FMCSA Compliance for Amazon Relay Carriers: What Amazon Requires and What FMCSA Checks
Amazon Relay has been one of the largest sources of new motor carriers in the past five years. Many of those new carriers came in believing that Amazon's onboarding process is the compliance program. It is not. Amazon's requirements are a layer on top of FMCSA compliance -- and FMCSA still expects every Amazon Relay carrier to have a complete safety management program. This guide covers both layers and how to manage them together.
Amazon Relay's basic requirements
Amazon Relay's carrier onboarding typically requires:
- Active USDOT and MC numbers
- $1,000,000 auto liability and $100,000 cargo insurance, with Amazon listed as a certificate holder
- ELD compliance with logs reviewable on demand
- Drug and alcohol testing program
- Clean recent inspection record (no recent out-of-service orders)
- Amazon-specific onboarding portal: W-9, banking information, equipment list, driver list
- Compliance with Amazon's Service Level Agreement (on-time pickup and delivery thresholds)
Amazon does not file your compliance documents with FMCSA. Amazon checks that your insurance is bound and your authority is active. Amazon does not verify your DQ files, your written policies, your accident register, or your maintenance program. FMCSA does.
What FMCSA still requires
An Amazon Relay carrier is a motor carrier under 49 CFR Part 390, and the New Entrant Safety Audit will occur in the first 12 months. The audit reviews:
Operating authority and registrations
USDOT, MC, BOC-3, UCR, MCS-150. Amazon checks USDOT and MC; FMCSA checks all five.
Driver qualification files
Every Amazon Relay driver needs a Part 391 DQ file: application with 10 years of work history, MVR, medical certificate, road test, prior employer verification, annual review.
Drug and alcohol program
DOT consortium enrollment, written policy, driver acknowledgments, Clearinghouse registration, pre-employment tests, random pool, post-accident protocol.
Hours of service
ELD records for the past six months. Amazon's logs alone are not enough -- the ELD must be on the FMCSA registered device list.
Vehicle maintenance
Written maintenance policy, annual inspection records, daily DVIRs, repair invoices.
Insurance filings
BMC-91 or BMC-91X on file in FMCSA L&I. Amazon checks the COI; FMCSA checks the federal filing.
Accident register
Required under 390.15 even with zero accidents.
Where Amazon and FMCSA align
- Both require active operating authority
- Both require insurance (Amazon requires more than FMCSA minimum)
- Both expect ELD compliance
- Both expect a drug and alcohol testing program for CDL drivers
Where Amazon and FMCSA diverge
- Amazon does not verify DQ files; FMCSA reviews them in detail
- Amazon does not require written maintenance, accident, or HOS policies; FMCSA expects all of them
- Amazon does not verify Clearinghouse registration; FMCSA does
- Amazon does not verify BOC-3 filing; FMCSA requires it
- Amazon's SLA monitors on-time performance; FMCSA monitors safety compliance
Common Amazon Relay carrier audit findings
DQ files missing entirely
Carrier built the Amazon-side driver list but never assembled a Part 391 DQ file for each driver.
Written policies missing
No written drug policy, no written maintenance policy, no written HOS policy.
Clearinghouse not registered
Carrier enrolled in a consortium but never registered as an employer in the FMCSA Clearinghouse.
BOC-3 not filed
Carrier assumed Amazon onboarding included process agent designation.
Accident register missing
Even Amazon Relay carriers with zero accidents need the register document.
ELD not on registered device list
Carrier used a logbook app that was not FMCSA-registered.
What to do in your first 30 days as an Amazon Relay carrier
- Complete Amazon onboarding -- get loads moving
- File BOC-3, register for UCR, file MCS-150 if not done at authority application
- Bind $1M liability + $100K cargo and confirm BMC-91X is filed in L&I
- Enroll in a DOT drug consortium and register as an employer in the FMCSA Clearinghouse
- Build a Part 391 DQ file for every driver -- not just the Amazon driver list
- Adopt written policies for drug and alcohol, HOS, maintenance, and accident response
- Install a registered ELD if not already in place
- Open accident register and maintenance log
Why this matters for Amazon Relay specifically
Amazon will deactivate a carrier if the carrier's authority goes inactive, insurance lapses, or the carrier accumulates inspection violations that exceed Amazon's thresholds. The same compliance failures that cause an FMCSA audit failure also cause Amazon deactivation. The reverse is also true: an Amazon-deactivated carrier is often a sign that an FMCSA audit will not go well.