A construction contractor in San Antonio transports its 40 workers to the job site every morning in three 15-passenger vans. They’ve been doing it for three years. Never had a problem on the road.
What they didn’t know until recently is that those vans have been under FMCSA regulation from day one. And the requirements they need to meet go beyond what any of their drivers assumed.
Why 15-passenger vans have special regulatory treatment
The FMCSA has a specific category for vehicles designed to transport between 9 and 15 passengers (plus the driver) when used for business-related transport. These vehicles have a documented statistical history of multi-fatality accidents that led to stricter federal oversight.
If the van transports 15 passengers or fewer and the trip is work-related — carrying employees to a job site, transporting subcontracted workers — the operation is subject to DOT regulation.
If the vehicle’s rated capacity is 16 or more passengers including the driver, the driver needs a CDL with passenger endorsement (P). Many vans marketed as “15-passenger” have a technical capacity for 16 or more, which triggers that requirement.
What needs to be in order
For the company:
USDOT number — any company operating commercial vehicles in interstate commerce or transporting passengers for commercial purposes needs a DOT number. For companies transporting workers, the threshold applies even if it’s “internal” company transport.
Drug and alcohol testing program — all DOT-regulated companies with commercial drivers must maintain an active program: pre-employment, random, post-accident, and reasonable suspicion.
Liability insurance for passenger transport — minimums are significantly higher than for commercial vehicles without passengers. For vehicles carrying 9 to 15 passengers: $1.5 million. For 16 or more: $5 million.
Per vehicle:
Annual DOT inspection — required for all FMCSA-regulated vehicles. Inspection records must be kept for a minimum of 14 months.
Commercial vehicle registration — annual per state.
Commercial insurance — at the specific minimums for passenger transport.
Per driver:
CDL with P endorsement — if the vehicle has rated capacity for 16 or more passengers including the driver. Many market-standard 15-passenger vans (Ford Transit, Chevrolet Express) have a technical capacity of 16, which triggers this requirement.
DOT medical certificate — required for CDL holders. Every two years for most drivers.
Motor vehicle record (MVR) review — the company must review each driver’s driving history before hiring and annually thereafter.
Safety training — some states and municipalities require specific training for drivers of worker transport vehicles.
The San Antonio contractor’s situation
When I walked them through all of this, the immediate reaction was: “Do we need CDL to drive the vans?”
It depends on the exact model and the officially rated capacity. But yes — some of their drivers probably needed CDL-P and didn’t have it.
They started getting compliant in order: first confirmed their DOT number, then reviewed insurance coverage, then checked each driver’s situation. The process took weeks but they did it systematically because they knew exactly what they needed per person and per vehicle.
In GoExpirely they created one entity type for the vans and one for the drivers. Each van with its annual inspection, registration, and insurance. Each driver with their license type, medical card if applicable, and annual MVR check.
Renewals no longer depend on someone remembering. The system alerts 30 days out.
What changes when DOT compliance runs on a system
The vans are on the road every morning. Everyone knows the route. What nobody tracked is whether the drivers have current DOT medical certificates — because the previous employer handled it, and this is a new operation.
When compliance runs on a system: every driver’s medical card and license is tracked from day one. The 90-day alert comes out before anyone has to think about scheduling a DOT physical. The van leaves every morning with compliant drivers.
For companies in Texas and Florida
Crew transport is especially common in Texas (construction, oil field, agriculture) and Florida (construction, agriculture, hospitality). Both states are among the highest for commercial vehicle roadside inspections in the country.
If your company transports workers in vans and you haven’t verified whether you fall under DOT regulation, that’s the first step. The second is making sure your vehicles and drivers stay current.
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Written by Julio Alvarez — builder of GoExpirely and other software tools for operators and small businesses in the US.