Expect an Audit if your Unified Carrier Registration (UCR) Changes

Wayne Schooling • June 5, 2024

If your fee bracket has changed under the Unified Carrier Registration (UCR) program, make sure your records back up the new numbers for your fleet. States are required to perform audits each year on carriers who move from one payment bracket to a lower bracket. The goal is to verify that the carrier has properly deducted vehicles from its UCR payment.

How many vehicles do you own or operate?

Most carriers, freight forwarders, leasing companies, and brokers engaged in interstate commerce are subject to annual registration and fees under the UCR program. The fee structure is a bracket system, with the fees based on the number of commercial motor vehicles (CMVs) a carrier owns or operates.

A CMV is owned or operated by a carrier if the vehicle is:

Registered under federal or state law, or both, in the name of the carrier; or
Controlled by the carrier under a long-term lease during a vehicle registration year. A vehicle operated by a registrant under a lease of 30 days or less need not be included in the count.

The number of CMVs owned or operated and subject to fees is either:

Option A: The number reported on the most recently filed MCS-150 with the USDOT, or
Option B: The total number of CMVs owned or operated for the twelve-month period ending on June 30 immediately prior to the beginning of a given registration year.

Motor vehicles used solely in intrastate operations may be excluded from the vehicle count. This exclusion must be clearly documented (see “UCR-1 Form” below).

Determining your bracket

For a carrier, fees are based on the number of CMVs it owns or operates.

Fees are charged at the lowest bracket level for a:

Broker,
Leasing company (that is not also a motor carrier), or
Freight forwarder (that does not own or operate motor vehicles).

Brackets are defined as follows:

Bracket	Number of Vehicles
1	0 - 2
2	3 - 5
3	6 - 20
4	21 - 100
5	101 - 1,000
6	Over 1,000

Proving your numbers

Carriers must retain two specific documents and provide them to the base state upon request:

UCR-1 Form: If you subtracted vehicles used exclusively for intrastate transportation when you registered for UCR, you must maintain a list of the vehicles you subtracted. To subtract a CMV under this option, during the UCR registration year:
The vehicle did not or will not travel outside the state;
The vehicle did not or will not carry property, waste, or recyclable material that originated outside the state or is destined for a location outside the state; AND
The vehicle was not or will not be registered under the International Registration Plan (vehicle must not have an apportioned plate).
UCR-2 Form: If you counted your vehicles using Option B (from above) and this count puts you in a lower fee category compared to Option A, you must keep a list of the vehicles covered by your UCR registration on Form UCR-2.

UCR registrants must keep UCR records for two years from the due date or filing date, whichever is later, plus any time period included as a result of state decisions or inquiries.

Key to remember: If your UCR fee bracket has changed – and especially if it is lower – make sure your records back up the new numbers for your fleet.

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