New Carrier Compliance Checklist

Getting your authority is the easy part. What comes after is a list of federal requirements that nobody hands you in one place, in the right order, with links to where each one actually gets done.

This is that list.

It covers the federal requirements that apply to most new for-hire interstate carriers. It does not cover every state requirement, and hazmat, passenger, and intrastate-only operations carry obligations this guide does not address.

One thing to be clear about before anything else. The motor carrier is responsible for its own compliance. That duty sits with you under 49 CFR, and it does not transfer to a vendor, a consultant, or a software product. This guide shows you what is required, points you to where each filing happens, and tells you what to keep. You decide, you file, you certify.

FMCSA rules move. This guide is current as of August 2026, and every requirement links to its official source, so check the source before you rely on anything here.

What does a new carrier need to be compliant?

A new interstate for-hire carrier needs three things in place: active registration and authority with FMCSA, a drug and alcohol testing program that is live before any driver operates, and complete records for every driver and vehicle. Almost everything on this roadmap falls under one of those three.

The order matters. Some steps gate others, and a few carry automatic-fail consequences at your new entrant safety audit if they are missing. This guide runs in the order a new carrier should complete them.

Phase 1: registration and authority.

Where do I register my trucking company with FMCSA?

New carriers register through MOTUS, FMCSA's registration system at motus.dot.gov. MOTUS replaced the old Unified Registration System (URS) on May 14, 2026. If a guide or a vendor points you to URS, it is out of date.

MOTUS is where you apply for your USDOT number and operating authority (your MC number), file your MCS-150 biennial updates, and change company information.

One thing MOTUS requires that no one can do for you: identity verification through Login.gov, with a government-issued ID and a facial scan. The person registering the company has to complete this themselves. Any service that offers to handle your registration end to end is describing a process that no longer exists.

What to keep: your USDOT number, MC number, Login.gov credentials, and FMCSA Portal access. You will use all of them again.

What does operating authority cost?

The FMCSA filing fee is $300 per authority type, paid inside MOTUS. That is the government's fee only. The real cost of starting a carrier is dominated by insurance, which comes next.

What insurance filings does FMCSA require?

For-hire property carriers need primary liability coverage of at least $750,000, and most brokers and shippers expect $1,000,000. Your insurance company files proof of coverage (form BMC-91 or BMC-91X) directly with FMCSA. Your authority will not activate without it.

You do not file this yourself. You buy the policy, and your insurer files it. Confirm with your agent that the filing went through, and keep your certificate of insurance and your MCS-90 endorsement where you can produce them.

What is a BOC-3 and who files it?

A BOC-3 designates a process agent in each state, someone who can accept legal documents on your company's behalf. It is required under 49 CFR Part 366 before your authority activates, and it must be filed electronically by a process agent company. You cannot file it yourself unless you are your own process agent in every state, which as a practical matter no carrier is.

Process agent services typically charge $20 to $100 for a one-time blanket filing. FMCSA keeps a list of process agents at fmcsa.dot.gov.

What is UCR and where do I register?

Unified Carrier Registration is an annual fee for carriers operating in interstate commerce. For 2026, the fee is $46 for a fleet of zero to two vehicles. Register directly at ucr.gov. The window for each year opens October 1 and payment is due by December 31, with enforcement starting January 1.

Third-party sites will register you for the same thing at a markup. The official site is ucr.gov, and it works fine.

Do I need IRP plates and an IFTA license?

If you run apportioned vehicles across state lines, yes to both. IRP (apportioned plates) and IFTA (fuel tax reporting) are handled through your base state, not FMCSA. In Tennessee, for example, both run through the Department of Revenue. Search your state's IRP and IFTA office and file there. IFTA requires quarterly fuel tax returns once you are licensed, so put the quarterly deadlines on your calendar the day you get your decals.

What is Form 2290?

The federal heavy vehicle use tax. Any truck with a taxable gross weight of 55,000 pounds or more must file Form 2290 with the IRS, and you need the stamped Schedule 1 to register the vehicle with your state. File at irs.gov. The tax year runs July through June.

Phase 2: the drug and alcohol program.

This phase comes before your first load, not after, and it is where new carriers fail audits. Under FMCSA's new entrant program, a carrier automatically fails its safety audit for having no drug and alcohol testing program, no random testing program, or for using a driver who refused a test or tested positive without completing return-to-duty steps. Automatic means automatic. There is no partial credit.

Do owner-operators need a drug and alcohol program?

Yes. If you drive a CDL vehicle, you are a covered driver even if you are the only employee. You cannot administer your own random program, so a one-driver operation must enroll in a consortium.

What is a drug and alcohol consortium and how do I join one?

A consortium is a group random-testing pool run by a third-party administrator (C/TPA). You enroll your drivers, the consortium runs the random selections at the federal rates, and you keep the records. Annual enrollment typically runs $100 to $300 per driver.

The 2026 minimum random rates are 50 percent of driver positions for drugs and 10 percent for alcohol, unchanged for six straight years. The consortium handles the selection math, but the obligation to test is yours.

What is the FMCSA Clearinghouse and do I have to register?

Yes. The Drug and Alcohol Clearinghouse is FMCSA's database of drug and alcohol program violations, and every employer of CDL drivers must be registered. Register at clearinghouse.fmcsa.dot.gov. Registration is free, and since April 2026, new registrations for certain account types include an identity verification step.

Once registered, you designate your C/TPA in the Clearinghouse, run a full pre-employment query on every driver before they operate, and run a limited query on every driver at least once a year. Full queries require the driver's electronic consent inside their own Clearinghouse account, which means each driver needs to register too. Limited queries run on a general written consent you collect and keep on file.

What else does the drug and alcohol program require?

Four things beyond the consortium and the Clearinghouse:

1. A written policy that meets 49 CFR 382.601, given to every driver, with a signed receipt in your records.
2. A negative pre-employment drug test result in hand before any driver performs a safety-sensitive function. Before, not after.
3. Supervisor training if you employ drivers: one hour on drug misuse and one hour on alcohol misuse, with completion documented. A sole owner-operator with no employed drivers keeps this on file when they hire their first one.
4. Records. Negative results are kept one year. Positives, refusals, and return-to-duty records are kept five years.

Phase 3: driver qualification files.

What goes in a driver qualification file?

A DQ file under 49 CFR 391.51 must contain, for every driver including an owner-operator driving their own truck:

1. The driver's employment application under 391.21, covering ten years of history for CDL drivers.
2. A motor vehicle record (MVR) from every licensing authority the driver held a license under during the past three years, pulled at hire.
3. A road test certificate, or a copy of a valid CDL accepted in its place.
4. Proof of medical certification. This changed in June 2025. For CDL drivers, medical certification now posts electronically to the driver's MVR, and you verify it by pulling the CDLIS MVR rather than keeping a paper card. During the transition, FMCSA's waiver (currently through October 11, 2026) lets a paper medical certificate serve as proof for up to 60 days after the exam, and a few states are still on paper entirely, so keep a copy of any paper certificate until the MVR shows the certification. For non-CDL drivers who need a DOT physical, the paper certificate still goes in the file, with the examiner verified against FMCSA's National Registry at nationalregistry.fmcsa.dot.gov.
5. Safety performance history from every DOT-regulated employer in the past three years under 391.23, including drug and alcohol history under 40.25, with your good-faith attempts documented.
6. The Clearinghouse pre-employment query result.
7. The negative pre-employment drug test.
8. An annual MVR and a documented annual review of the driving record, signed by a company official. This is the current requirement. The old driver-completed annual certification of violations (391.27) was eliminated in May 2022, so if a checklist still asks for it, that checklist is out of date.
9. Entry-level driver training (ELDT) verification for any driver whose CDL was first issued after February 7, 2022, checked against the Training Provider Registry.

One qualification standard worth calling out: under 391.11, a driver must be able to read and speak English well enough to converse with the public, understand traffic signs, and respond to official inquiries. Since June 2025, inspectors treat a failure of this standard as an out-of-service violation, so it belongs in your hiring review, not just your file.

Missing or incomplete DQ files are the most commonly cited violation in FMCSA audits. If you build one thing carefully, build this.

Retention: the full file is kept for the length of employment plus three years.

Phase 4: vehicle files and maintenance.

What vehicle records does FMCSA require?

Four things per vehicle:

1. A systematic maintenance program under 396.3. Written, with a schedule by miles or time, and a file for every unit listing make, VIN, year, and tire size, plus records of inspections and repairs. Maintenance records are kept one year, and six months after the vehicle leaves your fleet.
2. An annual periodic inspection under 396.17, performed by a qualified inspector, with the report kept 14 months.
3. Driver vehicle inspection reports (DVIRs) under 396.11 for each day a defect is found, with certification of repairs, kept three months. DVIRs can be created and signed electronically, which FMCSA made explicit in a 2026 rule.
4. Roadside inspection reports under 396.9. When a driver gets inspected, the report comes back to you, violations get corrected within 15 days, and you keep the report for 12 months. As of July 22, 2026, you return the signed report to the issuing state only if that state requests it, so check the rules of the states you run in.

Start these the day the truck starts working. Auditors ask for maintenance history, and a file that begins the week before the audit tells its own story.

Phase 5: hours of service and ELDs.

What do I need for hours of service compliance?

Most property carriers need an ELD from FMCSA's registered device list, at eld.fmcsa.dot.gov. Check the list before you buy, and keep checking it, because FMCSA removes revoked devices regularly (five more came off in August 2026). When your device gets revoked, you have up to 60 days to replace it with a compliant one, and the clock starts whether you noticed the announcement or not.

Beyond the device:

• Driver accounts set up correctly, with personal conveyance and yard move settings decided and documented.
• Eight days of blank paper logs in every cab, plus the ELD instruction sheet and the malfunction procedure under 395.34.
• Supporting documents (fuel receipts, dispatch records, bills of lading) retained six months alongside your records of duty status.

If you run short-haul under the 395.1(e) exemption, document the determination and keep time records instead. The exemption is real, but claiming it without records is the same as not qualifying.

Phase 6: the paperwork nobody mentions.

What is an accident register?

A list of every DOT-recordable accident, kept under 390.15 for three years, even if the list is empty. Open it on day one. An empty register that exists beats no register.

What company policies should be in writing?

At minimum: your drug and alcohol policy (required), hours of service expectations, the handheld phone and texting prohibition, seat belt use, and what a driver does after an accident, including the post-accident testing decision tree. Every policy gets a signed driver acknowledgment, and the acknowledgments go in your records.

Does my truck need my USDOT number on it?

Yes. Under 390.21, the legal name or a single trade name and the USDOT number go on both sides of the power unit, legible from 50 feet.

The new entrant safety audit.

When does the new entrant audit happen?

Within the first 12 months of operation, and FMCSA monitors new carriers for 18 months. Auditors typically give 5 to 20 business days' notice. That is not enough time to build a compliance program, which is why every phase above happens first.

The audit checks the areas this roadmap covers: drug and alcohol program, driver qualification, hours of service, vehicle maintenance, and insurance. Pass it, and you move toward permanent authority. The automatic failures are listed in Phase 2, and they are the reason Phase 2 comes before your first load.

How long do I keep each record?

• Driver qualification file: employment plus 3 years
• MVR and annual review: 3 years
• Negative drug test results: 1 year
• Positive tests, refusals, return-to-duty records: 5 years
• Random selection and collection process records: 2 years
• MIS annual summaries and program administration records: 5 years
• Records of duty status and supporting documents: 6 months
• DVIRs: 3 months
• Annual vehicle inspection report: 14 months
• Maintenance records: 1 year, plus 6 months after the vehicle leaves the fleet
• Roadside inspection reports: 12 months
• Accident register: 3 years
• Clearinghouse query records: 3 years

The roadmap in one list.

Before your first load:

• Authority active in MOTUS, insurance filed by your insurer, BOC-3 on file
• UCR registered at ucr.gov
• IRP and IFTA through your base state, Form 2290 filed if over 55,000 pounds
• Consortium enrolled, random pool live
• Clearinghouse registered, C/TPA designated, pre-employment query run
• Negative pre-employment drug test in hand
• Medical certificate current, MVR pulled
• ELD installed from the registered list, blank logs in the cab
• USDOT number on the truck

Within 30 days:

• Full DQ file assembled for every driver
• Previous employer inquiries sent and follow-ups documented
• Written policies signed and acknowledged
• Supervisor training complete, if you employ drivers
• Vehicle files and maintenance schedule built
• Accident register opened

Ongoing:

• Annual MVR and documented annual review of the driving record
• Annual limited Clearinghouse query
• Annual vehicle inspection
• Quarterly IFTA returns
• UCR renewal every December
• MCS-150 biennial update in MOTUS
• Medical certificate renewals as they come due

Where Dotra fits.

Dotra does not file anything for you, and it is not your compliance department. The duty stays where the regulation puts it.

What Dotra does is keep this entire roadmap in one place: it tells you what your operation requires, links you to where each filing happens, holds every record with the retention clock running, and flags what is coming due before it costs you a load. When the auditor calls, everything on this page is already organized and already yours.

A carrier should not have to guess at this. The requirements are public, the deadlines are knowable, and getting it right should not depend on who you happened to ask. We are building Dotra so a new carrier can see the whole picture on day one.

This guide is general information about federal requirements, not legal advice. Requirements vary by operation, and state obligations are not covered here. Verify current rules at fmcsa.dot.gov before relying on any requirement listed above.