Is it Possible to Do Hotshot Trucking Without a CDL?

What is a CDL (Commercial Driver's License)?

A CDL (Commercial Driver’s License) is the official license required in the U.S. to operate certain types of commercial vehicles. This credential is mandatory for drivers who operate:

·       Vehicles that exceed specific weight thresholds

·       Passenger vehicles designed to carry 16 or more people

·       Vehicles transporting hazardous materials

When it comes to hotshot trucking, the rules aren’t always straightforward. Since most hotshot loads are hauled with a pickup truck and trailer combination, a CDL may not always be required. However, whether you need one or not depends heavily on the weight of the load and the combined rating of the truck and trailer under federal and state regulations.

Who is Required to Have a CDL in the US?

According to the Federal Motor Carrier Safety Administration (FMCSA), a CDL is required in the following cases:

·       When the GVWR (Gross Vehicle Weight Rating) or GCWR (Gross Combined Weight Rating) of the vehicle combination is 26,001 pounds (11,793 kg) or higher

·       For drivers hauling hazardous materials

·       For commercial passenger transport

This means that in hotshot trucking, whether you need a CDL ultimately depends on the GVWR and GCWR ratings of your truck-and-trailer setup.

Weight and legal limits in hotshot trucking (what are GVWR and GCWR?)

·       GVWR (Gross Vehicle Weight Rating): The vehicle’s maximum carrying capacity plus its curb weight

·       GCWR (Gross Combined Weight Rating): The total maximum weight the vehicle and its attached trailer can safely carry together

  Sample Calculation Table:

Situations where a CDL is not required

·       If the GCWR is under 26,000 lbs

·       If the load being hauled is not hazardous materials

·       If you’re transporting your own goods or small loads

·       If the driver is operating within state lines (intrastate)

Important Reminder: Some states may have different rules for intrastate trucking. Always check your state’s DOT regulations before you hit the road.

Which Trailers/Loads Pose a Risk?

Some truck-and-trailer combinations may technically fall under the legal limit but still require a CDL in practice. For example:

·       If the trailer’s GVWR is higher than the truck’s GVWR

·       If the actual load weight is below the limit, but the combined GVWR ratings on the manufacturer labels exceed the threshold

Tip: DOT officers typically look at the GVWR ratings on the manufacturer’s labels, not just the actual weight being hauled.

If you plan to haul heavier loads or take on longer routes in the future, getting your CDL from the start can be more advantageous in the long run.

Advantages of driving without a CDL

·       Lower startup cost: No need to pay for CDL training or exams.

·       Faster entry: Less paperwork means you can get started more quickly.

·       Flexibility in intrastate hauling: In some states, operating intrastate only can reduce tax and regulatory burdens.

·       Side income opportunity: Even if you don’t run full-time, you can earn extra income with smaller loads.

·       Lower operating costs: Smaller vehicles generally mean lower fuel and maintenance expenses.

Requirements For Hotshot Trucking Without a CDL

Even when operating without a CDL, there are several key compliance requirements you must pay attention to:

1.       USDOT Number: Required for interstate commercial operations and/or if the vehicle combination is ≥10,001 lbs. Some states also require it for intrastate hauling.

2.       DOT Medical Exam Card: Mandatory for interstate commercial driving with GVWR/GCWR over 10,000 lbs. Typically valid for 24 months.

3.       HOS Compliance: If you qualify for the short-haul exemption, you must keep time records; if not, you’ll need ELD/logbooks for driver hours of service.

4.       Insurance: For-hire interstate carriers must meet FMCSA’s minimum liability requirements (generally $750,000, but can vary depending on the type of cargo). Some vehicles under 10,001 lbs may only require $300,000. Insurance filings (BMC-91/91X, MCS-90, etc.) depend on your operating authority. In practice, many brokers require $1 million liability coverage plus $ 100,000 cargo coverage. 

 “Before You Start” Quick Checklist

Photograph truck & trailer GVWR labels and verify GCWR <26,001 lbs

Check USDOT registration (and operating authority/MC if required), UCR, and state-specific requirements 

Obtain and carry your DOT medical exam card

Choose your HOS compliance method (time records vs. ELD)

Verify insurance coverages (liability, cargo, physical damage) with policies and certificates.

Perform pre-trip checks: cargo securement (straps, chains, binders) and brake/light inspections

Which Vehicle/Trailer Combinations are Used?

·       Light-duty pickups (F-150, F-250, Silverado 2500)

·       Trailers with a GVWR under 10,000 lbs

·       Single-axle open flatbed trailers

Key goal: Stay under a total GCWR of 26,000 lbs without sacrificing hauling capacity.

Tip: Ensure your trailer is equipped with a brake assist system and LED signal lights — both are essential for safety and regulatory compliance.

Which Types of Loads Can be Started With?

• Small construction materials
• Fence panels, generators, palletized products
• Landscaping supplies, lawn equipment
• Light machinery

Depending on the type of load, you must always check that your transportation documents and insurance coverage are valid and sufficient.

Which Types of Insurance are Required or Recommended?

Even if you’re running hotshot loads without a CDL, it’s highly recommended to carry the following types of insurance:

• Commercial Auto Insurance
• Cargo Insurance
• Liability Insurance
• General Liability Insurance (optional, but strongly advised)

Tip: Always review your policies for the MCS-90 endorsement and BMC-91/91X filings (required with MC authority). Missing these can lead to being denied loads or even losing your operating authority.

When is Obtaining a CDL Inevitable?

A CDL becomes mandatory in the following scenarios:

• If the GCWR is 26,001 lbs or higher
• If the trailer’s GVWR is 10,001 lbs or more and the truck’s GVWR exceeds 16,001 lbs
• If you are hauling hazardous materials
• If you are operating as a driver in interstate (across state lines) commerce

Additionally, in some states, a CDL may be required even if the load itself is under the limit, as long as the vehicle’s GVWR alone exceeds 26,001 lbs. That’s why it’s always important to check with your state’s Department of Transportation (DOT) for confirmation.

Before You Start: Quick Checklist

Conclusion: Hotshot Trucking Without a CDL Is Possible — But Limited

It is possible to get started in hotshot trucking without a CDL, but you must pay close attention to load restrictions, truck-trailer compatibility, and state-specific laws. For those looking to reduce startup costs and enter the industry quickly, this can be an attractive option. However, as you take on larger loads or longer hauls over time, obtaining a CDL may become necessary.

For drivers starting hotshot trucking without a CDL, choosing the right equipment is crucial. Investing in truck-and-trailer systems that stay within legal limits while ensuring safe transport will set you up for long-term success.

This is where Tulga Fifth Wheel solutions stand out. Designed for both light and medium-duty hauling, they provide durability, compliance, and reliability. The Tulga T10 Fifth Wheel Hitch, manufactured to meet DOT and SAE standards, is an ideal choice for drivers mindful of GVWR and GCWR thresholds.

✅ Up to 14,000 lbs load capacity

✅ Certified to DOT and SAE standards

✅ Easy installation, long-lasting build

✅ Available in gooseneck or bumper pull options

If you want to make a professional start in non-CDL hotshot trucking, Tulga’s strong, safe, and easy-to-install equipment will help you hit the road with confidence.

Check out Tulga’s official web page here!