New authority checklist: your first 18 months

Updated 11 October 2026 · 5 min read

Getting your authority is the start, not the finish. For the next 18 months you're a "new entrant", and FMCSA will audit your records. This checklist walks through what to set up and keep up, in the order it tends to matter, with the federal rule behind each item.

This guide covers interstate, for-hire property carriers. Passenger and hazmat carriers have extra rules and shorter deadlines. Check the cited rule for your situation.

Before your first load

Insurance in force, every day

You may not operate until the required minimum financial responsibility is in effect (49 CFR 387.7(a)). For a for-hire carrier of non-hazardous property in interstate commerce, with vehicles of 10,001 lbs gross vehicle weight rating or more, the minimum public liability level is $750,000. Certain hazardous materials need $1,000,000 or $5,000,000 (387.9). Operating without it, even for a day, is one of the 16 automatic-fail violations of the new entrant audit.

Set a reminder 30 days before the policy expires, and keep a copy of every policy period.

Process agents (BOC-3)

You designate agents for service of process on Form BOC-3. Only one current form may be on file, and you keep a copy at your principal place of business (366.2T). A motor carrier designates an agent for each State it is authorized to operate in and each State it travels through (366.4T).

Drug and alcohol program (if any truck needs a CDL)

• Join a program before anyone drives. Part 382 applies to drivers who need a CDL and their employers (382.103(a)). If you are the only driver, you are both the employer and the driver, and you must be in a random pool of two or more covered drivers (382.103(b)), which in practice means a consortium or third-party administrator.
• Pre-employment drug test. Before a driver's first safety-sensitive work, you need a verified negative result (382.301(a)), with narrow exceptions in 382.301(b).
• Clearinghouse pre-employment query. A full query of the Drug and Alcohol Clearinghouse, with the driver's specific consent, before they drive (382.701(a)).
• Random testing. The rule sets base minimum annual rates of 50% of average driver positions for drugs and 10% for alcohol, and FMCSA can change them each year by notice in the Federal Register (382.305). Random tests must be unannounced and spread reasonably through the year (382.305(k)). Ask your consortium for the current rate.

A qualification file for every driver, including you

Each driver file must hold, among other things: the employment application, the motor vehicle record from each State licensing authority, the road test certificate or accepted equivalent, the annual driving-record review, and the medical examiner's certificate or the CDLIS record showing medical status (391.51(b)).

Every day and every trip

• Records of duty status. Keep each driver's logs and supporting documents for at least 6 months from receipt (395.8(k)). Failing to require logs in 51% or more of examined records is an automatic audit failure.
• Driver vehicle inspection reports. Defects reported by a driver must be repaired before the vehicle runs again if they affect safety. Keep the report, the certification of repairs and the driver's review for three months (396.11).
• Maintenance records. Systematic inspection, repair and maintenance of every vehicle you control, with a record of what was done and when. Keep these records where the vehicle is housed or maintained for 1 year, and for 6 months after the vehicle leaves your control (396.3).

Every year

• Annual inspection of each vehicle, including each trailer, within the preceding 12 months, with documentation on the vehicle (396.17(c)).
• Annual driving record check and review for each driver: obtain the record, review it, and note who reviewed it and when (391.25).
• Annual Clearinghouse query for each driver subject to testing. A limited query, with the driver's consent, satisfies the annual requirement (382.701(b)).
• Insurance renewal, with no gap.

Every two years: the MCS-150 update

You file Form MCS-150 before you begin operations and update it every 24 months (390.19T(b)). The month is set by the last digit of your USDOT number: 1 is January, 2 is February, and so on, with 0 meaning October. You file by the last day of that month. If the next-to-last digit is odd, you file in odd-numbered years; if even, in even-numbered years. Missing the update can lead to penalties and deactivation of your USDOT number.

The new entrant timeline

FMCSA generally aims to complete the audit within your first 12 months. That target comes from federal law and agency practice rather than the regulation text, so treat it as approximate.

Other registrations to check

Depending on your operation, you may also need Unified Carrier Registration (UCR), IRP apportioned plates and an IFTA fuel tax license, and to file the federal heavy vehicle use tax return (Form 2290). We couldn't open those agencies' sites while writing this guide, so confirm the requirements on their official pages.

Keep it boring

New entrants who pass tend to have dull, complete files: every driver, every truck, every date. Set up the folders on day one, put every renewal in a calendar, and add documents the day you get them.