Guide

New carrier compliance checklist

Starting a trucking operation involves more regulatory steps than most new carriers expect. Missing any of these can mean operating illegally, failing broker setup, getting placed out of service at a roadside inspection, or losing authority. This checklist covers the core requirements for a new for-hire interstate motor carrier — it is a starting orientation, not a substitute for current FMCSA guidance or legal advice.

Step 1: Federal registration and authority

• Apply for a USDOT number
  Required for most commercial carriers operating in interstate commerce. Applied through FMCSA's Unified Registration System (URS). The DOT number identifies your operation for safety data, inspection records, and SAFER system lookup.
• Apply for MC operating authority
  Required to transport regulated freight for compensation in interstate commerce. Applied through FMCSA URS. The MC number goes through a 10-day protest period — authority is not active until the period clears and insurance and BOC-3 are on file.
• File BOC-3 (process agent designation)
  Required before authority activates. A BOC-3 designates a process agent in each state where you operate. Most carriers use a blanket BOC-3 filing service that covers all 50 states for a small fee. Verify the filing appears on the FMCSA SAFER record before expecting authority to activate.
• File proof of insurance with FMCSA
  Your insurance agent files the required proof of financial responsibility (Form MCS-90 or BMC-91/91X) directly with FMCSA. This is not the certificate of insurance you send to brokers — it is a separate electronic filing. Without it, authority does not activate.

Step 2: Insurance requirements

• Primary auto liability
  Federal minimum: $750,000 for most dry freight; $1,000,000 for hazmat; $5,000,000 for certain high-risk hazmat categories. Many shippers and brokers require $1,000,000 regardless of commodity. Confirm your insurer files proof with FMCSA.
• Motor truck cargo insurance
  Not federally mandated at a specific minimum, but brokers typically require $100,000. High-value or specialty freight may require higher limits. Confirm commodity exclusions with your agent — electronics, pharmaceuticals, and art are commonly excluded without specific endorsement.
• Additional coverages (varies by operation)
  Physical damage (required if truck is financed or leased), general liability (required by some shippers and 3PLs), occupational accident (common for leased-on owner-operators), bobtail/non-trucking liability (commonly required in lease agreements).
• Certificate of insurance (COI)
  Get a COI from your agent immediately after policies are active. You will need to provide this to every broker. Confirm the COI shows the correct limits, the correct named insured, and an active policy period.

Step 3: Annual and recurring state registrations

• IRP (International Registration Plan) — cab card
  Required for interstate commercial vehicles over 26,000 pounds. Apportions registration fees across states based on miles operated. Results in a cab card that must be in the vehicle at all times. Renewed annually; must be updated when fleet size changes or states are added.
• IFTA (International Fuel Tax Agreement) — fuel tax license
  Required for interstate commercial vehicles over 26,000 pounds. Quarterly fuel tax returns based on miles driven and gallons purchased by jurisdiction. Results in an IFTA license and decal displayed on the cab. Keep all fuel receipts organized by jurisdiction for quarterly filing.
• UCR (Unified Carrier Registration) — annual fee
  Annual fee required for interstate carriers, brokers, and freight forwarders. Tiered by fleet size. Registration typically opens in October for the following year. Many carriers miss this because there is no automatic reminder.
• Heavy Vehicle Use Tax (HVUT) — Form 2290
  IRS tax for vehicles over 55,000 pounds, filed annually. Results in a stamped Schedule 1 required for IRP registration and sometimes requested during carrier setup. Due annually on August 31 for the upcoming tax year (July through June).

Step 4: Biennial and ongoing FMCSA filings

• MCS-150 biennial update
  Required every two years from the date of initial registration. Updates your fleet size, commodity type, miles operated, and contact information in the FMCSA record. Missing the update can cause FMCSA to deactivate your DOT number. Set a calendar reminder for the required filing month.
• Insurance renewal — continuous FMCSA filing
  When your insurance renews, your agent must re-file proof with FMCSA. A lapse in the filing — even if the policy is active — can trigger revocation of operating authority. Confirm with your agent each renewal that the filing is submitted and reflected on the SAFER record.

Step 5: Driver qualification file (per driver)

• CDL verification — Confirm class and endorsements match the vehicle and loads the driver will operate. Pull the MVR at hire and annually.
• Drug and Alcohol Clearinghouse query — Required pre-employment query before the first dispatch. Full query requires driver consent. Annual limited query required for existing CDL drivers.
• Pre-employment drug test — Required before the driver operates a CMV. Test must use an FMCSA-compliant drug testing program. Keep documentation in the driver qualification file.
• Medical examiner's certificate — Driver must have a current medical card from a certified FMCSA examiner. Keep a copy in the driver qualification file. Track the expiration date — it varies from 3 months to 24 months depending on medical conditions.
• Driving history (PSP report) — FMCSA Pre-Employment Screening Program report shows 5 years of crash data and 3 years of inspection data. Requires driver consent and a small fee. Common in carrier safety screening.
• Previous employer verification — Required under FMCSA rules for any CDL driver with prior CMV experience in the past 3 years. Contact each prior employer to verify employment dates, accident record, and whether the driver is eligible for rehire.

Step 6: ELD and HOS compliance

• Install certified ELD
  Required for most carriers subject to HOS rules. The ELD must be on the FMCSA registered device list. Installation includes connecting to the engine ECM, verifying data sync, and ensuring drivers know how to operate and demonstrate the device to a roadside inspector.
• Establish a supporting documents policy
  Fuel receipts, bills of lading, dispatch records, and toll records are supporting documents that must be available to match against ELD logs. Establish a process for drivers to submit or scan these records.
• Train drivers on HOS rules
  The 11/14/70 hour structure, the 30-minute break requirement, sleeper berth rules, personal conveyance limits, and adverse driving conditions exceptions. A driver who does not understand the rules cannot log accurately, and inaccurate logs are the carrier's compliance problem.

Step 7: Broker setup readiness

Before accepting loads from freight brokers, have these documents current and ready to send:

• Certificate of insurance with the broker listed as certificate holder (or additional insured if required)
• W-9 form (current, signed)
• Operating authority documents (MC number, USDOT number)
• Bank account or payment information for ACH setup
• Signed carrier agreement or master transportation agreement
• Completed carrier profile or packet (varies by broker)

Ongoing compliance — what to track monthly and annually

• Monthly: ELD log review for violations, insurance certificate currency for active broker accounts, driver hours tracking.
• Quarterly: IFTA fuel tax filing and payment, review CSA score for new inspection data.
• Annually: UCR registration, HVUT Form 2290, IRP cab card renewal, driver MVR pull, annual Clearinghouse limited query, review and update driver qualification files.
• Every 2 years: MCS-150 update, CDL and medical card renewals (varies by driver), review insurance limits against current broker and shipper requirements.

This checklist is for general orientation. FMCSA requirements, state laws, and broker standards change. Verify current requirements with FMCSA.dot.gov, your state agency, and qualified legal or compliance advisors before making filings or operational decisions.