materials must register with PHMSA every year. 49 CFR Part 107 Subpart G
• Hazmat employee training: general awareness, function-specific, safety, and security training, repeated at least every 3 years. 49 CFR 172.704
• Hazardous Materials Safety Permit: required from FMCSA for carriers of certain high-risk materials. 49 CFR Part 385 Subpart E
• Placarding, marking, labeling, shipping papers, and emergency response information. 49 CFR Part 172

IFTA, IRP & HVUT

These programs are run by states and the IRS, not FMCSA, but most interstate fleets need them.

• IFTA (fuel tax) and IRP (apportioned registration) apply to qualified motor vehicles: generally power units with two axles and a gross weight over 26,000 pounds, three or more axles, or a combination over 26,000 pounds. IFTA returns are filed quarterly (due the last day of the month after each quarter), and IFTA records must be kept for 4 years. IFTA, Inc. · IRP, Inc.
• Heavy Vehicle Use Tax (Form 2290) applies to vehicles with a taxable gross weight of 55,000 pounds or more. IRS Form 2290

State requirements

States add their own rules for intrastate carriers and for operating on their roads. Examples in the states we work in most include California's motor carrier permit (MCP) and BIT terminal inspection program, Oregon's weight-mile tax for heavier vehicles, and Washington's intrastate carrier and registration rules. Ask us what applies to your routes.

Record retention cheat sheet

Frequently asked questions

Sources

• eCFR, Title 49 Subtitle B Chapter III (FMCSRs): ecfr.gov/current/title-49/subtitle-B/chapter-III
• FMCSA, Updating Your Registration (biennial update): fmcsa.dot.gov/registration/updating-your-registration
• FMCSA, Temporary Suspension of the Biennial Update Requirement (updated Sept. 10, 2026): fmcsa.dot.gov/registration/temporary-suspension-biennial-update-requirement
• FMCSA, Registration Modernization FAQs (Motus, MC numbers): fmcsa.dot.gov/registration/modernization-faqs
• 49 CFR 382.701, Drug and Alcohol Clearinghouse: ecfr.gov
• DOT ODAPC, 2026 Random Testing Rates: transportation.gov/odapc/random-testing-rates
• FMCSA, Hours of Service: fmcsa.dot.gov/regulations/hours-of-service
• FMCSA, New Entrant Safety Assurance Program: fmcsa.dot.gov/safety/new-entrant-safety-assurance-program; 49 CFR 385.321
• FMCSA, CSA Prioritization Preview: csa.fmcsa.dot.gov/prioritizationpreview
• FMCSA National Registry (NRII): nationalregistry.fmcsa.dot.gov
• UCR Plan: plan.ucr.gov

This guide is general information, not legal advice. Requirements depend on your operation; confirm with FMCSA, your state, or a qualified advisor.