Quick answer
An operating trucking company’s compliance checklist is a calendar, not a one-time list: UCR by December 31, the MCS-150 update in your assigned month every 24 months(49 CFR §390.19T), Form 2290 by August 31, quarterly IFTA returns (April 30, July 31, October 31, January 31), IRP renewal on your base state’s cycle, plus an annual MVR review and Clearinghouse query per driver and a periodic inspection per truck.
Most authority losses we see are not audits. They are a missed biennial update, a UCR that nobody paid, or an insurance filing that lapsed while someone was on the road. Put the dates below on a calendar with a named owner and the paperwork risk mostly disappears. Our deadline calendar builds it from your USDOT number.
What are the annual and biennial deadlines?
These are the dated items. Four are federal, one is your base state, and the last two apply only if you hold the underlying registration.
| Filing | When | Rule | Note |
|---|---|---|---|
| UCR registration | By December 31 for the coming year; portal opens October 1 | 49 CFR Part 367 | 2026: $46 (0–2 units), $138 (3–5), $276 (6–20); count from your latest MCS-150 |
| MCS-150 biennial update | Your month (last USDOT digit), every 2 years (odd/even by next-to-last digit) | 49 CFR §390.19T | Free; lapse can deactivate the USDOT number |
| Form 2290 HVUT | August 31 for trucks in use in July; otherwise last day of the month after first use | 26 USC §4481; IRS 2290 instructions | $100–$550 per truck at 55,000+ lbs; e-file required at 25+ vehicles |
| IRP renewal | Annual, on your base jurisdiction’s cycle | IRP Plan / base state | Needs a stamped 2290 Schedule 1; report actual mileage |
| IFTA license and decals | Annual, calendar year; renew before January 1 | IFTA Articles of Agreement / base state | Quarterly returns continue all year |
| Hazmat registration (if applicable) | Annual (multi-year options) | 49 CFR Part 107 Subpart G | PHMSA registration for placarded loads |
| State permit accounts (if applicable) | Annual renewals plus periodic returns | NY HUT, KY KYU, NM WDT, OR weight-mile | Only for states you operate in |
Two notes on the table. First, the UCR count comes from the power units on your most recent MCS-150, which is one more reason to keep that form accurate between biennial cycles; the UCR fee calculator shows your bracket. Second, Form 2290 is per truck, so a vehicle bought in November owes a prorated return by December 31 even though the fleet filed in August. Our Form 2290 guide covers proration and the stamped Schedule 1 your IRP office will ask for at renewal.
The MCS-150 is the one that ends authorities
It is free, it takes minutes, and it is the filing most often missed because it comes around only every two years. Deactivation for a lapsed update is authorized in §390.19T(b)(4), and reinstating an authority costs far more than filing on time. Look up your month with the MCS-150 deadline calculator; the late-filing guide explains what happens if you already missed it.
What has to happen every quarter, or all the time?
- IFTA returns for every quarter you hold the license, due the last day of the month after the quarter ends: April 30, July 31, October 31, January 31. File even for zero-mile quarters. See the IFTA filing guide.
- Random drug and alcohol selections. 49 CFR §382.305 requires the annual rate (50% controlled substances, 10% alcohol) to be met with unannounced tests spread reasonably through the calendar year. In practice your consortium or C/TPA draws names at least quarterly; your job is to send the selected driver immediately, not at the end of the quarter.
- Insurance on file, continuously. 49 CFR §387.7(a) bars operating without the minimum coverage in effect. If your insurer files a cancellation, FMCSA gets 30 days’ notice on Form BMC-35 under §387.313(d); a replacement filing has to post before that clock runs out or the authority is revoked.
- SAFER check. Not a rule, a habit: pull your record at safer.fmcsa.dot.gov once a quarter and confirm operating status, insurance, BOC-3, and the MCS-150 date all read the way you expect.
- State permit filings (NY HUT, KY KYU, NM WDT, OR weight-mile) on each state’s own cycle, usually quarterly or monthly, for as long as the account is open.
What does the checklist look like per driver?
Every item below lives in the driver qualification file, which the auditor reads first. A solo owner-operator keeps this file on themselves.
- MVR inquiry and review, at least once every 12 months (49 CFR §391.25). Pull the record from every state that licensed the driver, review it against the minimum standards, and file a dated, signed note of who reviewed it.
- Medical examiner’s certificate current, from an examiner on the National Registry; the maximum period is 24 months and many drivers are certified for less. See the medical card guide.
- Clearinghouse query at least once a year for every CDL driver (49 CFR §382.701(b)). A limited query with the driver’s consent is enough unless it returns a hit, in which case a full query is due within 24 hours or the driver comes off safety-sensitive work.
- CDL and endorsements not expired; hazmat endorsement renewals run through TSA on their own cycle.
- Hours-of-service records: RODS and supporting documents kept for six months (49 CFR §395.8(k)), the driver carrying the previous seven days.
For new hires, add the pre-employment Clearinghouse query and pre-employment test before the first safety-sensitive shift. Our DQ file checklistlists every §391 document in order.
What does the checklist look like per truck?
- Periodic (annual) inspection. Every CMV must pass the Appendix A inspection at least once in the preceding 12 months, with proof on the vehicle (49 CFR §396.17) and the report kept 14 months (§396.21(b)).
- Driver vehicle inspection reports. Under 49 CFR §396.11 a property-carrying driver reports defects at the end of each day’s work; no defect, no report required. Repairs get certified before the truck moves, and the carrier keeps each report three months. A template is at /resources/dvir-driver-vehicle-inspection-report.
- Maintenance file. For any vehicle you control 30 days or more: identification, an inspection and maintenance schedule, and the records of what was done, kept where the truck is housed for one year and for six months after it leaves your control (49 CFR §396.3).
- Registration documents on board: IRP cab card, IFTA decals and license copy, and the current Form 2290 Schedule 1 where the state asks for it.
- ELD registered on FMCSA’s list, with the data-transfer and malfunction instruction sheets and at least eight days of blank paper logs in the cab (49 CFR §395.22(h)).
How long do you keep each record?
Auditors ask for records by window, so it helps to know the windows cold.
| Record | Keep for | Rule |
|---|---|---|
| Records of duty status + supporting documents | 6 months from receipt (driver carries 7 days) | 49 CFR §395.8(k) |
| Short-haul time records | 6 months | 49 CFR §395.1(e)(1)(iv) |
| Driver vehicle inspection reports | 3 months | 49 CFR §396.11 |
| Periodic (annual) inspection report | 14 months | 49 CFR §396.21(b) |
| Maintenance records | 1 year where housed + 6 months after vehicle leaves your control | 49 CFR §396.3(c) |
| Driver qualification file | Employment + 3 years (application, road test, initial MVR stay) | 49 CFR §391.51(c) |
| Accident register | 3 years after each accident | 49 CFR §390.15(b) |
| Positive tests, refusals, annual summaries | 5 years | 49 CFR §382.401(b)(1) |
| Collection-process records | 2 years | 49 CFR §382.401(b)(2) |
| Negative and canceled test results | 1 year | 49 CFR §382.401(b)(3) |
What is different in the first 18 months?
A new interstate carrier sits in the new-entrant program for 18 months under 49 CFR §385.307, with roadside performance watched closely and a safety audit once there are enough records to review, generally inside the first 12 months. The audit checks the same files this page describes; new entrants fail it by not having the files at all, not by having imperfect ones. Read the new-entrant safety audit guide before month three.
How do you actually run this calendar?
- Name an owner for each line. In a one-truck company that is you; in a five-truck company it is still one person, not “the office.”
- Work back from the deadline. UCR opens October 1 for the following year; file it in October, not on December 30. Form 2290 opens July 1; file it in July so the stamped Schedule 1 is in hand for the plate renewal.
- Automate the two-year item. The MCS-150 is missed because nothing reminds you. Put the month in every calendar you own, or let FastMCS150 track and file it ($150 per update).
- Renew UCR on autopilot if you can. FastUCR auto-renews a Tier 1 carrier for $70 a year, federal fee included, so the December deadline stops being a deadline.
- Check SAFER quarterly and fix anything wrong the same week. Records fall out of sync after system changes, and Motus replaced FMCSA’s legacy registration system in May 2026.
Common questions about the compliance calendar
Is UCR due December 31 or January 1?
Register by December 31 for the coming calendar year; enforcement at roadside starts January 1. The registration window opens October 1 of the prior year, so there are three months to file. UCR is due every year for interstate carriers, brokers, and forwarders under 49 CFR Part 367 regardless of whether the truck count changed, and the fee bracket follows the power units on your most recent MCS-150.
When exactly is my MCS-150 due?
Look at your USDOT number. The last digit gives the month (1 through 9 are January through September, 0 is October) and the next-to-last digit gives the year: odd digit, odd years; even digit, even years. So USDOT 1234567 files every July of odd-numbered years. Keep the power-unit count and address current between cycles as well: UCR reads the vehicle count from your latest MCS-150, and a stale count puts you in the wrong bracket.
My truck was first used in November. Is Form 2290 still due August 31?
No. The tax period runs July 1 through June 30, and a vehicle first used in a later month is due by the last day of the month after first use, so a November first use is due December 31, prorated for the months remaining. The August 31 date applies to trucks already in service in July. Suspended vehicles expected to run 5,000 miles or fewer (7,500 for agricultural) still file, they just owe no tax.
Do I need an annual inspection if my driver does daily inspection reports?
Yes. The DVIR under §396.11 and the periodic inspection under §396.17 are separate requirements. The DVIR is the driver’s end-of-day defect report; the periodic inspection is a full Appendix A inspection by a qualified inspector at least once every 12 months, documented on the vehicle and kept for 14 months. One does not substitute for the other, and an auditor will ask for both.
Are the random testing rates the same in 2026?
Yes. FMCSA kept the minimum annual random rates at 50% for controlled substances and 10% for alcohol for calendar 2026, unchanged since the 2020 increase. The rate applies to the average number of driver positions across the year, so a one-driver owner-operator in a consortium is selected on the pool’s schedule; the pool as a whole must hit the percentages, and every selection has to be unannounced.
How long do I keep driver logs?
Six months from the date you receive them, along with the supporting documents, under 49 CFR §395.8(k). The driver keeps the previous seven consecutive days available in the cab. ELD data counts as the record of duty status, so your ELD provider’s retention setting has to cover at least that six-month window, and you need a way to export it when an investigator asks.
Authoritative citations
- 49 CFR §390.19T — MCS-150 biennial update schedule and deactivation.
- 49 CFR Part 367 — UCR fees; brackets published at plan.ucr.gov.
- IRS Form 2290 instructions — Tax period, due dates, suspension mileage.
- 49 CFR §382.305 — Random testing rates and spread.
- 49 CFR §382.701 — Clearinghouse pre-employment and annual queries.
- 49 CFR §391.25 — Annual MVR inquiry and review.
- 49 CFR §391.51 — Driver qualification file contents and retention.
- 49 CFR §395.8 — Records of duty status and six-month retention.
- 49 CFR §396.3, §396.11, §396.17, §396.21 — Maintenance records, DVIRs, periodic inspection.
- 49 CFR §387.7 and §387.313 — Continuous insurance and cancellation notice.
Related guides
DOT Compliance Handbook
The complete federal compliance roadmap from USDOT through CSA - the pillar reference.
Read the DOT Compliance Handbook guideMCS-150 Late Filing Consequences
What happens when you miss the biennial update - fines, deactivation, reinstatement.
Read the MCS-150 Late Filing Consequences guideDOT Audit Defense & FMCSA Investigation
Surviving an FMCSA on-site or off-site compliance review - the seven BASICs, retention windows, safety-rating spectrum, and DataQs appeals.
Read the DOT Audit Defense & FMCSA Investigation guideBottom line
Who needs to act, and what they should do next
- Owner-operators
- Five dates: UCR by Dec 31, Form 2290 by Aug 31, IFTA on the last day after each quarter, IRP on your base-state cycle, MCS-150 in your month every two years. Plus your own MVR, medical card, and Clearinghouse query once a year.
- Small fleets
- Same dates, multiplied by drivers and trucks. Build the DQ file, DVIR, and maintenance file as systems with a named owner, and reconcile the MCS-150 power-unit count before UCR opens each October.
- New entrants
- You are in the 18-month monitoring window under Part 385. The audit checks these exact files, usually inside the first year - start them on day one and check SAFER quarterly.