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Trucks drive on a highway, framed in a red circle. Blue background features text: "ICC Authority Basic Requirements & Exemptions You Should Be Aware Of."

May 13, 2022

What is Interstate Commerce Commission Authority

If you are working as a “for-hire” carrier and intend to haul loads across state lines in exchange for pay, most of the loads that you want to haul will require you to obtain an ICC authority from the federal government in Washington.

You will require this ICC authority if you are hauling loads in a van, in a pickup truck towing a trailer, a pickup truck alone, or a straight truck, or a straight truck that tows a trailer or a semi-tractor and a trailer combination.

Regardless of what vehicle apparatus you choose, you will need ICC authority to cross state lines. You will have to take into consideration the gross vehicle weight rating of your vehicle in this application. The GVWR of the power unit and the trailer will also be considered.

The GVWR or the CGVWR, if below 10,000 LBS in your application for ICC authority, you will have to get at least $300,000 in personal injury or property damage liability insurance.

If the GVWR of the vehicle or the CGCWR is greater than 10,000 LBS when you apply for your authority, this requirement is going to change to $750,000 in personal injury and property damage liability insurance.

MC authority is the official name of the ICC Authority. Remember that in this process of applying for your ICC authority you will also need a USDOT number. 

You are required to keep your PIN handy for this application as well if you already have your USDOT number.

Exemptions Do The ICC Authority Requirements  

Yes, there are a few exemptions that you should be aware of. These include the following:

Farmers With Farm Plates

You will not have to apply for ICC authority if you are a farmer using a vehicle with a farm plate. Even if you intend to cross state lines, you do not have to apply for this authority.

Whether it is a farm-plated van or a pickup truck or any other vehicle, you do not have to apply for a USDOT number or register for Interstate Commerce Commission authority.

This applies to automobiles with a GVWR of 10,000 LBS or less and also a CGVWR of the same value.

However, if the gross vehicle weight rating of your vehicle setup is more than 10,000 lbs, you will have to apply for a USDOT number. An Interstate Commerce Commission authority will not be required.

When your semi-tractor, trailer, or trailer tractor combination has a gross vehicle weight rating of more than 10,000 lbs, a USDOT number is required but not an ICC authority. 

Your farm-plated truck or trailer or any apparatus that pulls a trailer exceeds the weight of 26,000 lbs when you are crossing state lines, you must register with the state for IFTA fuel tax.

To cross state lines using a farm-plated semi-tractor or a trailer, you must register for a US DOT number and IFTA fuel tax. However, you do not need to obtain ICC authority.

Private Carriers Involved In Hauling Their Own Products 

When it comes to private carriers, they do not need to have Interstate Commerce Commission authority.

If your business entity or manufacturing involves hauling its own products across state lines using a vehicle with a gross vehicle weight rating of 10,000 LBS or less, you do not need to obtain a USDOT number or register for ICC authority.

This is also applicable if the CGVWR is less than 10000 LBS. If the vehicle that you are using to cross state lines has a GVWR of more than 10,000 LBS whether it is a truck or a semi-tractor or a semi-tractor pulling a trailer, you will require a US DOT number but not ICC authority.

“For-Hire” Carriers Involved In Hauling Exempt Products Across State Lines

In this case, you still don’t need ICC authority. If you are hauling exempt commodities across state lines and these include logs, corn, and livestock, you do not need ICC authority.

If the GVWR is less than 10,000 LBS, you will require neither a US DOT number nor ICC authority.

When your truck has a GVWR of more than 10,000 LBS and a power unit of CGVWR of more than 10,000 LBS. You then have to apply for a US DOT number but not ICC authority.

ICC Authority Requirements When Applying For It

When you are applying for your ICC authority, you will need to have your US DOT number as well. You must also register for the BOC-3 list of process agents. Remember to carry personal injury or property damage liability insurance as well.

Your authority requires you to have adequate cargo insurance to cover the value of the cargo that you are carrying. 

When you are applying for the authority, remember that the entire process is going to take at least 21 days.

The feds will issue you a docket number and grant you final authority only after verifying that you have submitted all the correct information.

When you get your authority and a letter of ICC authority, then you need to keep these documents with you in your vehicle.

After you get your final authority, you will have to register for the Unified Carrier Registration program. After that, you have to go through a new entrant carrier safety audit process. 

There will be 16 requirements that you will have to fulfill. If you fail even one of them, your authority will be taken away.

A state police officer from the motor carrier section will visit your workplace to conduct the safety audit. Make sure that you follow the 16 critical guidelines to the last detail to retain your ICC authority.

FAQ

What Happens If You Fail a DOT Inspection?

If the vehicle or driver is deemed unsafe, they may be placed out of service, meaning the vehicle cannot operate until all violations are properly corrected.

Who decides which level of inspection to perform?

Both the Commercial Vehicle Safety Alliance (CVSA) and the Federal Motor Carrier Safety Administration have a part in DOT inspection levels. The CVSA develops the criteria and sets the procedures for every inspection level. The FMCSA establishes overall regulations and determines which vehicles must be inspected.

How often do DOT inspections happen?

DOT inspections can happen at any time. They most commonly happen during roadside stops and weigh stations. Carriers with higher risk, poor safety records, or hazardous material may be inspected more frequently.

What documents are required during an inspection?

Documents required during an inspection include but may not be limited to:

  • State driver’s license or commercial driver’s license
  • Medical examiner’s certificate
  • Record of duty status
  • Vehicle registrations
  • Periodic inspections document for all vehicles being operated
  • Shipping papers or bills of lading
  • Information for hazardous materials being transported
  • Proof of insurance

What are common DOT inspection violations?

According to the FMCSA, the 5 most cited roadside violations are:

  1. False Report of Driver’s Record of Duty Status: log falsification providing inaccurate or intentionally altered duty-status information.
  2. No Record of Duty Status (ELD Required): using a commercial vehicle without the required electronic logging device or valid time records.
  3. Inoperable Required Lamp: crucial lights (headlights, brake lights, turn signals, etc.) are not functioning properly.
  4. Operating a Commercial Motor Vehicle Without a Commercial Driver’s License (CDL)
  5. Operating a Commercial Motor Vehicle Without Proof of a Periodic Inspection: failure to meet FMCSA the maintenance standards of a required annual inspection.

Why is updating VMT important for compliance?

VMT is tracked to determine fuel tax obligations (Vehicle Miles Traveled Tax) used for road maintenance and improvements. Trucking companies must keep accurate records of VMT to ensure they pay the correct amount of taxes.

How often should VMT be updated?

For motor carriers VMT must be updated every two years along with the MCS-150 form for the Biennial Update.

Can VMT be tracked automatically with technology?

Yes, Electronic Legging Devices (ELDs), Fleet Management Apps, and Mileage Tracking Software are all technological advancements that can simplify the process of VMT tracking.

How does VMT affect taxes and fuel reporting?

Accurate VMT records help document mileage for business-related tax deductions, ensuring compliance with IRS regulations. It also supports fuel tax reporting by tracking the miles each vehicle travels in different jurisdictions, which is essential for state and federal fuel tax calculations. Proper tracking reduces errors, prevents penalties, and provides a clear record of operational costs.

How do I know when my Biennial Update is due?

  • Your filing schedule depends on the last two digits of your USDOT number. The last digit corresponds with what month the form needs to be filed in. January is 1, February is 2, March is 3, etc. The next to last digit determines the year (odd-numbered year or even numbered year). For example, DOT number 1234567 files their biennial update in July (7) of every even year (6). Contact us today to see if you’re due.

Does the Biennial Update cost money to file?

While you can file your Biennial Update yourself for no cost through FMCSA. The process can often be confusing and time-consuming. Our team can handle your filing for you, simplifying the process for you.

Do intrastate carriers need to file the update?

Yes, even if carriers stay within state lines, a biennial update is still needed for their USDOT number.

What happens if I miss my filing deadline?

  • Failure to complete biennial update to FMCSA can be subject to fines with a maximum penalty of $10,000. If your update is past due, you can still file it to restore your compliance status. Contact us today to file your form! https://dotcompliancegroup.com/bu-update/ 

What are the new FMCSA rules in 2025?

  1. Civil Penalty Amount Increases
  2. Drug & Alcohol Clearinghouse Becomes Exclusive Source for checking driver history.
  3. ELD Technology Required
  4. SMS (Safety Measurement System) Modernization
  5. Crash Preventability Determination Program Expanded

When do the 2025 FMCSA regulations take effect?

The confirmed dates these regulations take effect is May 30, June 23, October 1, 2025.

How can trucking companies prepare for these changes?

Regularly reviewing your Safety Measurement System (SMS) scores and maintaining personal checklists for inspections, driver qualification files, and drug and alcohol testing helps catch issues before they affect audits. Partnering with DOT Compliance Group streamlines filings, reporting, and ongoing monitoring, taking the guesswork out of FMCSA regulations and keeping your operation audit-ready year-round.

What Triggers a DOT Compliance Review?

A DOT compliance review is triggered when FMCSA wants to ensure a carrier is following safety regulations. Common triggers include high SMS safety scores, a history of crashes or violations, and previous noncompliance. Staying proactive with accurate records, driver files, and regular internal audits helps reduce the likelihood of a review.

Where can I get help with FMCSA filings?

DOT Compliance Group can assist with any help or questions you may have about FMCSA filings. Call 972-476-9962.

How long are violations kept on record?

According to the Clearinghouse rules, drug and alcohol violations remain in the FMCSA Clearinghouse for five years, provided all requirements (such as completing the return‑to‑duty process) have been met before that period ends.

What if an employer makes a mistake in reporting?

In practice, correcting an employer reporting error typically involves identifying the mistake in the database and then submitting a request for correction through the Clearinghouse portal or FMCSA procedures, so the record reflects accurate information. 

What are the penalties for non-compliance?

FMCSA rules allow civil penalties for non‑compliance, and separate authorities note that employers who fail to meet Clearinghouse requirements may face civil fines or criminal penalties under federal regulations.

Do trucking companies check the Clearinghouse?

Yes — trucking companies check the Clearinghouse as part of their hiring and compliance process. The FMCSA Clearinghouse is designed so employers can search a driver’s drug and alcohol violation records before permitting them to operate a commercial vehicle. Employers are required to conduct these queries for both prospective and current drivers as part of compliance.

How MOTUS Changes Daily Compliance Operations

MOTUS primarily changes system access and verification, not safety rules. Login issues, verification delays, or profile errors could temporarily affect filing ability if not addressed early. Even when regulations themselves remain unchanged, system transitions can create operational confusion. Proper preparation helps prevent disruptions in daily compliance operations.

When will MOTUS fully launch for motor carriers?

Phase 2 of MOTUS, which includes motor carriers, brokers, and freight forwarders, is expected mid-to-late 2026. During this phase, users will create accounts, complete business verification, and begin filing through the system. Post-launch enhancements and refinements will continue afterward.

Who is required to use MOTUS?

MOTUS will apply to interstate carriers, brokers, freight forwarders, passenger carriers, and Mexico-domiciled carriers operating in the U.S. Intrastate requirements remain governed by state regulations, though some states still require USDOT registration. For authority holders, additional insight is available in our guide to Motus registration for carriers and brokers.

Does MOTUS replace the FMCSA Portal?

MOTUS does not directly replace the FMCSA Portal. It modernizes and centralizes functions currently spread across multiple systems. Over time, it will replace legacy registration platforms.

Does MOTUS replace the Unified Registration System (URS)?

MOTUS is part of the FMCSA’s broader modernization effort and is intended to replace fragmented registration processes, including legacy URS functions. It consolidates and modernizes legacy registration systems over time, but does not change the core regulatory requirements for carriers.

Will MOTUS eliminate MC, FF, or MX numbers?

No, MOTUS will not eliminate MC, FF, or MX numbers. The modernization affects access and verification — not authority structure. Existing authority numbers stay valid; MOTUS only changes how registration data is accessed and managed.

What documents are required for a DOT audit?

Documents required during an inspection include but may not be limited to:

  • State driver’s license or commercial driver’s license
  • Medical examiner’s certificate
  • Record of duty status
  • Vehicle registrations
  • Periodic inspections document for all vehicles being operated
  • Shipping papers or bills of lading
  • Information for hazardous materials being transported
  • Proof of insurance

Who must comply with DOT regulations?

Any business operating a Commercial Motor Vehicle (CMV) with a USDOT number is required to comply with DOT regulations. This requirement applies to motor carriers, freight forwarders, brokers, and companies operating under a hazardous materials permit.

How can companies avoid common DOT violations?

Companies can avoid common DOT violations by maintaining accurate records, including driver logs, vehicle inspections, and required documents. Regular vehicle maintenance and pre-trip inspections help prevent safety-related violations. Proper training ensures drivers follow Hours-Of-Service rules, secure cargo correctly, and meet CDL and medical requirements. Using technology like ELDs and fleet management software can streamline compliance and reduce the risk of penalties.

What happens during a DOT compliance review?

During a DOT compliance review, or audit, officers review both the vehicle and the driver to ensure compliance with federal and state regulations. They check registration, insurance, inspection reports, and inspect safety equipment and vehicle systems for proper operation. Drivers’ licenses, medical cards, hours-of-service records, and logbooks or ELDs are also examined. The inspection helps identify violations and ensure safety on the road.

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