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California rules & filings

USDOT vs CA number: what intrastate contractors in California need

Plenty of contractors who never leave California assume a USDOT number is only for interstate truckers. In California it's usually the first step, and the CA number comes second.

Quick answer

California generally requires intrastate carriers to have a USDOT number, so that comes first. The CHP then issues a CA number through its online CHP 362 application, and the DMV uses that same CA number as your Motor Carrier Permit number. Federal rules call for an MCS-150 update every 24 months to keep the USDOT record current, on a schedule set by the number's last two digits. Under California's display rule, a truck that shows a valid USDOT number is exempt from displaying the CA number.

01Staying in California doesn't mean skipping the USDOT number

A common assumption on job sites goes like this: Our trucks never cross the state line, so the federal number doesn't apply to us. California sees it differently. The Federal Motor Carrier Safety Administration (FMCSA) lists California among the states that require a USDOT number of carriers operating only inside the state, and California has required the USDOT number since September 2016.

That gives most contractor and business fleets with permit-sized trucks two numbers. The USDOT number identifies the company to the federal safety system. The CA number, issued by the California Highway Patrol (CHP), identifies it to the state, and the DMV uses the CA number as the Motor Carrier Permit (MCP) number. They aren't alternatives: The CA number is built on the USDOT number.

Which trucks pull a company in? The permit rules generally reach a motortruck with two or more axles rated over 10,000 lbs GVWR, among other vehicles, and they include private carriers hauling their own tools, parts and materials. The CHP's permit FAQ uses a construction company's pickup rated 10,500 lbs GVWR as an example of a truck that needs one. Read the GVWR on each unit's door-jamb label before deciding a truck is too small to count.

Size isn't the only trigger. A vehicle used to carry someone else's property for pay typically falls under the permit at any weight, though that's for-hire trucking, which sits outside what we insure. For a contractor hauling its own gear, the axle count and the rating usually decide it.

02The order: USDOT number, CA number, permit, filing

  1. USDOT number. Register with the FMCSA and file the MCS-150 information it asks for before the trucks operate.
  2. CA number. Once the USDOT number is issued, apply to the CHP online with form CHP 362. The CHP's guidance for new carriers lays out the steps.
  3. Motor Carrier Permit. Apply to the DMV with form MC 706 M, online or by mail. Under the DMV's rules, the permit runs for 12 months.
  4. Insurance filing. Your insurer files a Certificate of Insurance with the DMV on form MC 65 M, the filing many people search for as "MCP 65." Under the Vehicle Code, it can't be canceled on less than 30 days' notice, and the permit is suspended on the date the insurance is canceled.

Because the DMV uses the CA number as the permit number, the number on your CHP record, your permit and your insurance filing should be the same one. Our guide to the MC 65 M filing behind the Motor Carrier Permit explains what the insurer files and when it typically needs to be in place.

Keep the approvals together. When a CHP officer, a general contractor's safety manager or an underwriter asks for your numbers, you'll want the USDOT number, the CA number and the permit's expiration date on a single page.

More detail

03Keeping the USDOT record current: the MCS-150 every 24 months

Getting the number is the easy part. Keeping it active usually takes a biennial update. Federal rules call for an MCS-150 update every 24 months, and California's statute adds its own version, which generally calls for the USDOT information to be updated at least every two years and within 15 days of a change to what's on file.

The federal schedule picks the date for you. The last digit of the USDOT number sets the month the update is due:

MCS-150 update month by the USDOT number's last digit
Last digitDue by the end ofLast digitDue by the end of
1January6June
2February7July
3March8August
4April9September
5May0October

The next-to-last digit sets the year: Odd means odd-numbered years; even means even-numbered years. A fleet whose number ends in 47 updates by the end of July in even-numbered years. A carrier that skips the update risks having its USDOT number deactivated, so put the month on the office calendar next to the permit renewal.

04Marking the trucks

California's rule calls for the CA number on both sides of the vehicle, legible from 50 feet. Under the same rule, a vehicle that displays a valid USDOT number is exempt, so many fleets letter the USDOT number on both doors and leave the CA number off, while others show both.

Three situations deserve a second look. A used truck may still wear the seller's numbers, which should come off before it works for you. A truck borrowed from a related company raises the question of whose number belongs on it, which the CHP can answer. And magnetic door signs can fall off on the freeway; paint or vinyl tends to stay put.

The display rule is one of several state requirements that ride along with the permit. Our page on commercial truck insurance requirements gathers the rest in one place, from inspections to filings.

05The compliance calendar these numbers create

Once the numbers are issued, the agencies' schedules set recurring dates. A missed one can go unnoticed until a roadside inspection or a permit renewal, so it pays to keep them in one place:

  • Every 12 months: Renew the Motor Carrier Permit with form MC 134 M.
  • Every 24 months: File the MCS-150 update in the month and year your USDOT number sets.
  • Within 15 days of a change: Update the USDOT information, for example after a move or a change in ownership.
  • At every policy renewal: Confirm with your broker that the MC 65 M filing carries over to the renewed or replacement policy without a gap.
  • Whenever a truck joins the fleet: Check its rating, add it to the policy and confirm it's lettered correctly.

Insurance isn't the only way to back the permit. The DMV also accepts a surety bond on form MC 55 M, and carriers with 25 or more vehicles may qualify to self-insure on form MC 131 M. Most contractor fleets file insurance, since they carry an auto policy anyway.

06One small fleet, start to finish

Picture an electrical contractor in Sacramento with three cargo vans, two service body trucks rated 14,500 lbs and a one-ton pickup rated 10,700 lbs. The vans sit under the 10,000-lb line. The service trucks and the pickup are two-axle motortrucks over it, so the company would likely need a permit: a USDOT number first, a CA number second, then the MC 706 M application and an MC 65 M filing from its insurer. Its USDOT number ends in 82, so the MCS-150 update is due by the end of February in even-numbered years.

The pickup is the unit owners often overlook. Heavier one-ton trucks are often rated just over 10,000 lbs, and that rating is what counts; our page on insurance for heavier work pickups covers how they're written. If the service trucks are diesel, they also sit over CARB's 14,000-lb line, which typically brings in Clean Truck Check rules for trucks over 14,000 lbs. None of this company's drivers needs a commercial license, but the owner can still enroll them voluntarily in the DMV's pull notice program for employers.

07Where insurance fits and what to confirm

The insurance side meets these numbers at the filing. The MC 65 M ties your policy to your permit, so the legal name, USDOT number and CA number on the policy should match what the CHP and DMV hold. For general freight, the Vehicle Code calls for the filing to show at least a $750,000 combined single limit; many contractor fleets carry $1 million because their contracts ask for it.

When you add a truck that needs the permit, tell your broker before it runs so the schedule and the filing keep pace. If the company changes its name or legal entity, raise it with the FMCSA, the CHP, the DMV and your broker before the change takes effect, because the numbers, the permit and the policy usually have to follow it.

This guide is general information, not legal advice. The FMCSA, the CHP and the DMV decide how their rules apply to your trucks, so confirm your situation with them. When your numbers are in order, get a quote for the trucks that carry them, and we can arrange the MC 65 M filing through national carriers.

Numbers, permits and the policy

USDOT and CA number questions

Do I need a USDOT number if my trucks never leave California?
If your trucks need a Motor Carrier Permit, generally yes. California's rules call for intrastate carriers to have a USDOT number, and it comes before the CA number.
Is the CA number the same as my MCP number?
Yes. The CHP issues the CA number, and the DMV uses it as the Motor Carrier Permit number.
How do I know when my MCS-150 update is due?
Check the last two digits of your USDOT number. Under the federal schedule, the last digit sets the month, and the next-to-last digit, odd or even, sets whether you update in odd- or even-numbered years.
Do my trucks need both numbers on the doors?
Generally not. Under California's display rule, a vehicle showing a valid USDOT number is exempt from the CA number display requirement; confirm the marking details with the CHP.
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