PASSENGER TRANSPORTATION — 49 CFR §382 + §387
What passenger carriers must do after getting DOT authority
Motorcoach operators, shuttle services, transit companies, and other passenger carriers carry the full standard compliance stack — plus passenger-specific operating authority and higher insurance requirements. This checklist covers the core requirements.
What is the complete compliance checklist for passenger transportation carriers?
The steps below apply to a standard for-hire interstate carrier in this sector. Items marked "We do this for you" are handled by Vertical Identity when you enroll.
Activate your authority
File your BOC-3 (process agent)
A registered process agent must file this. We resell a partner that handles it.
When:Before authority is granted; must stay on file.
Source: 49 CFR §366 · reviewed 2026-06-14
File your insurance (BMC-91X)
Your insurer files this electronically. $750k for most for-hire property; higher for passenger/hazmat.
When:Within 20 days of FMCSA Register publication.
Source: 49 CFR §387 · reviewed 2026-06-14
Authority goes ACTIVE
You may not operate until your authority shows ACTIVE. (Not a flat "21 days.")
When:~3–4 weeks (10-day protest + 20-day filing); longer if vetted.
Source: FMCSA registration · reviewed 2026-06-14
Register for UCR
UCR's site makes DIY easy — do it yourself there, or we'll handle it. Fees = official UCR schedule.
When:Annual; before interstate operation.
Source: 49 U.S.C. §14504a · reviewed 2026-06-14
Get compliant to operate
Join a drug & alcohol consortium (C/TPA)
Owner-operators MUST be in a consortium for random testing — you can't self-administer. We are your C/TPA.
When:Before any driver performs a safety-sensitive function.
Source: 49 CFR §382 · reviewed 2026-06-14
Pass a pre-employment drug test
The test must be passed — not just taken — before driving. We order it.
When:Negative result REQUIRED before the first dispatch.
Source: 49 CFR §382.301 · reviewed 2026-06-14
Register + query the FMCSA Clearinghouse
Login.gov steps are yours; we run the queries as your TPA.
When:Full query pre-employment; limited query annually.
Source: Clearinghouse final rule · reviewed 2026-06-14
Build your Driver Qualification File
Even a solo owner-operator needs a DQF on themselves. We manage it.
When:Before driving; MVR within 30 days of hire + annually.
Source: 49 CFR §391.51 · reviewed 2026-06-14
DOT medical card (physical)
Required to hold a CDL for interstate non-excepted driving. We perform the physical.
When:Valid up to 24 months — can be shorter. Renew before expiry.
Source: 49 CFR §391.41–.49 + §383.71 · reviewed 2026-06-14
Written drug & alcohol policy
A written policy is required. We provide one per DOT mode.
When:Provided to drivers before they drive.
Source: 49 CFR §382.601 · reviewed 2026-06-14
Supervisor reasonable-suspicion training
60 min drugs + 60 min alcohol for anyone making reasonable-suspicion calls. We train them.
When:Before the DER/supervisor supervises drivers.
Source: 49 CFR §382.603 · reviewed 2026-06-14
Register your truck
File IRS Form 2290 (HVUT)
Vehicles ≥55,000 lb. E-file returns a stamped Schedule 1 in minutes — do it yourself at IRS.gov.
When:Before plating (Schedule 1 required to register).
Source: IRS Form 2290 · reviewed 2026-06-14
Register IRP apportioned plates
Multi-state operation. File through your base state — link below for each state you picked. Apportioned plates are about the VEHICLE running interstate, not about holding MC authority — private and exempt-commodity carriers (USDOT-only, no MC) register IRP too.
When:After authority is active; needs your base state.
Source: IRP / base-state · reviewed 2026-06-14
Get your IFTA license + decals
Qualified vehicles in 2+ jurisdictions. Issued by your base state.
When:Before interstate operation; quarterly returns after.
Source: IFTA · reviewed 2026-06-14
Pass your New Entrant Audit
Pass your New Entrant Safety Audit
The #1 automatic failure is having no drug & alcohol program. Stay enrolled and you pass.
When:Within 12 months of starting operations.
Source: 49 CFR §385 subpart D · reviewed 2026-06-14
Core regulatory sources: 49 CFR §382 — drug & alcohol testing · 49 CFR §385 subpart D — New Entrant Safety Audit · last reviewed 2026-06-14
Important: passenger carriers need passenger operating authority
If you are transporting passengers, your operating authority type matters. Passenger carriers generally require passenger operating authority (not standard for-hire property authority) and are subject to higher insurance minimums under 49 CFR §387 — the specific minimums depend on the number of passengers and type of operation. If you are configuring your authority type, use the interactive tool on our homepage and select "Passenger carrier." The drug and alcohol program under 49 CFR §382 and the New Entrant Safety Audit under 49 CFR §385 apply to passenger carriers just as they do to freight carriers.
Sources: 49 CFR §387 — insurance requirements · FMCSA — authority types · last reviewed 2026-06-14
Frequently asked questions
Do passenger carriers need different operating authority than freight carriers?
Yes. Passenger carriers generally need passenger operating authority, which is a separate registration from standard for-hire property authority. The requirements differ — including insurance minimums under 49 CFR §387. Verify your specific authority type with FMCSA before applying.
Are insurance requirements higher for passenger carriers?
Under 49 CFR §387, passenger carriers are subject to higher insurance minimums than standard for-hire property carriers. The exact minimum depends on your passenger capacity and operation type. Verify the requirement that applies to your specific operation with FMCSA and your insurer.
Do passenger carriers need to join a drug and alcohol consortium?
Yes. The drug and alcohol testing requirements under 49 CFR §382 apply to all motor carriers employing CDL drivers in safety-sensitive functions, including passenger carriers. Owner-operators must be enrolled in a consortium (C/TPA) and have a negative pre-employment test on file before the first dispatch.
What is the New Entrant Safety Audit for passenger carriers?
FMCSA audits every new carrier within 12 months of starting operations under 49 CFR §385 Subpart D. The audit applies to passenger carriers as well as freight carriers. The most common automatic failure remains not having a drug and alcohol program in place.
Let us handle the compliance stack
Enroll in our consortium and we take care of your drug and alcohol program, Clearinghouse queries, and driver qualification files — so you can focus on your operation.
Enroll in the consortiumThis is general guidance, not legal advice. Verify requirements with FMCSA and your state DOT.