Do I need passenger authority for charter, shuttle, or limo work?
Yes for any interstate transportation of passengers for compensation. The 49 CFR §365 passenger-authority requirement (OP-1(P) application) applies to charter buses, shuttle services, limo services, and any other for-compensation passenger-carrying operation that crosses state lines. Intrastate passenger work is regulated by state authority instead. Passenger BIPD insurance under §387.33 is significantly higher than property insurance.
The §365 framework requires FMCSA operating authority for any "person engaged in interstate commerce as a passenger carrier." The trigger is interstate operation plus carriage for compensation; both conditions must be met. A purely intrastate limo service that never crosses state lines operates under state authority only. A limo service that occasionally crosses state lines for airport runs needs federal passenger MC authority.
The OP-1(P) application is the passenger-specific entry point. It requires the same applicant information as OP-1, plus passenger-specific insurance minimums under §387.33: $1.5 million BIPD for vehicles seating 16 or fewer passengers, $5 million BIPD for vehicles seating 17 or more. The higher minimums reflect the higher claim exposure on passenger-carrying operations.
New-entrant passenger carriers face the §385.305 new-entrant audit just like new-entrant property carriers, but the audit checks passenger-specific items: §391 driver qualifications including passenger-endorsement CDL where applicable, §392 driving-of-vehicles requirements, §393 vehicle-equipment requirements specific to passenger configurations, and §396 inspection-and-maintenance documentation. The audit happens within the first 12 months of operation.
For mixed property/passenger operations, the carrier files separate OP-1 (property) and OP-1(P) (passenger) applications and operates under separate MC numbers, both under the same USDOT. A single BOC-3 process-agent designation typically covers both authorities since BOC-3 is keyed to the carrier entity, not to specific MC numbers. BMC-91 financial-responsibility filings are separate per authority.