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Do Texas intrastate carriers need a USDOT number?

Updated . Sources for every claim are listed at the end.

Short answer

Yes, if you need Texas intrastate authority. TxDMV says you must have a valid USDOT number before you begin the TxDMV registration process, and that if your operations are exclusively within Texas you should register with USDOT as intrastate, not interstate. Your insurer then files proof of insurance with TxDMV.

  • TxDMV registration applies to carriers running commercial vehicles over 26,000 pounds, placarded hazmat, and certain other operations listed by TxDMV.
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Who needs Texas intrastate authority

TxDMV lists the operations that require a TxDMV number, including:

  • Commercial vehicles with a gross weight, registered weight, or gross weight rating over 26,000 pounds (combinations count)
  • Hazardous materials in a quantity that requires placarding
  • Farm vehicles rated at 48,000 pounds or more
  • Vehicles designed to carry more than 15 passengers including the driver
  • Household goods for hire, regardless of weight

If you are in one of those groups and stay inside Texas, you need a USDOT number first, then TxDMV authority, then an insurance filing.

Intrastate or interstate on your USDOT record

TxDMV's instruction is direct: if you operate exclusively within Texas, register with USDOT as intrastate. Marking yourself interstate when you are not can create obligations that do not apply to you, such as UCR. Going the other way is the bigger problem: if you start hauling across state lines or handle freight moving in interstate commerce, you need interstate operating authority and federal insurance filings. See FMCSA truck insurance minimums.

Keep the USDOT record current with the MCS-150 biennial update; an inactive USDOT number can block TxDMV registration.

The insurance filing

TxDMV says only your insurance company can file proof of insurance or a cancellation, electronically, and you must keep an active filing in TxMCCS at all times while operating in Texas. That filing is the Texas Form E. The required limits are covered in Texas intrastate truck insurance requirements.

Which filing goes where

Trucking insurance filings and where each one goesThe insurer files BMC-91X or BMC-91 with FMCSA as proof of liability for interstate authority, and BMC-35 to cancel it, effective 30 days after FMCSA receives it. The carrier or a process agent service files the BOC-3 with FMCSA. The insurer files Form E with TxDMV for Texas intrastate registration, and Form K to cancel it. The MCS-90 endorsement is not a filing; it is attached to the policy.Who filesFormWhere it goesInsurerfiles itBMC-91X or BMC-91proof of liabilityFMCSAneeded for interstate authorityInsurerfiles itBMC-35notice of cancellationFMCSAeffective 30 days after receiptCarrieror a process agent serviceBOC-3designates process agentsFMCSAan agent in every stateInsurerfiles itForm Eproof of liabilityTxDMVTexas intrastate registrationInsurerfiles itForm Kliability cancellationTxDMVcancels the proof on fileInsurerattaches itMCS-90 endorsementguarantee to the publicYour policynot a filing; part of the policy
Forms named in 49 CFR 387.313 (BMC-91, BMC-91X, BMC-35) and 49 CFR part 366 (BOC-3). Under 387.313, federal filings cannot be cancelled until 30 days after FMCSA receives the BMC-35. TxDMV states that only the insurance company can file proof of insurance (Form E) or its cancellation (Form K), and that the carrier is still responsible for keeping its insurance record active.

Common questions

My truck is under 26,001 pounds. Do I need a TxDMV number?

TxDMV's list is based on weight and type of operation. A non-hazmat property carrier at or under 26,000 pounds generally is not on it, but household goods movers and placarded hazmat carriers are regardless of weight. Check TxDMV's requirements page for your situation.

Can I use my USDOT number in place of a TxDMV number?

No. They are separate credentials. TxDMV requires the USDOT number first, then issues its own registration.

Who files my insurance with TxDMV?

Your insurance company. TxDMV accepts proof of insurance and cancellations only from the insurer.

Sources

  1. TxDMV, TxDMV number requirements. Who needs a TxDMV number, valid USDOT number required first, register with USDOT as intrastate, insurer-only filings.
  2. TxDMV UCR bulletin (January 28, 2019). Intrastate-only carriers should update USDOT profile to intrastate.

This page explains insurance, not law. Have your attorney review indemnity and contract language; our job is making the insurance match it.

Keep reading

Questions

What insurance do Texas intrastate trucking companies need?

Questions

What is a Texas Form E?

Contracts and deadlines

Which insurance filings does a Texas trucking company need, and who files them?

Questions

What is UCR registration?

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