DOT Compliance Requirements for Trucking Companies in 2025: Your Complete Checklist

Staying DOT compliant keeps your trucking company legal, safe, and on the road.

In 2025, updated FMCSA rules and stricter enforcement make compliance more important than ever.

This guide covers what DOT compliance means, who it applies to, and how to keep your fleet audit-ready all year.

What Does it Mean to be DOT Compliant?

DOT compliance means following the safety, testing, and recordkeeping regulations established by the U.S. Department of Transportation (DOT) and enforced by the Federal Motor Carrier Safety Administration (FMCSA).

Meeting these requirements helps trucking companies avoid costly fines, keep drivers qualified, and reduce crash risks, protecting both your business and the communities you serve.

DOT Compliance Updates in 2025

While most core DOT and FMCSA safety regulations remain unchanged, several important updates take effect in 2025 that affect how trucking companies manage compliance.

These changes focus on digital reporting, simplified registration, and data accuracy across federal systems.

1. Transition from MC Numbers to USDOT-Only Identifiers

The FMCSA is transitioning toward a USDOT-only identification system as part of its ongoing Registration Modernization initiative.

While Motor Carrier (MC) numbers are still in use in 2025, the agency plans to consolidate registration and authority tracking under USDOT numbers in the near future.

When the FMCSA stops issuing MC numbers, it will use suffixes with a company’s existing USDOT number to denote its type of operating authority.

What it means: Monitor FMCSA announcements for the official phase-out timeline, and begin updating internal systems, vehicle markings, and compliance records to prioritize your USDOT number as your company’s primary identifier.

2. Electronic Medical Certificate Submission Now Required

As of June 23, 2025, certified medical examiners are required to electronically transmit commercial driver medical exam results to the FMCSA’s National Registry, which automatically forwards them to state driver licensing agencies (SDLAs) after checking for errors.

What it means: Paper medical certificates are being phased out as FMCSA completes the Medical Examiner’s Certification Integration Final Rule. Drivers and carriers should verify that each driver’s medical certification appears correctly in FMCSA records, since paper cards will only serve as temporary proof during the transition period.

However, on Oct. 9, 2025, the FMCSA reissued the temporary waiver, effective from Oct. 13, 2025, to Jan. 20, 2026, allowing drivers to continue relying on paper medical certificates for up to 60 days after the issuance of the medical examiner’s certificate.

3. Revoked and Updated ELD Devices

The FMCSA has removed several noncompliant Electronic Logging Devices (ELDs) from its approved list in 2025, including the ROBINHOOD ELD, TT ELD PT30, WALKER ELD, and others.

What it means: Verify that your fleet’s devices appear on the official FMCSA Registered ELD List to stay compliant and avoid violations.

Drivers using revoked ELDs may be placed out of service.

4. Temporary Waiver for Paper Medical Certificates

To support the transition to electronic reporting, the FMCSA has reissued a temporary waiver allowing CDL and CLP holders to use paper medical certificates for up to 60 days after issuance.

The previous waiver, which was issued in July, only allowed a grace period of 15 days.

What it means: This longer grace period helps during the transition, but preparing for full electronic submission is still essential.

5. Self-Reporting Requirement Under Review

The FMCSA has proposed removing the rule that requires CDL holders to self-report motor vehicle violations to their state agencies.

States now exchange this data electronically through centralized systems.

What it means: This would simplify compliance for drivers and carriers, but you should continue following current reporting requirements until FMCSA finalizes the change.

Who Must Follow DOT Compliance Requirements?

DOT regulations apply to most Commercial Motor Vehicles (CMVs) engaged in interstate commerce that meet certain thresholds.

A CMV is generally covered if it:

• Has a gross vehicle weight rating (GVWR) or gross combination weight rating (GCWR) of 10,001 pounds or more.
• Is designed or used to transport more than 8 passengers (including the driver) for compensation.
• Is designed or used to transport more than 15 passengers (including the driver), not for compensation.
• Transports hazardous materials requiring DOT placards.

In addition, many of these vehicles require a commercial driver’s license (CDL) when they meet higher thresholds:

• 26,001 pounds or more GVWR/GCWR.
• More than 15 passengers, including the driver.
• Any vehicle requiring hazmat placards.

These rules apply to both large and small carriers, as well as full-time, part-time, and seasonal drivers.

Owner-operators and motor carriers must also comply if they operate under DOT authority.

All motor carriers operating commercial vehicles in interstate commerce must obtain a USDOT number before beginning operations.

This number serves as the company’s federal identifier, allowing the FMCSA to track safety performance, audits, inspections, and crash data.

Intrastate carriers may also need a USDOT number if they transport hazardous materials or operate in a state that requires it.

New entrants undergo a New Entrant Safety Audit within their first 12 months to verify compliance with FMCSA safety requirements.

During this audit, inspectors review driver qualification files (DQFs), drug and alcohol testing programs, and maintenance records.

Carriers most often fail due to missing paperwork, poor recordkeeping, or not implementing a compliant testing policy.

Ultimately, companies are responsible for ensuring that all qualifying drivers and vehicles meet DOT and FMCSA requirements.

DOT Compliance Checklist for 2025

Use this quick checklist to confirm your trucking company meets current DOT and FMCSA standards:

• Maintain a valid USDOT number and operating authority (MC number)
• Verify each driver’s CDL and medical card
• Keep Driver Qualification Files (DQFs) complete and current
• Conduct all required drug and alcohol tests
• Track Hours of Service (HOS) using FMCSA-approved ELDs
• Perform regular vehicle inspections and maintenance
• Retain records and logs for required timeframes
• Train staff on hazmat, securement, and safety procedures
• Work with a qualified Substance Abuse Professional (SAP) after any failed or refused DOT drug or alcohol test to guide drivers through the return-to-duty process

Key DOT Compliance Requirements

1. Drug and Alcohol Testing (49 CFR Parts 40 & 382)

The 49 CFR Part 40 & Part 382 regulations establish DOT’s drug and alcohol testing requirements, including how tests are conducted and when they are required.

Employer responsibilities:

• Implement and maintain a written drug and alcohol testing policy.
• Assign a Designated Employer Representative (DER) to oversee compliance.
• Conduct required pre-employment, random, post-accident (alcohol within 8 hours, drug within 32 hours), reasonable suspicion, return-to-duty, and follow-up tests.
• Report results to the FMCSA Clearinghouse and maintain proper records.

Employee responsibilities:

• Submit to testing when required.
• Refrain from alcohol use within 4 hours of duty and from controlled substances unless medically prescribed and authorized.
• Disclose prescription use that may affect performance.

Common violations:

• Failing to conduct random tests.
• Using a driver in safety-sensitive functions without a negative pre-employment test.
• Not removing a driver after a positive test or refusal.

Consequences:

• Civil penalties as outlined in 49 CFR part 386, Appendix B (2025 inflation-adjusted), including per-violation and daily recordkeeping fines.
• Driver disqualification or out-of-service orders.
• Increased liability exposure in crashes.

2. Return-to-Duty Process (49 CFR Part 40)

After a failed or refused test, 49 CFR Part 40 defines the return-to-duty process involving a Substance Abuse Professional (SAP) and follow-up testing.

Employer responsibilities:

• Immediately remove the driver from duty.
• Refer the driver to a qualified Substance Abuse Professional (SAP) such as American River Wellness.
• Ensure the driver does not return to duty until all SAP requirements and testing are completed with a negative result.

Employee responsibilities:

• Complete the SAP evaluation and any required treatment or education.
• Follow the SAP’s return-to-duty and follow-up testing plan.
• Pass a return-to-duty test.
• Comply with a follow-up testing plan: a minimum of six unannounced tests in the first 12 months, with possible testing for up to five years.

Common violations:

• Allowing a driver to resume duties without SAP clearance.
• Failing to complete follow-up testing requirements.

Consequences:

• Civil penalties per 49 CFR part 386, Appendix B (2025 inflation-adjusted).
• Loss of operating authority for carriers that knowingly reinstate drivers early.
• Liability exposure in the event of an accident.

3. Driver Qualifications (49 CFR Part 391)

49 CFR Part 391 outlines driver qualification standards, including licensing, medical certification, and recordkeeping.

Employer responsibilities:

• Verify every driver holds a valid CDL and current medical examiner’s certificate.
• Maintain a Driver Qualification File (DQF) with employment history, MVRs, medical exams, and safety performance records.
• Conduct annual motor vehicle record reviews.

Employee responsibilities:

• Maintain a valid CDL and medical certification.
• Disclose past driving violations and safety history.
• Notify the employer of any license suspensions or restrictions.

Common violations:

• Incomplete or missing DQF.
• Allowing medically unfit drivers to operate.
• Employing drivers with suspended CDLs.

Consequences:

• Civil penalties per 49 CFR part 386, Appendix B (2025 inflation-adjusted).
• Disqualification of the driver.
• Company liability in crashes.

4. Hours of Service (HOS) (49 CFR Part 395)

Driver work and rest limits are governed by 49 CFR Part 395, enforced through Electronic Logging Devices (ELDs).

Employer responsibilities:

• Monitor and enforce HOS limits.
• Provide drivers with FMCSA-registered ELDs (from the official list) and replace any devices that appear on the FMCSA Revoked Devices list within 60 days.
• Immediately remove revoked ELDs and require drivers to use paper logs until replaced.
• Train drivers on logbook use, ELD functionality, and exemptions.

Employee responsibilities:

• Observe the 11-hour driving limit within a 14-hour duty window.
• Take a 30-minute break after 8 cumulative hours of driving.
• Comply with weekly limits (60 hours/7 days or 70 hours/8 days).
• Record duty status accurately in ELDs.

ELD exemptions:

Some drivers are exempt from the ELD mandate, including:

• Vehicles manufactured before model year 2000, which lack compatible engine control modules.
• Driveaway/towaway operations, where the vehicle being transported is the commodity being delivered.
• Short-haul drivers who use timecards and operate within a 100-air-mile radius and non-CDL drivers operating within a 150-air-mile radius, returning to their reporting location and being released from duty within 14 consecutive hours.
• Drivers who are only required to keep records of duty status (RODs) for fewer than 8 days in a 30-day period.
• Agricultural or livestock drivers operating within a 150-air-mile radius.

Common violations:

• Driving beyond legal limits.
• Falsified or incomplete logs.
• Employer coercion or harassment to exceed hours.

Consequences:

• Civil penalties per 49 CFR part 386, Appendix B (2025 inflation-adjusted), with separate amounts for carrier and driver violations.
• Out-of-service orders.
• Increased crash risk from fatigue.

5. Vehicle Inspections and Maintenance (49 CFR Part 396)

49 CFR Part 396 requires pre- and post-trip inspections, defect repairs, and preventive maintenance.

Employer responsibilities:

• Ensure pre-trip inspections are performed.
• Require post-trip DVIRs only if a defect is found (per 2014 update).
• Perform preventive maintenance and keep records: maintenance files (one year while under control plus 6 months after disposition), daily DVIRs (3 months), periodic inspection reports (14 months).
• Repair defects before vehicles return to service.

Employee responsibilities:

• Complete inspections accurately.
• Report any defects immediately.
• Do not operate unsafe vehicles.

Common violations:

• Skipping inspections.
• Operating vehicles with defective brakes, tires, or lights.
• Failing to retain maintenance records.

Consequences:

• Out-of-service orders.
• Civil penalties as outlined in 49 CFR part 386, Appendix B (2025 inflation-adjusted), including per-violation and daily recordkeeping fines.
• Liability for preventable accidents.

6. Hazardous Materials (HazMat) Compliance (49 CFR Parts 171–180)

The handling, packaging, labeling, and transport of hazardous materials are regulated under 49 CFR Parts 171–180.

Employer responsibilities:

• Train all hazmat employees initially and at least every 3 years.
• Properly classify, package, and label shipments.
• Provide and maintain shipping papers and emergency response info.

Employee responsibilities:

• Follow hazmat handling and securement procedures.
• Carry required documentation at all times.

Common violations:

• Missing or incorrect placards.
• Incomplete or inaccurate shipping papers.
• Lack of required training.

Consequences:

• Civil fines up to $102,348 per violation, or $238,809 if resulting in death/serious injury.
• Minimum fine of $617 for training violations.
• Cargo seizure or criminal penalties for willful misconduct.

7. Cargo Securement (49 CFR Part 393, Subpart I)

49 CFR Part 393 Subpart I sets securement standards to prevent shifting or falling cargo during transit.

Employer responsibilities:

• Train drivers in securement standards.
• Provide adequate straps, chains, and blocking devices.
• Maintain securement equipment.

Employee responsibilities:

• Secure cargo before transport.
• Recheck securement as required en route.
• Keep cargo from obstructing mirrors or the driver’s view.

Common violations:

• Too few tie-downs.
• Unsecured doors or tailgates.
• Failure to block or brace cargo.

Consequences:

• Out-of-service orders.
• Civil penalties up to $19,246 per violation.
• Crash risks from shifting loads.

8. Recordkeeping (49 CFR Parts 390–399)

Carrier record retention rules for testing, HOS, inspections, and qualifications are detailed in 49 CFR Parts 390–399.

Employer responsibilities:

• Retain:
  • Drug/alcohol test results (1–5 years depending on type).
  • Hours-of-service/ELD logs (6 months, plus a backup copy).
  • Maintenance and inspection records (1 year on file, 6 months after vehicle leaves fleet, 14 months for inspection reports).
  • Driver Qualification Files (life of employment plus 3 years).
• Provide records during DOT audits or inspections.

Employee responsibilities:

• Accurately complete records.
• Report incidents for documentation.

Common violations:

• Missing or incomplete files.
• Failing to retain ELD data.
• Disorganized records that delay audits.

Consequences:

• Audit failures and downgraded safety ratings.
• Penalties of $1,584/day up to $15,846 for recordkeeping violations.
• Increased federal oversight.

9. Licenses and Permits (49 CFR Parts 365 & 367)

49 CFR Parts 365 & 367 require carriers to maintain operating authority, registrations, and proper driver licensing.

Employer responsibilities:

• Obtain and maintain a USDOT number.
• Secure operating authority (MC number) if engaging in interstate commerce.
• Keep International Registration Plan (IRP) and International Fuel Tax Agreement (IFTA) filings current (state-administered programs required for multistate operations).
• Verify that all drivers hold valid CDLs with correct endorsements.

Employee responsibilities:

• Maintain valid CDLs with required endorsements (HazMat, passenger, etc.).
• Notify the employer of suspensions or restrictions.

Common violations:

• Operating without a valid USDOT or MC number.
• Expired CDLs or missing endorsements.
• Failure to register under UCR or IFTA.

Consequences:

• Civil penalties for operating without valid authority, as specified in 49 CFR part 386, Appendix B (2025 inflation-adjusted).
• Loss of operating authority.
• Vehicle impoundment or seizure.

10. Insurance Requirements (49 CFR Part 387)

49 CFR Part 387 establishes financial responsibility requirements for motor carriers to ensure adequate protection against public liability.

Employer responsibilities:

• Maintain proof of financial responsibility at all times.
• Meet minimum liability coverage:
  • $750,000 for general freight carriers with gross vehicle weight ratings of 10,001 or more pounds.$1 million to $5 million for hazardous materials and passenger carriers, depending on cargo type and passenger capacity.File and keep current insurance documentation (Form MCS-90) with the FMCSA.
  • Retain proof of financial responsibility at the principal place of business.

Employee responsibilities:

• Report any accidents or incidents that could affect insurance coverage.
• Follow company safety and reporting policies to prevent claims and coverage issues.
• Not to operate a CMV when the employer’s insurance has lapsed.

Common violations:

• Lapsed or expired insurance coverage.
• Missing or incorrect insurance filings.
• Insufficient liability coverage based on cargo type.

Consequences:

• Suspension or revocation of operating authority.
• Civil penalties and possible vehicle impoundment.
• Loss of contracts or broker partnerships due to noncompliance.

How to Stay Compliant

1. Keep Policies Clear and Updated

Maintain a written drug and alcohol testing policy, safety procedures, and driver qualification standards.

Review them annually to reflect the latest FMCSA rules.

2. Digitize Records

Paper logs and inspection reports are easy to lose.

Using digital platforms for DVIRs, ELDs, and testing results makes it easier to provide proof during audits and reduces errors.

3. Train Employees Regularly

Compliance isn’t just about paperwork – drivers and staff need to understand the rules.

Provide regular training on:

• Hours of Service rules
• Cargo securement requirements
• Drug and alcohol testing procedures
• Hazardous materials handling (when applicable)
• Electronic Logging Device (ELD) use, including how to certify logs, make edits, and transfer data during roadside inspections

4. Monitor Compliance Continuously

Don’t wait for an audit to uncover gaps.

Conduct internal reviews of driver qualification files, HOS logs, and maintenance records to correct issues early.

5. Use Qualified Partners

Work with qualified Substance Abuse Professionals (SAPs) to handle violations properly.

At American River Wellness, we guide drivers through the DOT SAP program, helping them return to duty safely while staying compliant.

6. Stay Informed

FMCSA regulations are updated regularly.

Subscribe to agency newsletters or industry updates so your policies evolve with the law.

Ongoing FMCSA Clearinghouse queries also help carriers stay compliant by checking drivers’ drug and alcohol testing status, return-to-duty progress, and eligibility for safety-sensitive duties throughout the year.

Download the official DOT Employer Guidelines (October 2025) for the most up-to-date compliance requirements.

Stay Compliant with American River Wellness

DOT compliance is critical for protecting your drivers, keeping your fleet on the road, and avoiding costly penalties.

With clear policies, accurate records, and consistent training, your company can meet FMCSA requirements confidently.

If you need support with the DOT SAP program, contact American River Wellness today to keep your operations safe and fully compliant: (833)436-8727

DISCLAIMER: This information is intended solely for educational and informational purposes. It should not be interpreted as legal counsel or guidance.

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