Do I need passenger authority for charter, shuttle, or limo work?

The §365 framework requires FMCSA operating authority for any "person engaged in interstate commerce as a passenger carrier." The trigger is interstate operation plus carriage for compensation; both conditions must be met. A purely intrastate limo service that never crosses state lines operates under state authority only. A limo service that occasionally crosses state lines for airport runs needs federal passenger MC authority.

The OP-1(P) application is the passenger-specific entry point. It requires the same applicant information as OP-1, plus passenger-specific insurance minimums under §387.33T: $5 million BIPD for any vehicle seating 16 or more passengers including the driver, and $1.5 million for 15 or fewer including the driver. The higher minimums reflect the higher claim exposure on passenger-carrying operations.

New-entrant passenger carriers face the §385.307 new-entrant audit just like new-entrant property carriers, but the audit checks passenger-specific items: §391 driver qualifications including passenger-endorsement CDL where applicable, §392 driving-of-vehicles requirements, §393 vehicle-equipment requirements specific to passenger configurations, and §396 inspection-and-maintenance documentation. The audit happens within the first 12 months of operation.

For mixed property/passenger operations, the carrier files separate OP-1 (property) and OP-1(P) (passenger) applications and operates under separate MC numbers, both under the same USDOT. A single BOC-3 process-agent designation typically covers both authorities since BOC-3 is keyed to the carrier entity, not to specific MC numbers. BMC-91 financial-responsibility filings are separate per authority.