New authority · 9 minute read
Getting your MC and staying legal in month one
The ninety days after FMCSA grants authority are the only window in which every one of your deadlines is still unwritten. What has to exist, in what order, and the rule behind each line.
Sources on October 18, 2026 and due for re-reading by January 18, 2027. Informational only — not legal, tax or insurance advice, and nothing here files or sends anything for you.
Nothing about the first month of operating authority is hard. Almost all of it is a deadline you have not heard of yet, arriving on a date that is decided by two days you already know: the day FMCSA granted your authority, and the day the truck first rolled onto a public highway. Everything else in this guide hangs off those two.
The two dates that decide everything
Write both down the day you get them, in a place you will look at in eleven months. Federal paperwork is unusual in how much it keys off "the month of first use" rather than "the date you signed up", and the most expensive mistake a new carrier makes is assuming the authority date does the work.
| What you owe | When it is due | Where the rule lives |
|---|---|---|
| Heavy highway use tax, Form 2290 | The last day of the month after the month of first highway use for any vehicle over 55,000 lbs, then every August 31 for as long as the truck is on the road. | IRC §4481 IRS Form 2290 |
| IFTA quarterly return | The last day of the month following each quarter, filed with your base state, which then distributes the tax to the jurisdictions where you reported miles. | IFTA Agreement, Art. V 49 U.S.C. §11501 |
| UCR registration | Once, before you run interstate, then annually. The fee bands by fleet size and the fee rule changed on September 1, 2026, so read the current bands rather than a forum post. | 49 U.S.C. §11504 |
| MCS-150 company information | Kept current. One truck still has to file it, and the biennial registration survey now runs through the Unified Registration System's replacement, so the place you file has moved more than once since 2025. | 49 CFR §390.19 |
| New-entrant safety review | Inside your first eighteen months of operating under new authority, on FMCSA's timing rather than yours. | 49 CFR part 385, subpart H |
A truck first put into highway use in early October owes its first 2290 at the end of that October. The following August feels like the deadline — it is the deadline for every subsequent year — and the difference between the two is a tax that was never filed plus penalties on top of it.
Insurance before wheels
Authority is not granted on a promise of insurance; the filings have to be on file. The minimum liability limits for interstate property are set by regulation, and the instrument that proves you meet them is the MCS-90 endorsement on your policy — the paper that tells FMCSA the insurer stands behind you even where the policy's exclusions would otherwise leave the public with nothing.
- General freight, interstate: the federal floor in 49 CFR §387.9 has sat at $750,000 for decades. It is a floor. Brokers routinely require $1,000,000 auto plus cargo, and a contract that requires a million while you carry the floor is a contract you are breaching on the first load.
- Cargo and auto are different lines. Ask your broker for the certificate in the form the broker actually accepts, not the generic one, and keep the PDF where you can find it at a scale house.
- Anything with placards moves the minimum several times over, and hazmat authority carries its own file. Price the insurance before you price the freight.
A driver file before the first driver — even when the driver is you
This is where new carriers lose the new-entrant review. The driver qualification rules do not care that the company is one person and a kitchen table; if you are a driver-employee of your own carrier, the file has to exist and be reviewed.
- Qualification file — licence, medical examiner's certificate, record of duty status history, annual review of the driving record. 49 CFR §§391.23, 391.27, 391.43, 391.45
- Clearinghouse query — a full query before the first assignment and a limited query every year afterwards. It is free, it takes four minutes, and its absence is one of the most common findings in a new-entrant audit. 49 CFR §382.701
- Random testing — a drug and alcohol programme with random selection at the minimum annual rates, which a one-truck carrier buys through a consortium rather than runs alone. 49 CFR §§382.107, 382.305
- ELDT record — if the CDL was issued or upgraded recently, the entry-level driver training record has to be on file. 49 CFR §§380.601–380.603
The truck's own paperwork
Three things about the power unit itself get checked at the roadside and again in a review, and none of them are documents anybody hands you when you buy the truck.
- Periodic inspection — every 12 months, with the evidence retained. 49 CFR §§396.17, 396.21
- DVIR — a report at the end of each driving day the vehicle was used, and a record that defects were repaired or that no repair was needed. This is the one most often "kept in somebody's head", which is the same as not kept. 49 CFR §396.11
- Accident register — a list of every accident, indexed by date and name, with the required details on each and the supporting records held for the period the rule sets. 49 CFR §§390.15, 390.31
The state bills you did not know you owed
IFTA covers fuel. It does not cover the states that tax the truck by weight and miles, and a base-state return filed on time with a missing state underneath it is not a small error: the jurisdiction stops selling you permits and apportioned plates, and after that the load board stops being interesting.
- Kentucky (KYU) — $0.0285 a mile on power units over 59,999 lbs, filed quarterly by gross miles or IFTA miles, whichever you elect.
- Oregon and New York — weight-mile and highway-use taxes with their own quarterly rhythms; Oregon's applies to designated highways rather than every mile you ran.
- New Mexico and California — a road-use/weight-distance regime and a declared weight programme that have to be set up before they can be renewed.
- IRP apportioned plates — renewed on a schedule driven by your base state's anniversary, not by the calendar year.
Which of those you actually owe is a function of where you are based and which states you run through, which is exactly the question the deadline calendar asks once and then never stops tracking. Guessing at the list is how carriers find out about a state tax from a penalty notice.
What staying legal costs per week
Not much, if the dates are written somewhere that interrupts you. The first ninety days are a filing project; everything after that is ten minutes a week against a calendar that already knows the difference between a medical card that expires in three weeks and a random testing programme that has to be enrolled before you hire anyone at all. The carriers who get caught are not the ones who could not afford compliance. They are the ones who kept the dates in a memory that was also carrying a dispatch call and a broken reefer.
Questions people actually ask
- Do I file IFTA in every state I drive through?
- No. You file one quarterly return with your base state, reporting miles and fuel for every qualifying jurisdiction you ran in, and the base state distributes the money. What gets a return questioned is a jurisdiction where you reported miles but produced no fuel receipts — so keep every fuel receipt against the state it was bought in.
- When is the first Form 2290 due?
- By the last day of the month following the month the vehicle first went on the road, and every August 31 afterwards. A truck first used in early October owes its first return at the end of that October, not the following August — the month people assume is the deadline is the month the authority was granted.
- I am the only driver and I own the company. Do I still need a random testing program?
- If you are a driver-employee of your own carrier in a non-exempt operation, yes: the drug and alcohol testing rules require a program that includes random selection at the minimum annual rates, and a consortium is how a one- or two-truck operation buys one. FMCSA Clearinghouse queries are required on top of it, not instead of it.
- Is this legal, tax or insurance advice?
- No. It is a checklist assembled from published regulations and tax forms, dated and cited so you can read the same text we did. Your broker, surety, accountant or the authority itself is the place to confirm what applies to your operation.
Where this comes from
Every rule quoted above was read from one of these, on October 18, 2026 and due for re-reading by January 18, 2027. Regulations move; the date is the reason there is one rather than a page of confident assertions with no expiry.
- 49 CFR part 390 (accident register, company information)
- 49 CFR part 382 (drug and alcohol testing, Clearinghouse)
- 49 CFR part 387 (minimum liability limits)
- 49 CFR part 391 (driver qualification)
- 49 CFR part 396 (inspection, repair and maintenance)
- 49 CFR part 385, subpart H (new-entrant safety review)
- IRS — Form 2290, Heavy Highway Vehicle Use Tax
- IFTA — International Fuel Tax Agreement handbook and base-state filing
Next
- How to bill detention and actually get paid — Every load
- What a new-entrant audit asks for — New authority
- The demo workspace — a whole truck to poke at, nothing saved
These are the deadlines. The calendar keeps them.
Nine questions about your truck, and the year assembles itself with the authority and the citation printed beside every line — plus an alert when one of them starts closing. Alerts are free on every plan, always.