Passenger Carrier Authority: USDOT Number, Insurance and the New Entrant Program

Who needs what

Two separate federal registrations are involved, and passenger operators regularly confuse them.

• A USDOT number identifies a carrier for safety oversight. Any interstate operator of a passenger commercial motor vehicle needs one, including private groups that never charge a fare. There is no FMCSA fee for the number itself.
• Passenger operating authority is the permission to carry passengers for hire in interstate commerce. You need it only if you are paid, but you need it in addition to the USDOT number. Each authority type carries a one-time, non-refundable fee of $300.

Under 49 CFR 390.5T, a passenger vehicle is a commercial motor vehicle if it is designed or used to carry more than 8 people including the driver for compensation, or more than 15 people including the driver without compensation. So a paid airport-to-casino run in a 10-seat van across a state line is regulated; a church taking a 12-seat van to a retreat in the next state is not a CMV on seat count alone.

The insurance minimums come from 49 CFR 387.33T and apply to for-hire passenger carriers in interstate or foreign commerce. Seating capacity counts the driver.

Step 1: Register through Motus

FMCSA is replacing the Unified Registration System (URS) and the FMCSA Portal with a single system called Motus. According to the agency's April 29, 2026 Federal Register notice, Phase I opened on December 8, 2025 for supporting companies such as BOC-3 blanket agents and insurance filers, and Phase II, opening Motus to all regulated entities, was planned for the second quarter of 2026. URS is to be disabled for new USDOT number and authority applications once Motus is the unified system.

What changes for a new bus company:

• Identity verification is mandatory. Every new applicant must pass identity proofing, using a smartphone or tablet and a valid government-issued ID. FMCSA uses IDEMIA for identity checks and CLEAR for business verification. Access runs through Login.gov.
• Forms become fields. The old paper forms, including the MCS-150 and the passenger authority form OP-1(P), are being folded into online questions. Until a rule change removes them, FMCSA still accepts the forms, and the notice says applicants using Motus during Phase II will not be penalized for not using them.
• Allow time. FMCSA says to expect at least eight business days for initial review, longer if the application is flagged for vetting.
• Payment is electronic, through Pay.gov.
• MC numbers are not gone yet. Eliminating MC docket numbers was explicitly left out of Phase II.

Because the rollout has moved in stages, check FMCSA's registration pages for the current status before you file. The trucking authority guide covers the Motus process step by step; the passenger application follows the same path with passenger-specific answers.

Step 2: Get insurance in place and filed

Authority does not become active until your insurer files proof of coverage with FMCSA. For passenger carriers, the policy must carry the MCS-90B endorsement (or, for a surety bond, Form MCS-82B), issued in the carrier's exact legal name, under 49 CFR 387.39.

The minimums by seating capacity are the most important numbers in this guide:

For comparison, a general freight truck needs $750,000. The minimum follows the vehicle, so a fleet of one 56-seat coach and one 14-passenger van needs coverage that meets $5,000,000 on the coach.

Under 49 CFR 387.27(b), these minimums do not apply to:

• a vehicle carrying only school children and teachers to or from school;
• a taxicab seating fewer than 7 passengers, not on a regular route;
• a vehicle carrying fewer than 16 people in a single daily round trip to commute to and from work; and
• a contractor carrying school students on extracurricular trips organized, sponsored and paid for by a school district.

Transit providers funded under certain Federal Transit Administration grants follow separate rules in 387.33T(b), set by the highest state requirement where they operate.

Step 3: File a BOC-3

Every carrier with operating authority must designate a process agent in each state where it operates, on Form BOC-3. Almost all carriers use a blanket agent company that covers every state in one filing. This is identical to the truck process; see the BOC-3 guide. The Motus notice says BOC-3 filing changes are not part of Phase II, so blanket agents continue to file for you.

Step 4: Build your safety systems before the first trip

Once registered, you are a new entrant under 49 CFR Part 385 Subpart D, monitored for 18 months. Federal law gives passenger carriers far less runway than freight haulers: 49 U.S.C. 31144(g)(1)(B) requires a safety review of a new passenger carrier no later than 120 days after it begins operations, against 12 months for other new entrants.

If you fail the audit, 49 CFR 385.319(c) gives a passenger carrier using vehicles designed or used for 9 to 15 people (for direct compensation) or more than 15 people 45 days to fix the problems, rather than the 60 days most freight carriers get. If corrective action is not accepted, registration is revoked.

The audit looks at driver qualification files, drug and alcohol testing, hours-of-service records, vehicle maintenance and inspection records, insurance and the accident register. The new entrant safety audit guide lists the violations that fail a carrier automatically, including having no testing program and operating without required insurance.

Step 5: State and annual items

• Unified Carrier Registration. For-hire interstate carriers register annually. For registration year 2027 the fee for 0 to 2 vehicles is $55 and for 3 to 5 vehicles $167; the full table is on the federal fee reference.
• Biennial update. Your USDOT record must be updated every two years.
• State authority. Interstate authority does not cover purely in-state trips. Many states regulate intrastate passenger carriers, and the rules differ widely. California, for example, requires charter-party carrier authority from its Public Utilities Commission, with its own insurance tiers and vehicle inspections by the California Highway Patrol for vehicles seating more than 10.

Common mistakes

• Buying the policy for the wrong seat count. A minibus with 15 seats plus the driver is a 16-person vehicle and needs the $5,000,000 minimum.
• Using borrowed buses without a lease. Since January 1, 2021, 49 CFR 390.403 requires a written lease or interchange agreement, with the vehicle details, both carriers' USDOT numbers, start and end times, and a statement that the lessee has exclusive control. A copy rides on the bus and both parties keep one for a year. Buying service from another carrier that holds active passenger authority is excluded.
• Treating the USDOT number as permission to operate. Without active authority, for-hire interstate trips are illegal even with a valid USDOT number.
• Assuming the audit is a year away. For passenger carriers the statute says 120 days.
• Paying a filing service believing it is required. It is not. Third-party services may help, but the federal fee is $300 per authority.

Questions

How much insurance does a 15-passenger van need for interstate charter work?

If the van seats 15 or fewer including the driver, the federal minimum is $1,500,000 under 49 CFR 387.33T. If it seats 16 or more including the driver, the minimum is $5,000,000.

Is there a fee for a USDOT number?

No. FMCSA does not charge for the USDOT number. Operating authority costs $300 per authority type, one time and non-refundable.

How soon will FMCSA audit a new bus company?

Federal law requires the safety review of a new passenger carrier no later than 120 days after it begins operations, compared with 12 months for other new entrants.

Do I still use URS to register?

FMCSA is moving all applicants into Motus and has said URS will be disabled for new applications once Motus is the unified system. Check FMCSA's registration pages for the current status on the day you apply.

Does a church bus need operating authority?

No. Operating authority is for carriers paid to transport passengers. A church operating interstate in a vehicle designed for 16 or more people including the driver needs a USDOT number but not authority.