Church van driver requirements
A church van built for 15 or fewer people, counting the driver, and rated under 26,001 pounds can be driven on a regular license. A church bus designed for 16 or more, or rated at 26,001 pounds or more, needs a commercial driver's license with a passenger endorsement under FMCSA's rules at 49 CFR 383.5 and 383.93, for volunteers too and on in-state trips. A bus that crosses state lines also has to file FMCSA's Form MCS-150 and carry a USDOT number on its sides (49 CFR 390.19T and 390.21T), and its CDL drivers are drug and alcohol tested under Part 382. Church Mutual recommends an annual motor vehicle record check on every driver.
Updated . Written by Andre Beukers, principal at Redoubt, a commercial insurance agency in Salt Lake City, not a government office.
Do you need a CDL to drive a church van?
No, not for a van built for 15 or fewer people, counting the driver, and rated under 26,001 pounds, because FMCSA's CDL rule, 49 CFR 383.5, starts at "26,001 pounds or more" or at a vehicle "designed to transport 16 or more passengers, including the driver."
Sources: 1
Do you need a CDL to drive a church bus?
Yes, if the bus is designed for 16 or more people including the driver, or is rated at 26,001 pounds or more. 49 CFR 383.3 applies the CDL rules "in interstate, foreign, or intrastate commerce," so a trip that never leaves Utah needs the same license, and Utah Code 53-3-404 bars driving one without "a CDL license certificate valid for the commercial motor vehicle the person is driving." The exceptions in 383.3 cover military, farm, emergency and snow-removal drivers and a few restricted licenses; none mentions churches or volunteers.
Volunteering does not change it. 383.5 counts "casual, intermittent or occasional drivers" as employees and anyone who "owns or leases a commercial motor vehicle" as an employer, and 383.37 bars that employer, here the church, from letting anyone drive without "the proper class or endorsements." In FMCSA's Appendix A to Part 390 a member volunteers to drive a faith-based group's bus on a paid trip open to the public, and the driver "must therefore hold a valid CDL with a Passenger endorsement" because the bus "is designed to transport 16 or more passengers." The pay is not what triggers the CDL; the bus's design is, as 383.5 says.
Budget time for a new driver. 49 CFR 380.609 requires a first-time passenger endorsement applicant to train with a provider on FMCSA's Training Provider Registry, and Utah Code 53-3-407 requires holding a learner permit at least 14 days before the skills test.
| Church vehicle | License | Endorsement |
|---|---|---|
| Van for 15 or fewer, driver included, under 26,001 lb | Regular license | None |
| Bus for 16 or more, driver included, under 26,001 lb | CDL, Class C | Passenger (P) |
| Bus rated at 26,001 lb or more | CDL, Class B | Passenger (P) |
| Bus carrying students between home and school | CDL for its size | Passenger (P) and school bus (S) |
Sources: 1, 5, 6, 13, 2, 3, 7, 25, 28, 11, 12, 14, 8, 10, 4, 9
Does a church bus need a DOT number?
Yes, once it crosses a state line, though no rule says so in those words; it follows from three FMCSA sections. In interstate commerce, 49 CFR 390.5T treats a vehicle "designed or used to transport more than 15 passengers, including the driver," as a commercial motor vehicle even when nobody pays, as it does any vehicle rated at 10,001 pounds or more. A church running one is a private motor carrier; 390.19T says a motor carrier "conducting operations in interstate commerce must file" Form MCS-150, and 390.21T requires the church's name and USDOT number on both sides of the bus. eCFR marks 390.5, 390.19 and 390.21 suspended indefinitely; the T versions quoted here are the text in force, and FMCSA's Appendix A to Part 390 applies them. The 1994 rule that created the church category said "all passenger carriers will be required to obtain a US DOT number." FMCSA's April 2026 notice says first-time registrants will be able to apply for a USDOT number in Motus once Phase II begins.
A free church trip needs no MC number: FMCSA's Appendix A to Part 390 says "Private motor carriers of passengers are not required to obtain operating authority registration." A van stays outside FMCSA's reach while it is under every line; the appendix says a vehicle for more than 8 but fewer than 16 passengers, under 10,001 pounds and without compensation, "is not a CMV." Check the weight rating before an out-of-state trip.
A bus that never leaves Utah falls outside 390.19T, which is written for interstate operations, and Utah Code 72-9-102(3) reaches it only if "used or maintained for business, compensation, or profit," without saying whether church trips count, so ask UDOT.
What federal rules apply to a church bus driver on an out-of-state trip?
Fewer than a business faces, as long as nobody pays. 49 CFR 390.5T calls a private passenger carrier business when the trip furthers "a commercial enterprise" and nonbusiness otherwise. When the Federal Highway Administration wrote the category in 1994 it said "Churches, civic associations, scouts, and other charitable institutions that may purchase or lease buses for sponsored activities are included in this category."
For a nonbusiness carrier, 49 CFR 391.68 switches off the age-21 rule and the road test in 391.11, the background inquiries of Subpart C, and the requirement to be "medically examined and to have a medical examiner's certificate." 395.8 drops the record of duty status, but the hours limits in 395.5 stay: no driving a passenger-carrying CMV more than 10 hours after 8 hours off duty, or after 15 hours on duty. Utah Code 53-3-402 lets a CDL holder whose only commercial driving is that kind of trip self-certify in the "Excepted interstate" category for the medical requirement.
Tax status does not decide it. Appendix A to Part 390 says of a religious music group that tax-exempt or non-profit status "does not determine whether it is a business or nonbusiness," and it treats a faith-based daycare whose fees cover its trips as a for-hire carrier. If a church school, daycare or camp runs the bus, sort that out first.
Do church bus drivers need drug and alcohol testing?
Yes, every driver who needs a CDL for the church's bus. 49 CFR 382.103 applies the testing rules to anyone who operates a CMV in commerce and is "subject to: (1) The commercial driver's license requirements of part 383," and 382.107 counts "casual, intermittent or occasional drivers." The relief in 391.68 does not reach Part 382; FHWA's 1994 rule said "Both business and nonbusiness PMCPs will be subject to these rules."
382.301 requires a controlled substances test "Prior to the first time a driver performs safety-sensitive functions for an employer," and 382.701 requires a Clearinghouse query, with the driver's consent, before that first trip and "at least once per year" after. Part 382 has no exception for a small or volunteer program, so set it up before the first trip.
What changes if riders pay or chip in for gas?
The church becomes a for-hire carrier for that trip. Appendix A to Part 390 says a nonprofit "is nevertheless engaged in for-hire passenger transportation when it receives compensation for such transportation," and "Compensation may come in many forms including donations, gifts, gas money, offerings, etc." Its example of a faith-based group asking members to help cover fuel for an out-of-state bus trip calls the money "direct compensation," puts the group under "all applicable FMCSRs, including parts 350 through 399," and requires operating authority as well as a USDOT number. Settle how a trip is paid for before the sign-up sheet goes out.
What does the church's insurer expect of its drivers?
Its own screen, written as recommendations. Church Mutual says to "establish a written policy" that requires "an annual Motor Vehicle Report (MVR) for every individual who drives on behalf of your organization," and to bar anyone with a listed violation "in the last five years," such as driving under the influence, reckless driving or speeding more than 14 miles per hour over the limit, or with two or more other listed violations or at-fault accidents in three years.
On age, Church Mutual's driver article offers 18 or older as an example, but its 15-passenger van article says "Van drivers should be at least 25 years old and have a clean driving record." Brotherhood Mutual calls a driver's age "Another important factor in on-the-road safety" and warns: "Your ministry may be judged negligent for allowing someone with a poor driving record to operate a vehicle."
What counts is the church's own policy and whatever driver criteria its insurer has put in writing; ask for them before naming a driver. 391.68 lifts the federal age-21 rule on nonbusiness trips, so the insurer's age rule is the one to check.
What to have on file for each church driver
The CDL items apply to bus drivers.
- 1.Name, date of birth, license number and state
- 2.A motor vehicle record from the last 12 months
- 3.License class and endorsements: a CDL with P for a bus
- 4.Entry-level training record for a P endorsement sought since February 7, 2022
- 5.Pre-employment drug test result and signed Clearinghouse consent
- 6.The driver's Utah CDL medical self-certification category
- 7.A signed copy of the church's vehicle and driver policy
- 8.Which vehicles the driver may use, and whether trips leave the state
Does a church bus driver need a school bus endorsement?
Only if the bus works as a school bus. 49 CFR 383.5 defines one as a CMV carrying pre-primary, primary or secondary students between home and school or to school-sponsored events, and 383.93 requires the S endorsement. A youth group outing is not that; a church school's home-to-school route is.
Where these answers come from
Each entry carries the exact words of the source so you can check it yourself. Forms, rules and carrier pages change; read the current version before acting.
- 1. 49 CFR 383.5, definition of commercial motor vehicle (CDL rules), eCFR
“(2) Heavy Straight Vehicle (Group B)—having a gross vehicle weight rating or gross vehicle weight of 11,794 or more kilograms (26,001 pounds or more), whichever is greater; or (3) Small Vehicle (Group C) that does not meet Group A or B requirements but that either— (i) Is designed to transport 16 or more passengers, including the driver;”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. - 2. 49 CFR 383.5, definition of employee, eCFR
“Employee means any operator of a commercial motor vehicle, including full time, regularly employed drivers; casual, intermittent or occasional drivers;”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. - 3. 49 CFR 383.5, definition of employer, eCFR
“Employer means any person (including the United States, a State, District of Columbia or a political subdivision of a State) who owns or leases a commercial motor vehicle or assigns employees to operate such a vehicle.”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. - 4. 49 CFR 383.5, definition of school bus, eCFR
“School bus means a CMV used to transport pre-primary, primary, or secondary school students from home to school, from school to home, or to and from school-sponsored events. School bus does not include operations of a for-hire motor carrier.”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. - 5. 49 CFR 383.3(a), applicability of the CDL rules, eCFR
“The rules in this part apply to every person who operates a commercial motor vehicle (CMV) in interstate, foreign, or intrastate commerce, to all employers of such persons, and to all States.”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. Paragraphs (c) through (i) list the exceptions: military drivers, farm vehicle operators, firefighters and emergency drivers, local-government snow and ice removal, Alaska, farm-related service industries, pyrotechnics, covered farm vehicles and certain fuel haulers. - 6. 49 CFR 383.3(b), general FMCSR exceptions do not apply to the CDL rules, eCFR
“The exceptions contained in § 390.3(f) of this subchapter do not apply to this part. The employers and drivers identified in § 390.3(f) must comply with the requirements of this part, unless otherwise provided in this section.”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. - 7. 49 CFR 383.37(a), employer responsibilities, eCFR
“No employer may allow, require, permit, or authorize a driver to operate a CMV in the United States if the employer knows or should reasonably know that any of the following circumstances exist: (a) During any period in which the driver does not have a current CLP or CDL or does not have a CLP or CDL with the proper class or endorsements.”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. - 8. 49 CFR 383.93(b) and (c), endorsements and their tests, eCFR
“An operator must obtain State-issued endorsements to his/her CDL to operate commercial motor vehicles which are: (1) Double/triple trailers; (2) Passenger vehicles; (3) Tank vehicles; (4) Used to transport hazardous materials as defined in § 383.5; or (5) School buses. (c) Endorsement testing requirements. The following tests are required for the endorsements contained in paragraph (b) of this section: (1) Double/Triple Trailers—a knowledge test; (2) Passenger—a knowledge and a skills test;”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. - 9. 49 CFR 383.123(a)(1), school bus endorsement requires the passenger endorsement, eCFR
“An applicant for the school bus endorsement must satisfy the following three requirements: (1) Qualify for passenger vehicle endorsement. Pass the knowledge and skills test for obtaining a passenger vehicle endorsement.”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. - 10. 49 CFR 383.153(a)(8) and (9), vehicle groups and endorsement codes on the CDL, eCFR
“(8) The group or groups of commercial motor vehicle(s) that the driver is authorized to operate, indicated as follows: (i) A for Combination Vehicle; (ii) B for Heavy Straight Vehicle; and (iii) C for Small Vehicle. (9) The endorsement(s) for which the driver has qualified, if any, indicated as follows: (i) T for double/triple trailers; (ii) P for passenger;”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. The same paragraph lists S for school bus. - 11. 49 CFR 380.609(b), entry-level driver training for the passenger endorsement, eCFR
“An individual seeking to obtain a passenger (P), school bus (S), or hazardous materials (H) endorsement for the first time, must complete the training related to that endorsement from a training provider listed on the TPR, as set forth in subpart G.”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. - 12. 49 CFR 380.603(b), licenses and endorsements issued before February 7, 2022, eCFR
“Drivers issued a Class A CDL, Class B CDL, or a passenger (P), school bus (S), or hazardous materials (H) endorsement before February 7, 2022, are not required to comply with this subpart pertaining to that CDL or endorsement.”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. - 13. Utah Code 53-3-404(1), requirements to drive a commercial motor vehicle, le.utah.gov
“A person may not drive a commercial motor vehicle, unless the person has been issued and is in immediate possession of: (a) a CDL license certificate valid for the commercial motor vehicle the person is driving;”
le.utah.gov, accessed October 3, 2026 - 14. Utah Code 53-3-407(2)(a)(ii), learner permit before the skills test, le.utah.gov (effective 2026-05-06)
“has held a CDIP for a minimum of 14 days prior to taking the skills test under 49 C.F.R. Part 383, including a person who is upgrading a CDL class or endorsement requiring a skills test under 49 C.F.R. Part 383;”
le.utah.gov, accessed October 3, 2026. A CDIP is Utah's commercial learner permit (53-3-102). - 15. Utah Code 53-3-402(13)(b), excepted interstate medical certification status, le.utah.gov (effective 2025-05-07)
“(b) Excepted interstate. An individual shall certify that the individual: (i) operates or expects to operate in interstate commerce, but engages exclusively in transportation or operations excepted under 49 C.F.R. Sec. 390.3(f), 391.2, 391.68, or 398.3 from all or parts of the qualification requirements of 49 C.F.R. Part 391; and (ii) is not required to obtain a medical examiner's certificate under 49 C.F.R. Sec. 391.45.”
le.utah.gov, accessed October 3, 2026 - 16. 49 CFR 390.5T, definition of commercial motor vehicle (safety rules), eCFR
“(1) Has a gross vehicle weight rating or gross combination weight rating, or gross vehicle weight or gross combination weight, of 4,536 kg (10,001 pounds) or more, whichever is greater; or (2) Is designed or used to transport more than 8 passengers (including the driver) for compensation; or (3) Is designed or used to transport more than 15 passengers, including the driver, and is not used to transport passengers for compensation;”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. eCFR notes: "At 82 FR 5311, Jan. 17, 2017, § 390.5 was suspended, effective Jan. 14, 2017"; it is again suspended indefinitely, and 390.5T is the text in force. The definition applies to a vehicle "used on a highway in interstate commerce". - 17. 49 CFR 390.5T, definition of private motor carrier, eCFR
“Private motor carrier means a person who provides transportation of property or passengers, by commercial motor vehicle, and is not a for-hire motor carrier.”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. eCFR notes: "At 82 FR 5311, Jan. 17, 2017, § 390.5 was suspended, effective Jan. 14, 2017"; it is again suspended indefinitely, and 390.5T is the text in force. - 18. 49 CFR 390.5T, private motor carrier of passengers, business and nonbusiness, eCFR
“Private motor carrier of passengers (business) means a private motor carrier engaged in the interstate transportation of passengers which is provided in the furtherance of a commercial enterprise and is not available to the public at large. Private motor carrier of passengers (nonbusiness) means private motor carrier involved in the interstate transportation of passengers that does not otherwise meet the definition of a private motor carrier of passengers (business).”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. eCFR notes: "At 82 FR 5311, Jan. 17, 2017, § 390.5 was suspended, effective Jan. 14, 2017"; it is again suspended indefinitely, and 390.5T is the text in force. - 19. 49 CFR 390.19T(a)(1), motor carrier identification report, eCFR
“A U.S.-, Canada-, Mexico-, or non-North America-domiciled motor carrier conducting operations in interstate commerce must file a Motor Carrier Identification Report, Form MCS-150.”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. eCFR notes that 82 FR 5316, Jan. 17, 2017, suspended § 390.19 effective Jan. 14, 2017; it is again suspended indefinitely, and 390.19T is the text in force. Paragraph (a)(2) reaches intrastate carriers only when they need a hazardous materials safety permit. - 20. 49 CFR 390.21T(b), marking of commercial motor vehicles, eCFR
“(1) The legal name or a single trade name of the motor carrier operating the self-propelled CMV, as listed on the motor carrier identification report (Form MCS-150) and submitted in accordance with § 390.19T. (2) The identification number issued by FMCSA to the motor carrier or intermodal equipment provider, preceded by the letters “USDOT.””
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. eCFR notes that 82 FR 5316, Jan. 17, 2017, suspended § 390.21 effective Jan. 14, 2017; it is again suspended indefinitely, and 390.21T is the text in force. - 21. 49 CFR 390.21T(c)(1), where the marking goes, eCFR
“The marking must— (1) Appear on both sides of the self-propelled CMV;”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. - 22. FMCSA, Availability of Motus, FMCSA's New Registration System, 91 FR 23144 (April 29, 2026), Federal Register
“When the implementation of Phase II begins, registrants will be able to complete all of the following activities using Motus: First-Time Registrants 1. Apply for a USDOT Number and operating authority registration from FMCSA.”
federalregister.gov, accessed October 3, 2026. Pulled by curl from the Federal Register's full-text copy of FR Doc. 2026-08334. The notice calls Phase II "planned for the second quarter of 2026" and says FMCSA will sunset the URS for new USDOT applications. The page does not state the Phase II launch date; this source does not give it. - 23. 49 CFR Part 390, Appendix A, III. Specific Example Scenarios, temporary sections, eCFR
“Some of the analysis provided in response to these example scenarios cites to regulatory sections that FMCSA designated as temporary sections in a final rule published on January 17, 2017 (82 FR 5292).”
ecfr.gov, accessed October 3, 2026. Appendix A to Part 390 is FMCSA guidance printed in the CFR; it goes on to say the guidance applies to the suspended sections' corresponding language once the suspension is lifted. Pulled by curl from the eCFR versioner API. - 24. FHWA, Private Motor Carriers of Passengers, final rule, 59 FR 8748 (February 23, 1994), requirements of the final rule
“(4) PMCPs will not be subject to the road and written test requirements of part 391, and (5) all passenger carriers will be required to obtain a US DOT number to identify their buses for enforcement by Federal and State officials.”
federalregister.gov, accessed October 3, 2026. Pulled by curl from the Federal Register full-text copy of FR Doc. 94-3951. A 1994 statement of the rule's purpose; the filing duty in force today is 49 CFR 390.19T. - 25. 49 CFR Part 390, Appendix A, Faith-Based Organizations, Scenario 1 (the facts), eCFR
“A per-person fee will cover admission to the amusement park and round-trip transportation. The faith-based organization will use its own bus, which is designed to transport more than 15 passengers including the driver. A group member is the volunteer bus driver.”
ecfr.gov, accessed October 3, 2026. The scenario also says the trip is advertised and "open to the public". Pulled by curl from the eCFR versioner API. - 27. 49 CFR Part 390, Appendix A, vehicles for 9 to 15 passengers without compensation, eCFR
“If a vehicle is designed and used to transport more than 8, but fewer than 16 passengers, and has a GVW and GVWR of less than 10,001 pounds, without “compensation,” it is not a CMV, and FMCSA has no safety jurisdiction over it.”
ecfr.gov, accessed October 3, 2026. Appendix A to Part 390 is FMCSA guidance printed in the CFR (87 FR 68372, Nov. 15, 2022, amended 91 FR 23174, Apr. 30, 2026). Pulled by curl from the eCFR versioner API. - 28. 49 CFR Part 390, Appendix A, Faith-Based Organizations, Scenario 1 (volunteer bus driver), eCFR
“In addition, the faith-based organization is operating a passenger-carrying CMV, as defined in § 383.5 because it is designed to transport 16 or more passengers; the driver of the organization's bus must therefore hold a valid CDL with a Passenger endorsement and comply with the drug and alcohol testing regulations in part 382.”
ecfr.gov, accessed October 3, 2026. Appendix A to Part 390 is FMCSA guidance printed in the CFR (87 FR 68372, Nov. 15, 2022, amended 91 FR 23174, Apr. 30, 2026). Pulled by curl from the eCFR versioner API. The guidance for the paid, public trip in Scenario 1 (app-a-volunteer-scenario). - 29. 49 CFR Part 390, Appendix A, "For Compensation" and "For-Hire", eCFR
“An entity that is nonbusiness, nonprofit, or not-for-profit, is nevertheless engaged in for-hire passenger transportation when it receives compensation for such transportation. Compensation may come in many forms including donations, gifts, gas money, offerings, etc. received for transportation.”
ecfr.gov, accessed October 3, 2026. Appendix A to Part 390 is FMCSA guidance printed in the CFR (87 FR 68372, Nov. 15, 2022, amended 91 FR 23174, Apr. 30, 2026). Pulled by curl from the eCFR versioner API. - 30. 49 CFR Part 390, Appendix A, Faith-Based Organizations, Scenario 2 (members asked to help with fuel), eCFR
“A faith-based organization owns a bus which it uses to transport some of its members to an associated organization in another State. It suggests participating members contribute money to help cover the fuel expense.”
ecfr.gov, accessed October 3, 2026. Appendix A to Part 390 is FMCSA guidance printed in the CFR (87 FR 68372, Nov. 15, 2022, amended 91 FR 23174, Apr. 30, 2026). Pulled by curl from the eCFR versioner API. - 31. 49 CFR Part 390, Appendix A, Faith-Based Organizations, Scenario 2 guidance, scope, eCFR
“The faith-based organization's bus is a CMV, as defined in §§ 390.5T and 390.5, operating in interstate commerce, and the organization is a motor carrier subject to all applicable FMCSRs, including parts 350 through 399.”
ecfr.gov, accessed October 3, 2026. Appendix A to Part 390 is FMCSA guidance printed in the CFR (87 FR 68372, Nov. 15, 2022, amended 91 FR 23174, Apr. 30, 2026). Pulled by curl from the eCFR versioner API. - 32. 49 CFR Part 390, Appendix A, Faith-Based Organizations, Scenario 2 guidance, compensation and registration, eCFR
“The money provided from the organization's members for the trip constitutes direct compensation. Any type of compensation for providing a passenger transportation service makes the faith-based organization a for-hire motor carrier of passengers. The organization must register by following the procedures in 49 CFR part 365 subpart A regarding operating authority registration and part 390 subpart E regarding USDOT number registration.”
ecfr.gov, accessed October 3, 2026. Appendix A to Part 390 is FMCSA guidance printed in the CFR (87 FR 68372, Nov. 15, 2022, amended 91 FR 23174, Apr. 30, 2026). Pulled by curl from the eCFR versioner API. - 33. 49 CFR Part 390, Appendix A, Faith-Based Organizations, Scenario 6 (religious music group), eCFR
“Whether a musical group is tax-exempt or has a non-profit status does not determine whether it is a business or nonbusiness.”
ecfr.gov, accessed October 3, 2026. Appendix A to Part 390 is FMCSA guidance printed in the CFR (87 FR 68372, Nov. 15, 2022, amended 91 FR 23174, Apr. 30, 2026). Pulled by curl from the eCFR versioner API. - 34. 49 CFR Part 390, Appendix A, Faith-Based Organizations, Scenario 5 (daycare fees), eCFR
“Because the faith-based organization receives indirect compensation through the fees charged for the daycare center, it is operating as an interstate, for-hire motor carrier of passengers.”
ecfr.gov, accessed October 3, 2026. Appendix A to Part 390 is FMCSA guidance printed in the CFR (87 FR 68372, Nov. 15, 2022, amended 91 FR 23174, Apr. 30, 2026). Pulled by curl from the eCFR versioner API. - 35. FHWA, Private Motor Carriers of Passengers, final rule, 59 FR 8748 (February 23, 1994), Federal Register
“Churches, civic associations, scouts, and other charitable institutions that may purchase or lease buses for sponsored activities are included in this category.”
federalregister.gov, accessed October 3, 2026. Pulled by curl from the Federal Register full-text copy of FR Doc. 94-3951. The category is nonbusiness private motor carriers of passengers; the same preamble says FHWA "believes most churches will fall within the definition of nonbusiness PMCPs." The rule's exemptions are now codified, as amended, at 49 CFR 391.68. - 36. FHWA, Private Motor Carriers of Passengers, final rule, 59 FR 8748 (February 23, 1994), drug and alcohol testing
“These rules were issued in response to the Omnibus Transportation Employee Testing Act of 1991 and will require that all operators of CMVs subject to the CDL requirements, be tested for controlled substances and alcohol. Both business and nonbusiness PMCPs will be subject to these rules.”
federalregister.gov, accessed October 3, 2026. Pulled by curl from the Federal Register full-text copy of FR Doc. 94-3951. The testing rules are now 49 CFR Part 382. - 37. 49 CFR 391.68, private motor carrier of passengers (nonbusiness), eCFR
“The following rules in this part do not apply to a private motor carrier of passengers (nonbusiness) and its drivers: (a) Section 391.11(b)(1) and (7) (relating to general qualifications of drivers); (b) Subpart C (relating to disclosure of, investigation into, and inquiries about the background, character, and driving record of, drivers); (c) So much of §§ 391.41 and 391.45 as require a driver to be medically examined and to have a medical examiner's certificate on his/her person;”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. The list ends with (d), Subpart F, "relating to maintenance of files and records". - 38. 49 CFR 391.11(b)(1) and (7), age and road test, eCFR
“(b) Except as provided in subpart G of this part, a person is qualified to drive a motor vehicle if he/she— (1) Is at least 21 years old;”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. Paragraph (b)(7) is the road test under 391.31 or an accepted equivalent under 391.33. - 39. 49 CFR 395.8(a)(1), record of duty status, eCFR
“Except for a private motor carrier of passengers (nonbusiness), as defined in § 390.5 of this subchapter, a motor carrier subject to the requirements of this part must require each driver used by the motor carrier to record the driver's duty status for each 24-hour period”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. - 40. 49 CFR 395.5(a), maximum driving time for passenger-carrying vehicles, eCFR
“No motor carrier shall permit or require any driver used by it to drive a passenger-carrying commercial motor vehicle, nor shall any such driver drive a passenger-carrying commercial motor vehicle: (1) More than 10 hours following 8 consecutive hours off duty; or (2) For any period after having been on duty 15 hours following 8 consecutive hours off duty.”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. Paragraph (b) adds the 60-hour and 70-hour limits; 395.5 has no nonbusiness exception. - 41. 49 CFR 382.103(a), applicability of drug and alcohol testing, eCFR
“This part applies to service agents and to every person and to all employers of such persons who operate a commercial motor vehicle in commerce in any State and are subject to: (1) The commercial driver's license requirements of part 383 of this subchapter;”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. Paragraph (c) says the exceptions in 390.3T(f) do not apply to Part 382; paragraph (d) lists the only exceptions: FTA-tested employers, military drivers, drivers a State exempts from Part 383 (farm vehicle operators, firefighters) and covered farm vehicles. - 42. 49 CFR 382.107, definition of driver, eCFR
“Driver means any person who operates a commercial motor vehicle. This includes, but is not limited to: Full time, regularly employed drivers; casual, intermittent or occasional drivers;”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. - 43. 49 CFR 382.301(a), pre-employment testing, eCFR
“Prior to the first time a driver performs safety-sensitive functions for an employer, the driver shall undergo testing for controlled substances as a condition prior to being used”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. - 44. 49 CFR 382.701(a), pre-employment Clearinghouse query, eCFR
“Employers must not employ a driver subject to controlled substances and alcohol testing under this part to perform a safety-sensitive function without first conducting a pre-employment query of the Clearinghouse”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. Paragraph (a)(2) says the full query "requires that the individual driver give specific consent." - 45. 49 CFR 382.701(b), annual Clearinghouse query, eCFR
“Employers must conduct a query of the Clearinghouse at least once per year for information for all employees subject to controlled substance and alcohol testing under this part”
ecfr.gov, accessed October 3, 2026. Pulled by curl from the eCFR versioner API (full text as of 2026-09-30); the eCFR page is a script shell. - 46. Utah Code 72-9-102(3), intrastate commercial vehicle, le.utah.gov (effective 2026-05-06)
“"Intrastate commercial vehicle" means a motor vehicle, vehicle, trailer, or semitrailer used or maintained for business, compensation, or profit to transport passengers or property on a highway only within the boundaries of this state”
le.utah.gov, accessed October 3, 2026. Subsection (3)(b)(i) adds the passenger test: "designed to transport more than 15 passengers, including the driver". UDOT's motor carrier pages return 403 to curl and were not read. - 47. Church Mutual, How to choose your organization's drivers
“you should establish a written policy to manage your driving program that includes requiring an annual Motor Vehicle Report (MVR) for every individual who drives on behalf of your organization.”
churchmutual.com, accessed October 3, 2026. An insurer's guidance to its own policyholders; cited as what Church Mutual says. - 48. Church Mutual, How to choose your organization's drivers, violations in the last five years
“Church Mutual recommends that organizations prohibit drivers who have had the following driving violations in the last five years: Driving under the influence of alcohol or drugs. Driving with an open container of alcohol. Reckless/careless driving. Speeding in excess of 14 miles per hour over the speed limit.”
churchmutual.com, accessed October 3, 2026. The list continues with hit and run, eluding police, a suspended or revoked license, vehicular assault or homicide, unauthorized use, racing, use in a felony and passing a stopped school bus. - 49. Church Mutual, How to choose your organization's drivers, violations in the last three years
“It is also recommended that organizations prohibit an individual from driving if they have had two or more of the following violations in the last three years: All other speeding violations. Distracted driving. Improper lane changes. Failure to yield. At-fault accidents.”
churchmutual.com, accessed October 3, 2026 - 50. Church Mutual, How to choose your organization's drivers, age and experience
“You may also want to consider a candidate’s age and amount of driving experience (e.g., requiring drivers to be 18 years old or older)”
churchmutual.com, accessed October 3, 2026 - 51. Church Mutual, 15-passenger vans require extra care (May 19, 2021)
“Van drivers should be at least 25 years old and have a clean driving record.”
churchmutual.com, accessed October 3, 2026 - 52. Brotherhood Mutual, 4 Driver Screening Essentials, bonus tip on driver age
“Another important factor in on-the-road safety is a driver’s age.”
brotherhoodmutual.com, accessed October 3, 2026. Brotherhood Mutual's own text. The age figures that follow in the article are an outside agent's opinion (Lightwell Insurance Advisors) and are not used. - 53. Brotherhood Mutual, 4 Driver Screening Essentials, driving and safety record
“It’s important to choose people without reckless driving citations or multiple traffic violations. Your ministry may be judged negligent for allowing someone with a poor driving record to operate a vehicle.”
brotherhoodmutual.com, accessed October 3, 2026. An insurer's guidance to ministries; cited as what Brotherhood Mutual says.
A church or nonprofit is putting volunteers behind the wheel of a van
12- and 15-passenger vans, volunteer drivers, CDL and USDOT questions, and what the church's policy must say.
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Adding drivers to the church's auto policy?
Send Redoubt the vehicles with their seat counts and weight ratings, the drivers you want to list, and where the trips go. We will talk through what the insurer will ask about each driver and what to settle before the first trip.
This is general insurance information, not legal advice or a coverage determination. The policy forms, the endorsements the carrier issues, and the requirement in writing from whoever is asking control.