Motor carrier classes by state
Montana’s motor carrier safety statute contains two descriptions of who it covers. One reaches every for-hire carrier with no weight attached to it at all. The other reaches intrastate vehicles at 26,001 pounds and above. They sit in the same list, joined by the word “or”, and nothing in the statute or in the rule beneath it says which one governs a light combination hauling for money inside the state.
Most of what makes light-combination freight difficult is common to the whole class: a window measured in hours, a securement duty that changes with every deck, and a single high-value shipment that outruns a limit written against an average one. Those belong on the type page at hot shot trucking insurance, which is where they are dealt with.
Montana’s own contribution is a piece of unresolved drafting sitting exactly where this operator lives. MCA 61-10-154(2) directs the department of transportation to adopt safety standards for a list of six things, and the list is disjunctive. Its first item is “any for-hire motor carrier or any private motor carrier” — no weight, no configuration, no commodity. Its third item is “any motor vehicle or vehicle combination used in intrastate commerce that has a gross vehicle weight rating, gross combination weight rating, gross vehicle weight, or gross combination weight, whichever is greater, of 26,001 pounds or more and that is not a farm vehicle operating solely in Montana”.
Read the first item and a paid load makes the operator a covered carrier at any weight. Read the third and an intrastate combination under 26,001 pounds sits below the line. Both readings are available on the face of the same subsection, and the rule the department actually adopted tracks the split rather than closing it. This page does not resolve the question either, because the source does not, and a page that picked a side would be presenting an authoring decision as a finding.
What follows is what Montana does say, section by section, with the date of the version read. The safety rule, the driver-licensing rules it points at, the carrier-classification chapter and the policy statute the state routes property carriers to were all amended on separate clocks, and a page that treated them as one regime would be describing something Montana does not have.
Running paid freight inside Montana on a truck and trailer that stay under 26,001 pounds? That is the configuration the statute describes twice and reconciles never — and it is a question your underwriter will want answered before the filing conversation, not after.
Send the rating of the power unit and of the heaviest trailer you actually hitch, and tell us whether any dispatch leaves the state. Those two answers decide which reading of MCA 61-10-154 you have to be able to defend.
The whole of the ambiguity is visible in a single subsection. MCA 61-10-154(2) reads: “The department of transportation shall adopt, by rule, standards for safety of operations of: (a) any for-hire motor carrier or any private motor carrier;” and then, four items later, “(c) any motor vehicle or vehicle combination used in intrastate commerce that has a gross vehicle weight rating, gross combination weight rating, gross vehicle weight, or gross combination weight, whichever is greater, of 26,001 pounds or more and that is not a farm vehicle operating solely in Montana”.
Paragraph (a) attaches to a person — a carrier. Paragraph (c) attaches to a thing — a vehicle or combination, at a stated weight, in intrastate commerce. They are not layered. Item (b) between them covers interstate vehicles at a weight the statute names separately, and items (d) through (f) cover passenger configurations and placarded hazardous materials. The six items are alternatives, and paragraph (a) carries no qualifier that would confine it to the vehicles described in the other five.
The implementing rule inherits the split verbatim rather than deciding it. ARM 18.8.1502(1) opens: “Any commercial motor vehicle or motor carrier subject to regulation by the department under 61-10-154, MCA, shall comply with and the department adopts by reference the following portions of the Federal Motor Carrier Safety Regulations”. Vehicle or carrier — the same two objects, in the same disjunctive posture, one sentence lower.
Montana also imports the meanings it uses. MCA 61-10-154(1) provides that “for-hire motor carrier”, “private motor carrier”, “gross vehicle weight rating” and “gross combination weight rating” have the same meaning as in the federal safety definitions. So the terms in paragraph (a) are borrowed, defined terms — which is what makes the reading that a paid intrastate load brings a carrier inside the section a textual one rather than a strained one.
The practical posture for an operator is not comfortable but it is honest. A light combination hauling for compensation inside Montana can be described accurately as inside paragraph (a) and as outside paragraph (c) at the same moment. Nothing in the chapter or in the rule below it says which description controls. That is the finding, and it is carried here unresolved because it is unresolved in the source.
Montana does not promise that its adopted standards match the federal text. MCA 61-10-154(3) provides that “Standards of safety adopted under this section must substantially comply, within allowed tolerance guidelines, to the federal motor carrier safety regulations and the federal hazardous material regulations as applied to motor carriers and vehicles transporting passengers or property in commerce.”
That sentence is doing more work than it looks like it is doing. “Substantially comply, within allowed tolerance guidelines” is a standard of approximation written into the enabling statute, not a statement that the state text and the federal text are identical. An operator or a broker reconciling a Montana intrastate obligation against a federal one is reconciling against a statute that has already told them the two may differ within a tolerance it does not quantify.
The rule then names its edition. ARM 18.8.1502(1) adopts a specified list — parts 373 and 375, parts 377 through 379, part 382, part 383, part 385, part 386 subpart F, part 387, parts 390 through 399, and Appendix G to the relevant subchapter — “as updated through April 25, 2024”. That is a fixed date, not a rolling reference, so a federal amendment made after it does not reach an intrastate Montana carrier through this rule on its own.
The date and the rule carrying it are not the same date, and both were read on the rule’s own amendment history. The most recent amendment on that history is 2024 MAR p. 1455, effective June 22, 2024. So the department updated the rule and the edition it points at in the same motion, and an operator checking currency has two dates to check rather than one.
Because the adopted list is enumerated, its boundaries matter as much as its contents. Parts named in the list are adopted for Montana intrastate purposes at the April 25, 2024 edition. Parts not named are not adopted by this rule at all, and nothing in the rule extends the list by implication.
Two of the eight modifications in ARM 18.8.1502(2) create obligations that land before any question of coverage is reached, and both are administrative rather than financial.
The first is registration timing. ARM 18.8.1502(2)(c) provides that with respect to the federal identification-report requirement, “an intrastate motor carrier must complete a ‘Motor Carrier Identification Report’ (form MCS-150) at the following times: (i) before the carrier begins operation; and (ii) every 24 months thereafter”. The phrase “before the carrier begins operation” is the operative one. It is not a filing that follows the first load; it precedes it.
The second is marking. ARM 18.8.1502(2)(d) has the department assign a United States Department of Transportation number to each intrastate motor carrier, and requires that the number and the carrier’s name or trade name be marked on each self-propelled commercial motor vehicle, in the same manner as a federally issued number, “except: (i) The motor carrier is required to mark each vehicle subject to these regulations with the assigned ‘USDOT’ number immediately followed by the state abbreviation ‘MT.’”
For a light combination that marking rule has a wrinkle the text does not address: it runs to the self-propelled unit. A trailer is not a self-propelled commercial motor vehicle, so the number goes on the truck. That is a small thing until a fleet runs one power unit against several trailers, at which point the marked object and the rated combination are different objects, and only one of them is what a roadside officer reads.
Neither obligation is priced by an underwriter directly. Both are read, because a carrier that began operating before completing the identification report has a compliance history that starts with a gap, and a gap is a fact about the account rather than a fact about the truck.
Send the power unit rating, the heaviest trailer rating, the radius distribution, and the cargo values you actually haul. In a state that writes no cargo floor and no carrier-specific liability floor, those four answers do more work than they would anywhere else.
The most interesting modification in the Montana rule is one an operator in this weight class is likely to read and then discover does not apply to them. ARM 18.8.1502(2)(e) provides that the adopted driver-qualification part “is subject to the age and physical qualification provisions of ARM 23.3.505 and 23.3.506 for those individuals operating under a type 2 commercial driver’s license and not engaged in ‘interstate commerce’”.
Those two rules are a genuine, Montana-drafted alternative. ARM 23.3.505(1) sets eligibility at 18 years of age, adds a cargo-placement and securement competency requirement, and requires the driver to certify “that he/she operates solely in intrastate activities and that he/she is not subject to” the federal driver-qualification part. ARM 23.3.505(2)(a) then disqualifies a person with “less than 12 months licensed driving experience”. ARM 23.3.506 is a full physical-qualification standard written by Montana, running through limb loss and impairment, insulin-treated diabetes, cardiovascular and respiratory conditions, epilepsy, and a distant visual acuity requirement of at least 20/40 in each eye.
The gate on all of it is the words “type 2 commercial driver’s license”. Montana defines that term in the same subchapter. ARM 23.3.502(5) provides that there are two types: “(a) ‘Type I’ allows the operation of a commercial motor vehicle for interstate commerce. (b) ‘Type II’ allows the operation of a commercial motor vehicle within the state of Montana.” And ARM 23.3.502(7) defines the covered vehicle for that subchapter as a vehicle or combination at 26,001 pounds or more, a school bus, a bus capable of hauling more than 15 passengers, or a placarded hazardous materials vehicle.
Put those together and the consequence is specific. A driver operating a light combination below that weight, on an ordinary Montana class D license, is not operating under a type 2 endorsement — so ARM 18.8.1502(2)(e) does not reach them, and Montana’s own age and physical qualification standard is not the one they answer to. What they answer to is the federal driver-qualification part as adopted at the April 25, 2024 edition, unsubstituted.
That sharpens the disjunction described above rather than softening it. On the paragraph (2)(a) reading, a for-hire carrier at any weight is inside the adopted safety parts; and the one place Montana wrote a lighter, home-grown alternative is a place a light combination cannot get to. The operator is left holding the borrowed standard without access to the local one — which is an argument for keeping the driver file complete rather than for thinning it.
None of this binds an insurer in either direction. Montana setting an 18-year floor for its own endorsement class is a licensing fact; youthful-operator loadings, minimum-experience conditions and named-driver restrictions are underwriting facts, and they are set against loss experience.
Montana’s economic regulation of motor carriers sits in a different title, under a different body, and it does not reach irregular-route freight for hire. MCA 69-12-301 divides motor carriers into three classes: “(a) Class A motor carriers; (b) Class D motor carriers; and (c) Class E motor carriers.”
The definitions are narrow and they are quoted here in full because their narrowness is the whole answer. Class A covers “all motor carriers operating between fixed termini or over a regular route and under regular rates or charges, based upon either station-to-station rates or upon a mileage rate or scale.” Class D covers “all motor carriers operating motor vehicles transporting garbage.” Class E covers “all transportation network carriers.”
A carrier that goes where the load is, at a rate negotiated per load, is not operating between fixed termini or over a regular route under regular rates. It is not hauling garbage and it is not a transportation network carrier. There is no residual class for it to fall into, and the lettering itself carries the history: the section names classes A, D and E and skips B and C, which is the visible trace of a classification that was cut back rather than rewritten.
The chapter’s scope section confirms the shape rather than complicating it. MCA 69-12-102 lists what the chapter does not affect, and the list is populated by school buses, employee transportation by highway, logging and mining employers, household goods and garbage in very small communities, newspapers and periodicals, junk-vehicle haulage, ambulances, commuter carpools, municipal and district transit systems, armored vehicles carrying valuables, government household goods and garbage contracts, nonprofit passenger transportation, larger passenger vehicles holding a federal identification number, contracted employee shuttles, and small-group transportation to outdoor recreation sites. Fourteen items, and general property freight for hire is not among the things being exempted because it was never among the things being reached.
So the answer for an intrastate general-freight operator is that Montana requires no operating authority from this chapter — not by an exemption written for them, but because the classification never described them. That is a stronger answer than an exemption, and it is also a more fragile one, since a classification can be widened by amendment without anyone repealing an exemption.
Montana’s treatment of financial responsibility for intrastate property carriage is unusual, and it is worth being exact about, because the exactness is what keeps a reader from taking away a number that is not a carrier requirement.
ARM 18.8.1502(2)(b) provides, in full: “49 CFR part 387, subpart A, 387.7 and 387.9 apply to for-hire motor carriers operating in interstate or foreign commerce and motor carriers transporting hazardous material. Section 61-6-103, MCA, establishes the minimum level of financial responsibility for for-hire motor carriers transporting nonhazardous material intrastate.”
The first sentence confines the adopted federal financial-responsibility sections to interstate and foreign commerce and to hazardous materials. The second sends everyone else — a nonhazardous, intrastate, for-hire property carrier — to a Montana statute. So the question becomes what that statute is, and the answer is that it is not a motor carrier statute at all.
MCA 61-6-103 is captioned “Motor vehicle liability policy minimum limits — other requirements”, sits in the chapter on responsibility of vehicle users and owners, and was read here in full. Every one of its twelve subsections speaks to what “a motor vehicle liability policy” must contain, when the insurer’s liability attaches, what may and may not be endorsed onto it, and when it may be canceled or repriced. There is no carrier element in it, no for-hire element, no compensation element and no weight element. It binds a registered private car exactly as it binds a truck. This page therefore does not present its limits as a motor carrier requirement, because they are not one — what the safety rule does is decline to raise the bar for carriers, not create a carrier-specific bar.
The consequence for cargo is the part that matters commercially, and Montana states it out loud. MCA 61-6-103(4) provides that “A motor vehicle liability policy need not insure any liability under any workers’ compensation law or any liability on account of bodily injury to or death of an employee of the insured … or any liability for damage to property owned by, rented to, in charge of, or transported by the insured.” The closing words are the point. The policy standard Montana routes its intrastate property carriers to is expressly permitted to exclude the freight.
Read against the operating reality of this class, that is where the exposure actually sits. A single deck of machine components, or of replacement parts bought at a premium because a line has gone down, is worth more than the combination carrying it — and the state has neither required cargo coverage nor required a filing that would prove any exists. Motor truck cargo is therefore contractual in Montana rather than regulatory: the limit is set by the customer’s contract and by the most valuable load the operation actually carries, with no state schedule beneath either.
Montana modifies the adopted hours-of-service part in exactly two places, and both are agricultural. Neither reaches a general-freight for-hire operator, which is itself the finding.
ARM 18.8.1502(2)(f) provides that for the purpose of the federal agricultural-commodity exclusion, “the planting and harvesting seasons during which transportation of agricultural commodities or farm supplies for agricultural purposes is conducted shall be deemed to run from January 1 through December 31 of each year.” A seasonal window declared to be the entire calendar is a season in name only, and it is worth naming because it is the kind of provision an operator hauling occasional farm supplies could be told about second-hand and misapply to general freight.
ARM 18.8.1502(2)(g) attaches a record-keeping condition to that relief: a person exempted from the driving-time limits under the agricultural exclusion “must keep a daily record of the number of hours worked”, in a format the record keeper may choose so long as it allows entry of hours worked by calendar day, retained for six months from the initial entry date, with payroll records or time sheets usable if updated daily.
The full modification list at ARM 18.8.1502(2) runs (a) through (h) and was read end to end for this page. Item (a) renames the intrastate safety investigation. Items (c) and (d) are the identification and marking provisions described above. Item (e) is the type 2 driver-qualification substitution. Items (f) and (g) are the two agricultural provisions. Item (h) requires a driver’s presence and participation for a Commercial Vehicle Safety Alliance Level I, II, III or V inspection. Item (b) is the financial-responsibility routing. None of the eight touches the short-haul radius provisions in the adopted hours part, so those apply to Montana intrastate carriage as adopted at the April 25, 2024 edition.
For a light combination running same-day work inside the state, that matters practically rather than academically. The short-haul relief is the difference between a duty day recorded one way and a duty day recorded another, and an operator who assumes Montana has widened it will be recording against a rule the state never changed.
Price on this class is not read off a table and cannot be quoted from one. What follows is not a rate; it is the set of things an underwriter settles before producing one, and in Montana several of them are unusually consequential because the state supplies so little.
The first is which reading of MCA 61-10-154(2) the account is being priced against. An operation treated as a covered carrier under paragraph (2)(a) is an operation with a full adopted safety file, an identification report completed before operations began, and a marked power unit. An operation treated as outside paragraph (2)(c) is a lighter compliance posture and a harder one to defend after a loss. The honest answer is usually that the operator should be able to satisfy the first reading regardless of which reading a court would take.
The second is cargo, and Montana pushes it forward rather than backward. Because the state requires no cargo filing and routes carriers to a policy standard expressly permitted to exclude transported property, the limit is set entirely by what the shipper agreement demands and what the heaviest actual load is worth. A limit set against an average load value fails against exactly the shipment that generates the claim, and there is no state floor underneath it to catch the difference.
The third is radius and the state line, which in Montana are the same question asked twice. The safety adoption reaches intrastate operation by the state’s own extension; the adopted financial-responsibility sections are confined by ARM 18.8.1502(2)(b) to interstate and foreign commerce and to hazardous material. A dispatch that crosses into Idaho, Wyoming, North Dakota or South Dakota changes which sentence the operator is standing under. Distances in this state make that a live question on more loads than it would be elsewhere.
The fourth is the equipment as assembled. A gross combination weight rating describes a design and not a load, and the combination itself is assembled by its owner rather than built by a manufacturer — so the trailer hooked up in a given week is what decides which side of 26,001 pounds the operation is sitting on. It moves when the fleet buys, not when anybody files anything.
The fifth is paperwork the state never sees. Operating under a lease rather than on the operator’s own registration changes who answers first after a loss. Being added to a shipper’s program as an insured, carrying language that makes one policy respond ahead of every other without contribution, or having already conceded a recovery right at onboarding each reprices an account while every specification of the equipment stays exactly where it was. In a state that sets no floor of its own, those documents are the floor. The lines they usually name are described on the general freight and first-year authority pages.
The absences are as load-bearing as the text, and they were checked rather than assumed. No Montana instrument read for this page names the work, defines it, classes it or fixes a threshold against it. The vocabulary this trade uses for itself is nowhere in the law that reaches it, and Montana arrives at the work the way it arrives at every carrier: a compensation description in one paragraph, a weight description in another.
Montana requires no cargo insurance filing of a property carrier. The chapter that would carry one was enumerated part by part — general provisions, the role of the commission, classification and certificates, requirements for motor carriers, and ratemaking requirements, with the carrier-agreements part repealed — and the only two insurance-captioned sections in the whole of it sit inside the transportation-network-carrier block and reach passengers rather than freight.
Montana states no motor-carrier-specific financial responsibility amount for intrastate nonhazardous property. It points instead at the general policy statute described above, which is why no figure appears anywhere on this page as a Montana carrier requirement.
And Montana does not resolve its own coverage question. The statute says both things, the rule repeats both things, and thirty-eight amendments to that rule since 1974 — the most recent effective June 22, 2024 — have left the disjunction where it was. An operator cannot look this up and read an answer off, and the practical response is to build the file that satisfies the broader reading and to price the account as though a court might take it.
The state minimum is a licensing threshold. The program an operator actually needs is built from these lines:
We write hot shot and expedited hauling as a named class rather than as an exception to general trucking, and we read each account against the weight and authority regime of the state it operates in. For a Montana operator that means starting from the rating of the power unit and the trailer separately rather than from the combination, sizing cargo against the heaviest load actually carried rather than the average one, and treating the state line as a rating fact because a single crossing can change which driver file the operation owes.
If the operation also runs freight under separate authority, the Montana trucking insurance page covers the state’s broader motor carrier picture, and the hot shot trucking insurance page covers the class mechanics that apply wherever the operator runs.
The statute says two different things and does not reconcile them. MCA 61-10-154(2)(c) reaches intrastate vehicles and combinations at 26,001 pounds or more, while MCA 61-10-154(2)(a), in the same disjunctive list, reaches “any for-hire motor carrier or any private motor carrier” with no weight attached at all. ARM 18.8.1502(1) hooks to “Any commercial motor vehicle or motor carrier subject to regulation … under 61-10-154”, which repeats the split rather than deciding it. Read on August 31, 2026.
No. MCA 69-12-301 divides motor carriers into Class A (fixed termini or regular route under regular rates), Class D (garbage) and Class E (transportation network carriers). Irregular-route freight for hire matches none of them, and MCA 69-12-102, the chapter’s scope and exemption section, was read in full and contains no property-freight certificate requirement. The result is not an exemption written for this work; it is a classification that never described it.
Montana sets no motor-carrier-specific amount for this class. ARM 18.8.1502(2)(b) confines the adopted federal financial-responsibility sections to interstate and foreign commerce and to hazardous material, then states that MCA 61-6-103 establishes the minimum for intrastate nonhazardous for-hire carriage. MCA 61-6-103 is Montana’s general motor vehicle liability policy statute, with no carrier, compensation or weight element in any of its twelve subsections — so its limits are an ordinary-vehicle requirement, not a carrier requirement, and are not published here as one.
No. No cargo filing form exists for a Montana property carrier, and the motor carrier chapter contains no cargo provision. Montana goes further: MCA 61-6-103(4) provides that a motor vehicle liability policy “need not insure … any liability for damage to property owned by, rented to, in charge of, or transported by the insured.” The policy standard the state routes intrastate property carriers to is expressly permitted to exclude the freight, which puts the cargo limit entirely into the shipper agreement.
Montana’s own 18-year floor sits in ARM 23.3.505(1)(a), and ARM 18.8.1502(2)(e) makes that rule the applicable age and physical qualification standard only “for those individuals operating under a type 2 commercial driver’s license and not engaged in interstate commerce.” ARM 23.3.502 confines the type 2 endorsement to intrastate operation of a commercial motor vehicle as that subchapter defines it, at 26,001 pounds and above plus named passenger and placarded classes — so a driver of a lighter combination is outside the substitution and keeps the adopted federal driver-qualification part.
ARM 18.8.1502(1) adopts an enumerated list of parts “as updated through April 25, 2024.” That is a fixed incorporation rather than a rolling one, so a later federal amendment does not reach an intrastate Montana carrier through this rule by itself. The rule containing that date was itself last amended effective June 22, 2024 on its own published history, which means the date the rule points at and the date the rule took effect are two separate things to check.
Not for general freight. The full modification list at ARM 18.8.1502(2)(a) through (h) was read end to end and touches hours in only two places, both agricultural: (2)(f) deems the planting and harvesting seasons to run from January 1 through December 31 of each year, and (2)(g) requires a person using that exclusion to keep a daily record of hours worked, retained six months. Nothing in the list alters the short-haul radius provisions, which apply as adopted at the April 25, 2024 edition.
Two administrative steps sit ahead of operations. ARM 18.8.1502(2)(c) requires an intrastate motor carrier to complete a Motor Carrier Identification Report “before the carrier begins operation” and every 24 months thereafter. ARM 18.8.1502(2)(d) has the department assign a USDOT number to each intrastate carrier and requires each self-propelled commercial motor vehicle to be marked with that number “immediately followed by the state abbreviation ‘MT.’” The marking runs to the power unit, not the trailer.
Montana has no schedule to read this off, and a figure produced sight unseen would be fabricated. Price follows which reading of MCA 61-10-154(2) the file is able to defend; the rating the trailer in service produces; what the most valuable load carried is worth, given that Montana requires no cargo filing and permits the exclusion outright; the spread of dispatch distances and whether any leave the state; driver ages and tenure; and everything a customer contract says about insured status, order of response and surrendered recovery rights.
Every figure on this page was read at the source below on August 31, 2026, with the effective date of the version read. Treat each as current as of that date rather than as permanent.
Send the power unit and trailer ratings separately, the radius distribution, and whether any dispatch crosses a state line. We will size the program against the work the trucks actually do rather than against a statutory floor.
