UCR Requirements for Leased vs Owned Vehicles

Nov. 29, 2025, 10 a.m.
The Unified Carrier Registration (UCR) program applies to motor carriers, brokers, freight forwarders, and leasing companies operating across state lines. One of the most common questions carriers have is whether UCR requirements differ for leased and owned vehicles. The short answer: both types count, but how they are reported can vary based on the lease arrangement and who holds the operating authority. Below is a complete breakdown to help you stay compliant.
UCR Requirements for Leased and Owned Vehicles

1. Does UCR Apply to Both Leased and Owned Vehicles?

Yes. The UCR fee is based on the total number of commercial motor vehicles (CMVs) a carrier operates interstate—this includes:

  • Owned vehicles

  • Long-term leased vehicles

  • Short-term leased vehicles (if operating under your authority)

If the vehicle operates using your USDOT number, it must be included in your UCR fleet count.

2. Who Is Responsible for UCR Fees in a Lease?

Responsibility depends entirely on whose operating authority is being used.

 If YOU operate the vehicle under YOUR authority

You must include the vehicle—whether owned or leased—in your UCR fleet count.

 If a LEASED-ON OWNER-OPERATOR runs under the MOTOR CARRIER’S authority

The motor carrier (not the owner-operator) is responsible for the UCR.

 If the owner-operator has their own authority

They must file and pay UCR independently.

Key rule:

The entity whose USDOT number is on the side of the vehicle (for interstate operations) is the one responsible for UCR.

3. Long-Term vs. Short-Term Leases Under UCR

A. Long-Term Leases (30+ days)

Vehicles leased long-term are effectively treated like owned vehicles under UCR.

  • Counted in the motor carrier’s fleet

  • Included in annual UCR fee calculation

B. Short-Term Leases (Less than 30 days)

Even if the vehicle is leased for only a day or week, you must include it if:

  • It operates under your authority, and

  • You have control of it during interstate operations

4. How to Count Vehicles for UCR Fleet Size

UCR only counts CMVs used in interstate commerce that meet FMCSA’s definition:

  • 10,001+ lbs GVW/GVWR, or

  • Designed to transport 9+ passengers for compensation, or

  • Designed to transport 16+ passengers not for compensation, or

  • Transporting hazardous materials requiring placards

You report the highest number of vehicles operated at one time during the previous 12 months (owned + leased).

5. Do Leased Vehicles Need to Be Listed Separately?

No. UCR does not require separating leased vs. owned vehicles.

You simply report:

  • The total number of CMVs operated

  • Under the motor carrier’s authority

  • During the previous year

No VIN numbers or vehicle-specific data are required.

6. What About Trailer Counts?

Trailers are not counted in UCR registration.
Only power units (tractors, straight trucks, buses, etc.) are counted.

7. Common Mistakes Carriers Make

Here are the top compliance issues:

 Counting only owned trucks

UCR requires counting all CMVs under your authority, including leased ones.

 Owner-operators thinking they must pay UCR when leased-on

They do not pay UCR if operating under a motor carrier’s DOT number.

 Not including temporary lease vehicles

Even short-term leased CMVs used interstate count.

 Assuming trailers increase UCR fees

Only power units matter.

8. Summary: What You Must Remember

  • UCR applies to both leased and owned vehicles.

  • Vehicles count if they operate under your DOT authority.

  • Long-term and short-term leased vehicles must be included.

  • Trailers are excluded.

  • Owner-operators leased to a carrier do not pay UCR separately.

  • The number of CMVs you operate determines your UCR fee bracket.