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Do leased-on owner-operator trucks count toward my UCR fleet count?

It depends on whose name the truck is registered under. Trucks where the motor carrier is the registered owner count toward the carrier's UCR fleet. Trucks where the owner-operator is the registered owner (typical leased-on arrangements where the carrier provides only operating authority) do not count toward the carrier's fleet — they count toward the owner-operator's separate UCR filing. Each registered owner files UCR for their own fleet.

The UCR fleet-count definition under 49 USC §14504a is based on registered ownership. A motor carrier operating its own equipment counts those trucks in its UCR fleet. An owner-operator leasing on to a motor carrier (where the owner-operator owns the truck, the truck is registered in the owner-operator's name, and the motor carrier provides operating authority and load assignment) does not count those trucks in the motor carrier's UCR fleet — the owner-operator files UCR separately on their own fleet.

For typical leased-on arrangements, this means the motor carrier's UCR fleet might be smaller than the carrier's practical operational fleet. A carrier with 5 owned trucks plus 15 leased-on owner-operators files UCR as Tier 2 (3-5 vehicles) based on the 5 owned trucks. The 15 leased-on owner-operators each file their own UCR (typically Tier 1 if 0-2 vehicles each).

For motor carriers that own equipment they lease to owner-operators (the inverse arrangement — carrier owns, operator drives), the carrier counts those trucks in the carrier's UCR fleet because the carrier remains the registered owner. The owner-operator in this arrangement is more like an employee for UCR purposes.

For carriers with mixed structures (some owned, some leased, some leased-on), the rule is consistent: each registered owner files UCR for their own registered fleet. A carrier should track its UCR fleet count based on actual registered ownership, not operational use. Misreporting in either direction creates audit risk.

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