How to Start a Trucking Company: Complete DOT Compliance Checklist

By CarrierLens Compliance Team • Last updated: 2025-04-20

Starting a trucking company involves far more than buying a truck. Before your first load moves, you must complete a specific sequence of federal registrations, insurance filings, and compliance program setups mandated by FMCSA. Miss a step or do them out of order, and you either can't operate legally or face immediate out-of-service orders. This guide walks through every required step in the correct sequence — from your first USDOT application through your first FMCSA new entrant audit.

The New Motor Carrier Compliance Sequence

These steps must largely be completed in this order. Several have dependencies: you can't get MC authority without a USDOT number, and you can't activate operating authority without a BOC-3 on file. Start to finish, expect 4–8 weeks from first application to legally operating authority — most of the wait time is FMCSA processing.

Step 1: Get Your USDOT Number

A USDOT number is the unique identifier FMCSA assigns to every motor carrier subject to federal regulation. You need it before any other federal registration. Apply through FMCSA's Unified Registration System (URS) at safer.fmcsa.dot.gov. Registration is free. Processing is typically same-day for most applicants.

Who needs a USDOT number: Any motor carrier operating commercial motor vehicles in interstate commerce that meets one of these thresholds:

• Gross vehicle weight rating (GVWR) or gross combination weight rating (GCWR) over 10,001 lbs
• Vehicle designed or used to transport 9+ passengers (including the driver) for compensation
• Vehicle designed or used to transport 16+ passengers (including the driver) regardless of compensation
• Any vehicle transporting hazardous materials in quantities requiring placarding

Some states also require a USDOT number for intrastate carriers. Check your state's DMV for intrastate thresholds — they vary significantly.

See our complete USDOT number registration guide for the full step-by-step application process.

Step 2: Determine Whether You Need Operating Authority (MC Number)

A USDOT number alone is sufficient for private carriers (companies transporting their own goods). For-hire carriers — companies transporting other people's goods for compensation in interstate commerce — also need an MC number (operating authority). Apply through the same URS portal. The MC number application costs $300 and triggers a 10-day protest period during which existing carriers can object. Once the protest period clears without objections, FMCSA issues a "pending" authority that becomes active after you complete the next two steps.

Step 3: File Your BOC-3 (Process Agent Designation)

Before FMCSA will activate operating authority, you must file a BOC-3 form designating a process agent in every state where you intend to operate. Process agents accept legal documents (lawsuits, subpoenas) on behalf of your company in each state. Most carriers use a blanket BOC-3 service that designates agents in all 50 states simultaneously for a one-time fee ($15–$50 through most services). Filing is electronic and typically processed within 24–48 hours. See our BOC-3 filing guide for the full process.

Step 4: File FMCSA-Required Insurance

Operating authority cannot be activated without proof of insurance filed directly with FMCSA. Your insurance broker must file either:

• Form BMC-91 or BMC-91X: Proof of motor carrier liability insurance. Minimum $750,000 for carriers of non-hazardous freight in vehicles under 26,001 lbs GVWR; $1,000,000 for vehicles over 26,001 lbs or for carriers transporting oil; $5,000,000 for hazardous materials.
• Form BMC-34: Proof of cargo insurance for household goods carriers ($5,000 per vehicle, $10,000 per occurrence minimum).

The insurance filing links to your USDOT and MC numbers in FMCSA's system. Until the filing is confirmed, authority status remains "pending." This step typically takes 1–3 business days after your broker files.

Step 5: Register for IRP and IFTA (If Required)

Commercial vehicles operating in multiple states must register with the International Registration Plan (IRP) and file International Fuel Tax Agreement (IFTA) returns:

• IRP: Required for vehicles over 26,000 lbs GVWR operating in two or more IRP member jurisdictions. Register through your base state's DMV. IRP apportions registration fees across all states where you operate based on mileage. Cost varies by state and vehicle weight.
• IFTA: Required for motor vehicles with two axles and GVWR over 26,000 lbs, or with three or more axles regardless of weight, operating in two or more IFTA jurisdictions. Register through your base state. IFTA requires quarterly fuel tax returns — you report miles traveled and fuel purchased in each jurisdiction and pay the net fuel tax owed.

Step 6: Set Up Your Drug and Alcohol Testing Program

Every motor carrier with CDL drivers is required to have a drug and alcohol testing program in place under 49 CFR Part 382 before any CDL driver performs safety-sensitive functions. This is not optional and is not something you set up after hiring. Required program components:

• Written drug and alcohol testing policy (§382.601) — must be distributed to all drivers
• Random testing pool enrollment — join a DOT drug testing consortium (required for owner-operators, strongly recommended for small fleets)
• Pre-employment drug test — must be completed and negative result received before the driver's first safety-sensitive duty
• FMCSA Clearinghouse employer registration — required before conducting any hiring queries
• Supervisor training — 60 minutes on drug recognition, 60 minutes on alcohol recognition, for every supervisor who could make a reasonable suspicion determination

Step 7: Complete Driver Pre-Employment Screening

Before a driver makes their first run, you must complete these screenings and document them in the driver's qualification file:

1. DOT employment application (§391.21)
2. MVR from every state the driver held a license in for the past 3 years (§391.23)
3. Previous employer verification — 3-year employment history, requesting drug testing records from the past 2 years (§391.23)
4. Road test or equivalent (CDL is acceptable as road test equivalent)
5. DOT physical examination — driver must have a valid Medical Examiner's Certificate on a National Registry-listed examiner (§391.45)
6. Pre-employment drug test — negative result required before first duty (§382.301)
7. Clearinghouse pre-employment full query — requires driver's written consent (§382.701)

All of these documents must be assembled into a Driver Qualification File (DQF) and retained for the duration of employment plus 3 years. See our DQF checklist for the complete 10-document requirement.

Step 8: Install ELDs (If Required)

The FMCSA ELD mandate (49 CFR Part 395.8) requires most CDL drivers operating in interstate commerce to use an FMCSA-registered Electronic Logging Device to record their Hours of Service. Exceptions include:

• Drivers operating under the short-haul exception (within 150 air-miles of their normal work reporting location)
• Drivers of vehicles manufactured before model year 2000
• Drivers who use paper logs no more than 8 days in any 30-day period (driveaway-towaway operations)

ELDs must be registered on the FMCSA ELD registry at eld.fmcsa.dot.gov. Non-registered devices are not compliant regardless of their technical capabilities. Driving with a non-compliant logging device (or no device when required) is an out-of-service violation.

Step 9: Prepare for the New Entrant Safety Audit

Every new motor carrier with interstate operations receives a New Entrant Safety Audit within the first 12 months of operations. The audit is an educational review — not a full compliance investigation — but failing it results in the carrier being placed out of service until deficiencies are corrected. FMCSA audits new entrant carriers on:

• Driver qualification files (at least one must be complete and compliant)
• Drug and alcohol testing program (written policy, pre-employment test, consortium enrollment)
• Hours of service records
• Vehicle maintenance records
• Accident register
• Hazardous materials regulations (if applicable)

A new entrant carrier that fails the safety audit receives a "Unsatisfactory" safety rating and loses operating authority within 45 days if deficiencies aren't corrected. CarrierLens helps new carriers build compliant driver qualification files, drug testing records, and audit documentation from day one — so the new entrant audit is a formality, not a crisis.

New Motor Carrier Compliance Timeline