Private carrier vs for-hire carrier
A business delivering its own goods is a private carrier; one that hauls another's goods for a fee, even sometimes, is a for-hire carrier on those loads. For-hire carriage across state lines needs FMCSA registration under 49 U.S.C. 13901 and, at 10,001 lb GVWR and up, a $750,000 liability filing under 49 CFR 387.9; under 49 U.S.C. 14706 the carrier answers for the goods. A private carrier needs a USDOT number for interstate commercial motor vehicles but no MC number, and a Utah intrastate private motor carrier carries $750,000 under UDOT rule R909-1-4. A business that withdrew its MC application and hauls nothing for a fee is a private carrier until its first paid load.
What is the difference between a private carrier and a for-hire carrier?
A for-hire carrier is paid to transport goods or passengers; a private carrier transports its own property and is paid for something else. 49 CFR 390.5T, the definitions section in force for FMCSA's safety rules, says a for-hire motor carrier is "a person engaged in the transportation of goods or passengers for compensation," and a private motor carrier is one that "provides transportation of property or passengers, by commercial motor vehicle, and is not a for-hire motor carrier." eCFR marks the unsuffixed 390.5 suspended indefinitely, again on July 21, 2026.
The registration statute draws the same line by who owns the load. 49 U.S.C. 13102(14) defines a motor carrier as "a person providing motor vehicle transportation for compensation," and 13102(15) defines a motor private carrier as a person, other than a motor carrier, transporting property it owns, leases or holds as bailee "for sale, lease, rent, or bailment or to further a commercial enterprise." A bakery van full of the bakery's bread is a motor private carrier; the same van carrying a restaurant's chairs for a fee is providing transportation for compensation, a motor carrier under 13102(14).
Do you need an MC number if you haul your own products and sometimes other people's?
A business needs operating authority, the MC number, for interstate trips carrying other people's goods for a fee, and not for trips carrying its own goods. 49 U.S.C. 13901(a) lets a person "provide transportation as a motor carrier" under FMCSA's jurisdiction "only if the person is registered under this chapter," and that motor carrier is the for-compensation carrier of 13102(14). FMCSA's FAQ on private carriers, last updated May 26, 2023, says "A private motor carrier transports its own goods and is required to have a USDOT number but does not need operating authority (MC number)." Its operating authority FAQ, last updated May 20, 2023, lists "Private carriers (carriers that transport their own cargo)" among carriers that do not need it.
One paid interstate load for another business is transportation for compensation under 13102(14), and 49 CFR 387.7(a) bars operating it until the financial responsibility is in effect. Inside Utah, Utah Code 72-9-102(4) defines a motor carrier as a person "transacting the business of transporting passengers, freight, merchandise, or other property by a commercial vehicle on a highway within this state," with no for-hire condition, so Utah's motor carrier chapter names private and for-hire carriers alike.
| Question | Private carrier (own goods) | For-hire carrier (others' goods for a fee) |
|---|---|---|
| FMCSA registration | USDOT number for interstate commercial motor vehicles (49 CFR 390.19T); no MC number (FMCSA FAQ) | USDOT number and operating authority, the MC number (49 U.S.C. 13901) |
| Federal liability floor | None for non-hazardous goods: 49 CFR 387.3(a) reaches for-hire carriers | $750,000 interstate at 10,001 lb GVWR and up (49 CFR 387.9); insurer files within 20 days of the Register notice (49 CFR 365.109T) |
| Utah liability floor | $750,000 for an intrastate private motor carrier (R909-1-4(2)); 30/65/25 on every policy (31A-22-304) | 30/65/25 on every policy (31A-22-304); R909-1-4 states no intrastate for-hire figure |
| Who answers for the goods | The owner bears its own loss; ISO's auto form excludes property transported (CA 00 01) | The carrier, for actual loss (49 U.S.C. 14706 interstate; Utah Code 72-9-401 intrastate) |
Sources: 6, 4, 17, 7, 8, 9, 11, 12, 16, 18, 30, 10, 32, 27, 28, 33
What insurance does a private carrier need in Utah?
A Utah private carrier's liability floor is $750,000 under UDOT rule R909-1-4(2), above the 30/65/25 that Utah Code 31A-22-304 sets on every policy. R909-1-4(1) defines the private motor carrier as one transporting property or passengers "by commercial motor vehicle" and does not define that vehicle; Utah Code 72-9-102(3) defines an intrastate commercial vehicle at 26,001 lb GVWR or GCWR with an adult driver, more than 15 passengers, or placarded hazardous materials. Redoubt reads the two together as the line below which only 31A-22-304's $30,000 per person, $65,000 per accident and $25,000 property damage (policies issued or renewed on or after January 1, 2025) apply; that reading is Redoubt's, not a sentence in either text.
49 CFR 387.3(a) applies the federal schedule "to for-hire motor carriers operating motor vehicles transporting property in interstate or foreign commerce," so a private carrier of non-hazardous goods is outside it, while R909-1-4(3) requires "a $1,000,000 minimum level of financial responsibility, and an MCS-90 endorsement" of oil and hazardous materials carriers, for-hire and private. R909-1-4 states no intrastate for-hire minimum for general freight; as of October 12, 2026 that figure is an open question.
An interstate private carrier still registers with FMCSA: 49 CFR 390.19T(a)(1) requires a motor carrier "conducting operations in interstate commerce" to file Form MCS-150 before it begins operations, a registration separate from any insurance filing.
What changes in the insurance when you start hauling for others for a fee?
Hauling for others for a fee across state lines adds three things: operating authority, a liability filing at a $750,000 floor, and liability for the goods. 49 CFR 387.7(a) bars a motor carrier from operating until the 387.9 minimum is in effect, and 387.9 sets $750,000 for a for-hire carrier of non-hazardous property in interstate or foreign commerce at 10,001 lb GVWR and up. FMCSA's filing page says "a financial responsibility provider must file the appropriate insurance form(s) on behalf of the applicant," and 49 CFR 365.109T(a)(5) sets that filing at 20 days after the application notice is published in the FMCSA Register.
The goods become the carrier's liability: 49 U.S.C. 14706(a)(1) makes an interstate carrier liable "for the actual loss or injury to the property" it receives for transportation, and Utah Code 72-9-401(1) does the same for a motor carrier moving property between two Utah points, adding in (1)(b) that a contract or receipt "may not exempt the motor carrier from this liability." On ISO's CA 00 01 11 20 the auto policy excludes property damage "involving property owned or transported by the "insured" or in the "insured's" care, custody or control," and a carrier's own form may differ.
Tell the insurer the share: how many trips, or how much revenue, is other people's goods for a fee, so the application describes the work on the road.
I withdrew my MC application but still use the trucks. What insurance do I need now?
A business that withdrew its MC application and hauls nothing for a fee is a private carrier, insured under Utah's rules and without a federal filing. The withdrawal is a written request: 49 CFR 365.123 says "If the applicant wishes to withdraw an application, it shall request dismissal in writing," and FMCSA's May 2026 Motus job aid says the company account's Applications section lets a registrant "withdraw or remove pending applications." FMCSA's dismissed-application FAQ, last updated August 4, 2023 and written before Motus replaced URS on 2026-05-19, says an application is "Dismissed if the applicant fails to provide evidence of financial responsibility (proof of insurance) and a designation of process agent Form BOC-3 approximately 90 days from the date of filing," with a later application at "$300 per type of operating authority requested"; that 90 days is FMCSA's dismissal clock, not the 20-day filing deadline of 365.109T.
FMCSA's revocation Q&A of May 5, 2020, guidance FMCSA says does not have the force and effect of law, describes a carrier without operating authority: it "is limited to intrastate operations, operations within a commercial zone, or other operations specifically exempted under 49 U.S.C. § 13506," and "Insurance filings are only required to maintain active operating authority." The USDOT number is a separate registration under 49 CFR 390.19T; FMCSA's pages do not say what a withdrawal does to it, so check the company account in Motus, whose Operation Details section "Displays your company operations type" with an Update button, and set the operations type to what the business does now.
The insurance that remains is the private carrier's: Utah Code 31A-22-304's 30/65/25 on every vehicle and R909-1-4(2)'s $750,000 for an intrastate private motor carrier. An insurer withdraws a certificate of insurance it filed by notice to FMCSA: 49 CFR 387.313T(d) says such certificates "shall not be cancelled or withdrawn until 30 days after written notice has been submitted to the FMCSA" on Form BMC-35. Ask the insurer to withdraw any filing it made and to write the policy for private carriage, and confirm to it that nothing is hauled for a fee.
What do you tell the insurer, and what happens after you send it?
Redoubt asks for one list, private or for-hire: the vehicles, the drivers, the registration numbers, what rides in the truck, and the date cover has to start. Send it by text; the first reply is a conversation about which policy fits the work and what the insurer will file or withdraw.
- Each vehicle and trailer: year, make, model, body type, GVWR and value
- Every driver: name, date of birth, licence number and class
- USDOT number, and the MC or docket number if an application was filed, with what FMCSA's record says the business does
- Whether anything is hauled for a fee and, if so, the share of trips or revenue that is other people's goods
- What the vehicles carry and the highest value on one load
- How far the vehicles go: local, regional or long distance
- The date coverage has to start, and the current declarations page or the dates of prior coverage
Does a private carrier need an MCS-90 endorsement?
Not for non-hazardous goods. 49 CFR 387.7(d) lists the MCS-90 as proof of the Part 387 financial responsibility, and 387.3(a) applies that subpart to for-hire interstate property carriers; a private carrier of oil or hazardous materials needs $1,000,000 and the endorsement under Utah R909-1-4(3).
What does "not for hire" on a truck door mean for insurance?
The words on the door do not set the classification; compensation does, because 49 CFR 390.5T's definitions turn on transportation "for compensation."
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 390.5T, definition of for-hire motor carrier, eCFR
“For-hire motor carrier means a person engaged in the transportation of goods or passengers for compensation.”
ecfr.gov, accessed October 12, 2026. The T section is the text eCFR prints in force; the unsuffixed section is marked suspended since January 14, 2017. - 2. 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 12, 2026. Same pull. 390.5T's commercial motor vehicle definition starts at 10,001 lb GVWR, GCWR, GVW or GCW for property in interstate commerce. - 3. 49 CFR 390.5, effective date note, eCFR
“At 91 FR 45661, July 21, 2026, the suspension was lifted, § 390.5 was amended, and the section was again suspended indefinitely, effective July 21, 2026.”
ecfr.gov, accessed October 12, 2026. The last entry in the section's effective date note; the first entry records the suspension effective January 14, 2017. - 4. 49 U.S.C. 13102(14), definition of motor carrier, 2023 edition, govinfo
“The term "motor carrier" means a person providing motor vehicle transportation for compensation.”
govinfo.gov, accessed October 12, 2026 - 5. 49 U.S.C. 13102(15), definition of motor private carrier, 2023 edition, govinfo
“The term "motor private carrier" means a person, other than a motor carrier, transporting property by motor vehicle when— (A) the transportation is as provided in section 13501 of this title; (B) the person is the owner, lessee, or bailee of the property being transported; and (C) the property is being transported for sale, lease, rent, or bailment or to further a commercial enterprise.”
govinfo.gov, accessed October 12, 2026 - 6. 49 U.S.C. 13901(a), requirements for registration, 2023 edition, govinfo
“A person may provide transportation as a motor carrier subject to jurisdiction under subchapter I of chapter 135 or service as a freight forwarder subject to jurisdiction under subchapter III of such chapter, or service as a broker for transportation subject to jurisdiction under subchapter I of such chapter only if the person is registered under this chapter to provide such transportation or service.”
govinfo.gov, accessed October 12, 2026 - 7. FMCSA FAQ, What is a private motor carrier?
“A private motor carrier transports its own goods and is required to have a USDOT number but does not need operating authority (MC number).”
fmcsa.dot.gov, accessed October 12, 2026. The page prints "Last Updated: May 26, 2023". - 9. Utah Code 72-9-102(4), definition of motor carrier
“"Motor carrier" means a person engaged in or transacting the business of transporting passengers, freight, merchandise, or other property by a commercial vehicle on a highway within this state and includes a tow truck business.”
le.utah.gov, accessed October 12, 2026. Whether a private carrier's truck is a commercial vehicle turns on the thresholds in subsection (3). - 10. Utah Code 72-9-102(3), definition of intrastate commercial vehicle
“"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 if the commercial vehicle: (a) (i) has a manufacturer's gross vehicle weight rating or gross vehicle weight, or gross combination weight rating or gross combination weight of 26,001 or more pounds, whichever is greater”
le.utah.gov, accessed October 12, 2026. The quoted clause continues "and is operated by an individual who is 18 years old or older"; the definition then adds 16,001 lb with a driver under 18, more than 15 passengers, more than 12 passengers at 13,000 lb and up, or placarded hazardous materials. - 11. 49 CFR 390.19T(a)(1), who files Form MCS-150, 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 12, 2026. Paragraph (b)(1) sets the first filing "Before it begins operations" and (b)(2) a filing every 24 months. The T section is the text eCFR prints in force; the unsuffixed section is marked suspended since January 14, 2017. - 12. 49 CFR 387.3(a), applicability of Subpart A, eCFR
“This subpart applies to for-hire motor carriers operating motor vehicles transporting property in interstate or foreign commerce.”
ecfr.gov, accessed October 12, 2026. Paragraph (b) adds motor carriers of hazardous materials, substances and wastes in interstate, foreign or intrastate commerce. No suspension note on 387.3. - 13. 49 CFR 387.7(d), proof of financial responsibility, the MCS-90, eCFR
“Proof of the required financial responsibility shall be maintained at the motor carrier's principal place of business. The proof shall consist of— (1) “Endorsement(s) for Motor Carrier Policies of Insurance for Public Liability Under Sections 29 and 30 of the Motor Carrier Act of 1980” (Form MCS-90) issued by an insurer(s);”
ecfr.gov, accessed October 12, 2026. Backs the MCS-90 FAQ. Pulled through the eCFR versioner API at the 2026-10-01 point in time. - 14. FMCSA, Insurance Filing Requirements, who files
“Once an entity applies for Operating Authority (MC/FF/MX), a financial responsibility provider must file the appropriate insurance form(s) on behalf of the applicant.”
fmcsa.dot.gov, accessed October 12, 2026. The page prints "Last updated: Thursday, March 26, 2026". - 15. FMCSA, Motus: Navigating the Company Account Page (May 2026 job aid), Operation Details
“Operation Details: Displays your company operations type, New Entrant Program entry/exit dates, cargo classifications, HM details, and the number of vehicles and drivers you operate.”
fmcsa.dot.gov, accessed October 12, 2026 - 16. 49 CFR 387.9, schedule of limits, row 1, eCFR
“For-hire (In interstate or foreign commerce, with a gross vehicle weight rating of 10,001 or more pounds) Property (nonhazardous) $750,000”
ecfr.gov, accessed October 12, 2026. Rows 2 to 4 cover hazardous materials and oil at $1,000,000 and $5,000,000, for-hire and private. - 17. 49 CFR 387.7(a), financial responsibility required, eCFR
“No motor carrier shall operate a motor vehicle until the motor carrier has obtained and has in effect the minimum levels of financial responsibility as set forth in § 387.9 of this subpart.”
ecfr.gov, accessed October 12, 2026 - 18. 49 CFR 365.109T(a)(5), insurance filing within 20 days, eCFR
“Financial responsibility is indicated by filing within 20 days from the date an application notice is published in the FMCSA Register: (i) Form BMC-91 or 91X or BMC 82 surety bond”
ecfr.gov, accessed October 12, 2026. Paragraph (a)(6) gives the BOC-3 the same 20 days. The suspended 365.109(a)(5) prints 90 days. The T section is the text eCFR prints in force; the unsuffixed section is marked suspended since January 14, 2017. - 19. 49 CFR 365.123, applicant withdrawal, eCFR
“If the applicant wishes to withdraw an application, it shall request dismissal in writing.”
ecfr.gov, accessed October 12, 2026. The whole section. No suspension note on 365.123. - 20. FMCSA, Motus: Navigating the Company Account Page (May 2026 job aid), Applications
“Applications: View the real-time status of pending items, such as new registrations or legal name changes. You can also withdraw or remove pending applications from this section.”
fmcsa.dot.gov, accessed October 12, 2026. The Operating Authority Registration(s) section adds that a granted authority can be withdrawn or inactivated from its Actions/Options function. - 21. FMCSA FAQ, My operating authority application was dismissed, what can I do?
“An application for operating authority is Dismissed if the applicant fails to provide evidence of financial responsibility (proof of insurance) and a designation of process agent Form BOC-3 approximately 90 days from the date of filing of the application.”
fmcsa.dot.gov, accessed October 12, 2026. The page prints "Last Updated: August 4, 2023" and still refers to the Unified Registration System, which Motus replaced on 2026-05-19. - 22. FMCSA FAQ, My operating authority application was dismissed, fee for a new application
“pay the appropriate fee of $300 per type of operating authority requested. Applications following a rejection/dismissal must be filed under the same USDOT and MC/FF numbers.”
fmcsa.dot.gov, accessed October 12, 2026. Same page. $300 matches the fee in 49 CFR 360.3T. - 24. FMCSA, Voluntary Revocation of Operating Authority Registration Q&A, insurance filings
“Yes, unless the company requests a voluntary revocation of operating authority registration. Insurance filings are only required to maintain active operating authority.”
fmcsa.dot.gov, accessed October 12, 2026. The answer to "Am I still required to file proof of financial responsibility or insurance?" on the same page. - 25. 49 CFR 387.313T(d), cancellation notice for filings, eCFR
“shall not be cancelled or withdrawn until 30 days after written notice has been submitted to the FMCSA at its offices in Washington, DC, on the prescribed form”
ecfr.gov, accessed October 12, 2026. The paragraph names Form BMC-35 for policies of insurance and BMC-36 for surety bonds, and starts the 30 days when FMCSA actually receives the notice. The T section is the text eCFR prints in force; the unsuffixed section is marked suspended since January 14, 2017. - 26. 49 U.S.C. 14706(a)(1), receipt or bill of lading, 2023 edition, govinfo
“A carrier providing transportation or service subject to jurisdiction under subchapter I or III of chapter 135 shall issue a receipt or bill of lading for property it receives for transportation under this part.”
govinfo.gov, accessed October 12, 2026. The Carmack Amendment. It applies to carriers under FMCSA's jurisdiction, not to private carriage. - 27. 49 U.S.C. 14706(a)(1), liability for actual loss, 2023 edition, govinfo
“The liability imposed under this paragraph is for the actual loss or injury to the property caused by (A) the receiving carrier, (B) the delivering carrier, or (C) another carrier over whose line or route the property is transported”
govinfo.gov, accessed October 12, 2026. Same paragraph: "Failure to issue a receipt or bill of lading does not affect the liability of a carrier." - 28. Utah Code 72-9-401(1), motor carrier liability for property carried within Utah
“A motor carrier receiving property for transportation from one point in this state to another point in this state shall issue a receipt or bill of lading for the property, and shall be liable to the lawful holder of the property for any loss, damage, or injury to the property caused by the motor carrier,”
le.utah.gov, accessed October 12, 2026. Subsection (1)(b): "A contract, receipt, rule, regulation, or other limitation of any character whatsoever may not exempt the motor carrier from this liability." Whether the section reaches a business carrying its own goods is not stated. - 29. Utah Admin. Code R909-1-4(1), definition of private motor carrier
“"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.”
adminrules.utah.gov, accessed October 12, 2026. The rule does not define commercial motor vehicle; Utah Code 72-9-102(3) sets the intrastate thresholds. - 30. Utah Admin. Code R909-1-4(2), intrastate private motor carrier minimum
“Each intrastate private motor carrier must have a minimum amount of $750,000 liability.”
adminrules.utah.gov, accessed October 12, 2026. The rule names private carriers and hazmat carriers only; it states no figure for intrastate for-hire carriers of general freight. - 31. Utah Admin. Code R909-1-4(3), oil and hazardous materials carriers
“must have a $1,000,000 minimum level of financial responsibility, and an MCS-90 endorsement maintained at the principal place of business.”
adminrules.utah.gov, accessed October 12, 2026. The subsection opens "Each interstate and intrastate for-hire and private motor carriers transporting any quantities of oil listed in 49 CFR 172.101; hazardous waste, hazardous material, and hazardous substances defined in 49 CFR 171.8". - 32. Utah Code 31A-22-304(2), motor vehicle liability minimums from January 1, 2025
“a policy issued or renewed on or after January 1, 2025, containing motor vehicle liability coverage may not limit the insurer's liability under that coverage below the following: (a) (i) $30,000 because of liability for bodily injury to or death of one person”
le.utah.gov, accessed October 12, 2026. (2)(a)(ii) sets $65,000 for two or more persons and (2)(a)(iii) $25,000 for property damage; (2)(b) allows a $90,000 single limit. - 33. ISO CA 00 01 11 20, Business Auto Coverage Form, Section II B.6, Care, Custody Or Control exclusion
“"Property damage" to or "covered pollution cost or expense" involving property owned or transported by the "insured" or in the "insured's" care, custody or control. But this exclusion does not apply to liability assumed under a sidetrack agreement.”
assets.touchpointmarkets.com, accessed October 12, 2026. 11 20 is the newest edition found on the open web; a carrier's policy may carry a later edition or its own form. - 34. Redoubt, commercial auto insurance guide, what to send
“Text Redoubt the broker packet, the lender's insurance letter, the platform's upload screen or the renewal itself, with the vehicles and the date you need it by. We will say what can be bound now, what needs the carrier, and what to send back.”
www.redoubt.insure, accessed October 12, 2026
FMCSA will not activate the MC number until the insurer's filing is on file
New authority, hotshot and intrastate carriers: the MC number, the BMC-91 filing, the limits, and how long activation takes.
Elsewhere on the site
Send the vehicle list and what the trucks carry
Text Redoubt the year, make, model, body type and value of each vehicle and trailer, every driver's name, date of birth and licence number, your USDOT and MC or docket numbers if you have them, a paragraph on what the business does and whether any load is carried for a fee, and the date cover has to start, and we will talk through which policy fits the work and what the insurer will file or withdraw.
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.