• The Unified Registration System (URS) was designed to simplify the registration process and serve as an accurate depository of information for all entities regulated by the Federal Motor Carrier Safety Administration (FMCSA).
• Under URS, all entities will be required to notify the FMCSA within 30 days of any changes to their legal name, form of business, or address.
• The URS has differing effective/compliance dates based on various provisions.

The United States Department of Transportation (USDOT) identification number system, the commercial registration system (OP-1 forms used for for-hire authority applications), and the financial responsibility information system will eventually all be combined into one system — the Unified Registration System (URS). The new system is designed to simplify the registration process and serve as an accurate depository of information for all Federal Motor Carrier Safety Administration (FMCSA) regulated entities, including motor carriers, brokers, freight forwarders, intermodal equipment providers, hazmat permit holders, and cargo tank manufacturing/repair facilities. Under the new system, a number of things will change, including:

• The USDOT number will be the sole identifier;
• MC numbers will be discontinued;
• The MCS-150, MCS-150B, OP-1, etc., will be combined into one form, the MCSA-1;
• Once MCSA-1 is implemented, all new applications and updates must be filed electronically (paper will no longer be accepted); and
• A $300 fee will be implemented for all new applicants (and both new private and for-hire carriers will be subject to the fee).

Provisions in the rule that became effective November 1, 2013, allow the FMCSA to inactivate the USDOT number of entities who fail to update their MCS-150 information every two years; in addition, a provision prohibiting operation with an inactivated DOT has been added. Updating the MCS-150 must be done to stay in business. Failure of carriers to update their Form MCS-150 information will result in deactivation of their USDOT number, and civil penalties.

Also under URS, all entities will be required to notify the FMCSA within 30 days of any changes to their legal name, form of business, or address. There will be no fee for updating information, and entities will be able to update their information as often as necessary. However, making these updates does not relieve an entity of compliance with the biennial update requirement.

URS implementation

The majority of the Unified Registration System (URS) rule changes were originally slated to be effective October 23, 2015; however, due to unforeseen circumstances, the Federal Motor Carrier Safety Administration (FMCSA) was not ready to fully implement URS as of that date. FMCSA announced in the October 21, 2015, Federal Register that it was delaying the URS effective dates. In late July 2016, the FMCSA further extended the URS effective dates into 2017. On January 17, 2017, FMCSA suspended the implementation of URS and has not yet established new implementation dates. Final implementation of URS will occur at a later date to be determined by FMCSA.

URS history and timeline

An October 21, 2015, Federal Register final rule indicated that the Federal Motor Carrier Safety Administration (FMCSA) would be going forward with implementation of the MCSA-1 form, the electronic-only filing form, but only for new applicants (through adoption of a temporary rule). New applicants are those entities that are applying for a United States Department of Transportation (USDOT) number, and if applicable, operating authority, who do not at the time of application have an active registration or USDOT, Motor Carrier (MC), Mexico owned or controlled (MX), or Freight Forwarder (FF) number, and who have never had an active registration or USDOT, MC, MX, or FF number. These new applicants, starting December 12, 2015, use the online MCSA-1 form at www.fmcsa.dot.gov/urs to apply for a new USDOT number, authority, etc.

A Federal Register rule on July 28, 2016, extended the URS effective dates from September 20, 2016, and December 31, 2016, to January 14, 2017, and April 14, 2017, respectively. This meant that all existing entities (and any new entities at this point) would’ve started to use the MCSA-1 on January 14, 2017.

However, FMCSA published another Federal Register final rule on January 17, 2017, suspending the final implementation of the URS.

At a later date to be determined by FMCSA, all new private carriers of hazardous materials and for-hire carriers of exempt commodities will be required to file insurance with the FMCSA. Existing private carriers of hazardous materials and for-hire carriers of exempt commodities will also eventually be required to file proof of insurance.

At a later date to be determined by FMCSA, all new private carriers (hazardous and non-hazardous) and for-hire carriers of exempt commodities will be required to submit electronic designation of agents for service of process (BOC-3 form) as a condition of registration. Existing private carriers and for-hire carriers of exempt commodities will also eventually need to file a designation of process agents.

URS effective dates

The table below summarizes the previous effective/compliance dates and the new effective/compliance dates: