New authority checklist: every filing, in order, before your first load

A new authority checklist is the list of filings a new for-hire interstate carrier has to get through, in order, before the first load: the Motus application, the insurance filing, the BOC-3, the protest period, a drug and alcohol program with a negative pre-employment test, the Clearinghouse, a driver file on yourself, the truck's inspection, UCR, and IFTA, IRP and Form 2290 where they apply. The new entrant safety audit follows inside your first year. Below, each step says who files it, what it costs and where it goes wrong.

The new authority checklist at a glance

Apply and get the authority active

1. Apply for your USDOT number and operating authority in Motus

Since May 19, 2026, new registrations run through Motus, FMCSA's registration system. You sign in with your own Login.gov account and pass the identity check yourself, then apply for the USDOT number and, if you will haul other people's freight across state lines for pay, operating authority. What you enter becomes your MCS-150 record: power units, drivers, cargo and how you operate.

• Who files it: You, in your own Motus account, signed in with Login.gov.
• What it costs: $0 for the USDOT number; $300 to FMCSA for each operating authority application.
• Where it goes wrong: Applying for authority you do not need (a private carrier hauling its own goods, or a truck that never leaves Texas, follows a different path: see DOT compliance in Texas), estimates on the application that never get corrected, and paying a filing site that folds FMCSA's $300 into a bigger number without saying so. Nobody needs your Login.gov to help you, and nobody should ask for it.
• The rule: 49 CFR Part 365; 360.3T.

2. Have your insurer file proof of insurance with FMCSA

For-hire authority is not granted until FMCSA holds proof of financial responsibility. For most property carriers that is a BMC-91X filed by the insurer, showing at least $750,000 of liability coverage. Under 49 CFR 365.109T it has to be on file within 20 days of your application being published in the FMCSA Register, so bind the policy early and give the agent your USDOT number.

• Who files it: Your insurance company, through your agent; you cannot file it yourself.
• What it costs: Your premium; the filing comes with the policy.
• Where it goes wrong: Waiting on FMCSA when the filing was never sent. Ask the agent one question: on what date was the BMC-91X transmitted to FMCSA? If nobody can give you a date, it was not.
• The rule: 49 CFR 387.9; 365.109T.

3. Designate a process agent with a BOC-3

The BOC-3 names a process agent in each state, someone who can accept legal papers on your behalf, and a blanket agent covers every state in one filing. It shares the insurance filing's 20-day window, counted from publication in the FMCSA Register.

• Who files it: A blanket process agent, who files it electronically for you.
• What it costs: $25 to $50, once, paid to the agent.
• Where it goes wrong: Paying the agent and assuming it is done. Until the agent files, Motus shows the application pending on the process agent filing, and FMCSA will neither chase it nor file it for you. What it should cost is in BOC-3 filing cost.
• The rule: 49 CFR Part 366; 365.109T.

4. Get through the protest period without hauling

FMCSA publishes your application in the FMCSA Register. Anyone may protest it within 10 days of publication, and if nobody does, the grant takes effect when the certificate is issued. FMCSA publishes no processing time for the whole sequence. Motus names the gate an application is waiting on, and it is usually a filing a third party owes: see new authority pending in Motus.

• Who files it: FMCSA, with you watching the status in Motus.
• What it costs: Nothing.
• Where it goes wrong: Hauling while the status says pending. A pending application is not authority, 49 CFR 392.9a prohibits operating without it, and a truck found doing it is placed out of service. The quieter mistake is counting the 20 days from the day you applied instead of the day it was published.
• The rule: 49 CFR 365.115; 365.109T; 392.9a.

Before your first load

5. Join a drug and alcohol testing program

Every carrier with CDL drivers needs a DOT drug and alcohol testing program with a random testing pool. A one-driver carrier cannot select itself at random, so an owner-operator joins a consortium, a shared pool run by a consortium/third-party administrator (C/TPA). The consortium TenFour refers members to charges $99 a year per company, paid to the consortium directly. How the whole program runs is on the DOT drug and alcohol program page.

• Who files it: You, with a consortium that runs the random pool.
• What it costs: The consortium's own fee, paid to it directly; tests are extra.
• Where it goes wrong: A written policy with no pool behind it. No testing program and no random program each fail the new entrant safety audit on a single occurrence (49 CFR 385.321(b)).
• The rule: 49 CFR 382.115; 382.305.

6. Get a negative pre-employment drug test, yours included

Before a CDL driver performs any safety-sensitive function for you, driving included, you must have a verified negative result from a pre-employment drug test. For an owner-operator, that means you, before your own first load.

• Who files it: Every CDL driver, you included, at a collection site your program sends you to.
• What it costs: The test fee, set by your program or the collection site.
• Where it goes wrong: Driving before the result is back. Using a driver without a passing pre-employment test is a critical violation in the audit.
• The rule: 49 CFR 382.301.

7. Register in the Clearinghouse and run the pre-employment query

Register as an employer. If you drive under your own authority, designate your consortium as your C/TPA, and register as a driver too, because a full query needs the driver's electronic consent. Then run a full pre-employment query on every CDL driver before their first safety-sensitive work, and plan for the annual query a year later. The difference between the two is in limited vs full Clearinghouse queries.

• Who files it: You, in FMCSA's Drug and Alcohol Clearinghouse.
• What it costs: $1.25 per query, bought as a query plan from FMCSA.
• Where it goes wrong: Buying queries from a lookalike site at a markup instead of from FMCSA's own Clearinghouse, and forgetting the annual query when the anniversary comes around.
• The rule: 49 CFR 382.701; Part 382, Subpart G.

8. Build a driver qualification file on yourself

Under your own authority you are the carrier and the driver, and the carrier keeps a qualification file on every driver: the application, a motor vehicle record from each state that licensed the driver in the past three years, the road test certificate or the CDL accepted in its place, the medical certificate and the note verifying the examiner on the National Registry. Every item, with its rule and due date, is in the driver qualification file checklist.

• Who files it: You, as the carrier.
• What it costs: The state's fee for each motor vehicle record.
• Where it goes wrong: No file on the owner, because owners never think of themselves as a hire. The annual motor vehicle record and your written review of it come due twelve months later, and that is where most files fall out of date.
• The rule: 49 CFR 391.51.

9. Get the truck inspected and the logs set up

Every truck needs a periodic inspection within the last 12 months, with the documentation on the vehicle, and a maintenance file of its own. Hours of service are recorded on an ELD from FMCSA's registered list unless one of the regulation's exceptions applies to you.

• Who files it: You, with a qualified inspector for the annual inspection.
• What it costs: The inspection fee, and an ELD subscription if you need one.
• Where it goes wrong: A truck bought with an old inspection. The 12 months run from the last inspection, not from the day you bought the truck, and a truck used without a current periodic inspection fails the audit outright once it shows up in 51 percent or more of the records examined; with one truck, that is all of them.
• The rule: 49 CFR 396.17; 395.8.

The registrations that come with running

10. Register and pay UCR

Unified Carrier Registration is an annual fee for interstate carriers, set by fleet size. It is registered and paid at ucr.gov for each year you operate in interstate commerce, and inspectors check it at the roadside. Registration for 2027 opens October 1, 2026 and should be done before you run on January 1; the fees, brackets and dates are in UCR renewal 2027.

• Who files it: You, at ucr.gov.
• What it costs: $55 a year for 0 to 2 vehicles for 2027 ($46 for 2026); larger fleets by bracket.
• Where it goes wrong: Paying a lookalike site or answering a mailer that charges several times the fee. The fee is set in 49 CFR 367.50 and paid at ucr.gov.
• The rule: 49 CFR 367.50.

11. IFTA and IRP, if your truck qualifies

A qualified motor vehicle (over 26,000 pounds, or three or more axles regardless of weight) that runs in two or more jurisdictions needs an IFTA license, two decals and apportioned plates under IRP. The first quarterly IFTA return is due on the last day of the month after your first quarter ends, and a return is required even for a quarter with no miles: see how to file IFTA.

• Who files it: You, with your base jurisdiction (in Texas, the Comptroller for IFTA and TxDMV for IRP).
• What it costs: Set by your base jurisdiction; IRP fees follow the miles and weights you declare.
• Where it goes wrong: Letting the first quarter pass without a return. The penalty is $50 or 10 percent of the tax due, whichever is greater (IFTA R1220.100), even when nothing was owed.
• The rule: IFTA Articles of Agreement R245, R305; IRP.

12. Form 2290, if the truck is 55,000 pounds or more

A highway motor vehicle with a taxable gross weight of 55,000 pounds or more owes the heavy vehicle use tax. The tax period runs July 1 to June 30, Form 2290 is due by the last day of the month after the month the truck is first used, and the stamped Schedule 1 is the proof of payment a state asks for when you register the truck.

• Who files it: You, with the IRS; e-filing returns the stamped Schedule 1 fastest.
• What it costs: The heavy vehicle use tax, from the IRS table by taxable gross weight.
• Where it goes wrong: Asking for apportioned plates before the Schedule 1 is back, or assuming August 31 is the only date that exists for a truck first used mid-year.
• The rule: IRS Form 2290 instructions.

13. Check your MCS-150 record against how you actually run

Your application created your MCS-150 record, and it is only as good as the estimates you made that day. Once you are running, check the power units, drivers, cargo and mileage against reality and file an update if they differ. After that the update is due every 24 months, on a schedule set by the last two digits of your USDOT number: the MCS-150 due date calculator works yours out.

• Who files it: You, in Motus.
• What it costs: $0 to file.
• Where it goes wrong: Leaving the application's guesses in place. The record is what FMCSA measures you against, and a wrong power unit or mileage count skews how your safety data is calculated.
• The rule: 49 CFR 390.19T.

Inside your first year

14. Be ready for the new entrant safety audit

New carriers are monitored for 18 months. The new entrant safety audit comes once you have operated long enough to have records to review, generally at least three months, and FMCSA's guidance is to expect it within 12 months of beginning operations. Sixteen violations fail it on their own, most of them on a single occurrence, and the new entrant safety audit checklist lists every document the auditor asks for.

• Who files it: A certified safety auditor, reviewing your records.
• What it costs: Nothing to FMCSA.
• Where it goes wrong: Treating the audit as a later problem. Everything on this checklist is what the auditor reads, and a carrier that fails has 60 days, in most cases, to correct it before the registration is revoked.
• The rule: 49 CFR 385.307; 385.321(b).

What repeats after the first load

Most of the list above is done once. These come back on their own schedule, and missing one is how a carrier that started clean ends up with a deactivated number or a failed audit. The DOT compliance deadlines calendar puts every one of them on a month.

• IFTA returns every quarter: April 30, July 31, October 31 and January 31, moved to the next business day when one lands on a weekend or legal holiday.
• UCR for the following year, in the October 1 to December 31 window.
• An annual Clearinghouse query on every CDL driver, you included.
• An annual motor vehicle record and a written review of it for every driver.
• Each driver's medical card, renewed before the date printed on it.
• The truck's periodic inspection, every 12 months.
• The MCS-150 update, every 24 months, and Form 2290 each year by August 31 for trucks in use in July.

Doing it yourself, or having it done

Every filing on this list can be made by the carrier, and the government fees are the same either way. What a service sells is the order, the follow-up and the calendar. TenFour's new trucking authority setup covers the BOC-3, UCR, a review of your MCS-150, Clearinghouse registration, consortium enrollment and a twelve-month calendar for $199 once, or included on the annual plan. The filings are prepared for you to sign and submit in your own accounts.