Every week someone asks it: “Do I need a CDL to run hotshot?” The honest answer is “check two stickers.” The federal test is short, and once you see it written plainly you can answer it yourself in the parking lot.
01The Class A test
What the rule says
“Combination vehicle (Group A)—Any combination of vehicles with a gross combination weight rating (GCWR) of 11,794 kilograms or more (26,001 pounds or more) provided the GVWR of the vehicle(s) being towed is in excess of 4,536 kilograms (10,000 pounds).”
49 CFR 383.91(a)(1)
What it means for you
Two boxes, both have to be ticked for Class A:
- Truck rating + trailer rating = 26,001 lb or more.
- Trailer rating alone is more than 10,000 lb.
“Rating” is the GVWR on the manufacturer’s sticker, usually on the driver’s door jamb and the trailer tongue. It’s not your scale ticket.
| Truck GVWR | Trailer GVWR | Combined | CDL? |
| 14,000 lb dually | 24,000 lb gooseneck | 38,000 lb | Class A (both boxes ticked) |
| 14,000 lb dually | 10,000 lb trailer | 24,000 lb | No (under 26,001 and trailer not over 10,000) |
| 16,500 lb truck | 9,990 lb trailer | 26,490 lb | No (over 26,001, but trailer not over 10,000) |
Check your setup
Combined rating: 38,000 lb
Class A CDL required
Both boxes ticked: 26,001+ combined and a trailer over 10,000.
That third row surprises people: the combination is heavy enough, but the trailer rating isn’t over 10,000 lb, so it isn’t Group A. (A single truck rated 26,001 lb or more would be Group B, a different license.)
02No CDL still means you’re a commercial vehicle
What the rule says
“Commercial motor vehicle means any self-propelled or towed motor vehicle used on a highway in interstate commerce to transport passengers or property when the vehicle— (1) Has a gross vehicle weight rating or gross combination weight rating, or gross vehicle weight or gross combination weight, of 4,536 kg (10,001 pounds) or more, whichever is greater.”
49 CFR 390.5
What it means for you
The CDL line is 26,001. The commercial vehicle line is 10,001. Almost every hotshot setup is over it, so even without a CDL you’re still under the federal safety rules: a USDOT number, hours of service, inspections and a medical card.
What the rule says
“A person subject to this part must not operate a commercial motor vehicle unless he or she is medically certified as physically qualified to do so, and … when on-duty has on his or her person the original, or a copy, of a current medical examiner’s certificate.”
49 CFR 391.41(a)(1)(i)
What it means for you
Get a DOT physical and keep the card on you. “It’s at home” is still a violation.
03Insurance
What the rule says
“For-hire (In interstate or foreign commerce, with a gross vehicle weight rating of 10,001 or more pounds) Property (nonhazardous) $750,000.”
49 CFR 387.9, Table 1
What it means for you
Hauling other people’s freight across state lines at 10,001 lb or more? $750,000 minimum public liability. Many brokers ask for $1,000,000 plus cargo coverage, so price that in before you buy the truck.
04A break for local non-CDL hotshots
What the rule says
“The driver operates a property-carrying commercial motor vehicle for which a commercial driver’s license is not required … within a 150 air-mile radius of the location where the driver reports to and is released from work … returns to the normal work reporting location at the end of each duty tour; … does not drive: (A) After the 14th hour after coming on duty on 5 days of any period of 7 consecutive days; and (B) After the 16th hour after coming on duty on 2 days of any period of 7 consecutive days.”
49 CFR 395.1(e)(2)
What it means for you
Run non-CDL, stay within 150 air-miles and come home every night, and you skip the ELD and get two 16-hour days a week instead of the usual 14. It’s built for local work, not long hauls.
05So, CDL or not?
Non-CDL keeps the barrier to entry low, but the 26,000-lb ceiling limits how much you can haul, and heavy loads often pay best. Class A opens bigger trailers and more of the load board. Either way, check your state rules too if you run only inside one state, because intrastate rules can differ.
Bottom line
Read the two stickers. Combined 26,001 or more and a trailer over 10,000 means Class A. Under that, you still need a USDOT number, a med card, hours of service and insurance.
Running hotshot and want loads that fit your exact setup? See our hotshot dispatch or call 434-394-0605.
Sources
- 49 CFR 383.91: Commercial motor vehicle groups (eCFR)
- 49 CFR 390.5: Definitions, “commercial motor vehicle” (eCFR)
- 49 CFR 387.9: Financial responsibility, minimum levels (eCFR)
- 49 CFR 391.41: Physical qualifications for drivers (eCFR)
- 49 CFR 395.1(e)(2): Non-CDL short-haul exception (eCFR)
Rules quoted from the official text as of 24 October 2026. Rules change: check the source before you rely on it.