Authority & ownership
Certificate of Authority Applications
Determine whether the proposed service is covered, choose the appropriate authority, and address application and conditional-grant requirements.
Read the related answer
Shin Law Office · Passenger carrier counsel
WMATC Compliance Attorneys in Northern Virginia
Your routes are booked.
Is your authority ready?
A missed filing, an insurance termination, or a change in ownership can put your right to operate at risk. We help passenger carriers assess WMATC requirements, prepare filings, and respond when the Commission takes action.
Applications, insurance, tariffs, ongoing compliance, enforcement, and transfers. Offices in Leesburg and Fairfax.
Buses, shuttles & covered car servicesApplications & filingsEnforcement & transactions
Does your passenger business need WMATC authority?
Generally, a carrier needs WMATC authority for nonexempt passenger transportation for hire between points in the Metropolitan District. A state-line crossing is not required: some DC-only and Maryland-only trips are covered. Transportation solely within Virginia has a Compact exemption.
Start with the trip endpoints, compensation, type of service, and applicable exceptions. Shin Law Office helps connect that review to the authority and filings your business needs.
Sources: WMATC Compact, Articles I and XI–XIV · WMATC Jurisdiction FAQs
Where does the trip begin and end?The operator’s business address alone does not decide coverage.
What service are you providing?Vehicle capacity, compensation, and exemptions can change the answer.
Start with your situation
What needs attention right now?
Choose the stage of your business and the issue you are facing. The guide identifies useful records and a related answer.
Step 1 of 2
What brings you here?
Select the situation closest to yours.
This guide organizes your questions. It does not determine jurisdiction, check live carrier status, or authorize operations.
Have an order, suspension, or termination notice? Mention it when you contact the firm and keep the complete document. An approaching trip or customer commitment does not extend a Commission deadline.
From startup to enforcement
Find the issue in your own words.
Search for the filing, business change, or notice. One situation can involve several parts of WMATC compliance.
Try “conditional grant,” “change prices,” “missed annual report,” or “show cause order.”
Showing all six services.
Insurance & filings
Insurance Filings & Coverage
Review the required coverage and Commission filing, coordinate with the insurer, and address termination notices, gaps, or insurance suspensions.
Read the related answerInsurance & filings
Tariffs & Rate Filings
Align general and contract tariffs with the services offered, applicable rates, effective dates, and changes to customer agreements.
Read the related answerOperations & enforcement
Annual Reports & Ongoing Compliance
Organize annual reporting, fee payments, vehicle records, inspections, markings, and updates as the carrier’s operations change.
Read the related answerOperations & enforcement
Enforcement & Show Cause Defense
Assess the allegations, preserve operating records, prepare supported responses, and evaluate corrective action, reconsideration, or review.
Read the related answerAuthority & ownership
Transfers & Sale of Authority
Evaluate certificate transfers and changes of control, investigate the carrier’s status, and coordinate regulatory approval with the transaction.
Read the related answerTry a shorter description of the issue.
Select “All services” to broaden the results, or contact the firm to discuss the situation.
Discuss your carrierJurisdiction & exemptions
The trip matters more than the address on your business card.
A carrier based in Leesburg can provide a covered trip elsewhere in the Metropolitan District. A carrier based in DC can also offer services that require a different jurisdictional analysis. Review the actual service rather than assuming that a business address or vehicle label decides the answer.
The District includes DC; Alexandria, Falls Church, Arlington and Fairfax; the Dulles Airport portion of Loudoun County; and Montgomery and Prince George’s counties, with the subdivisions and other areas specified in the Compact.
- Identify both endpoints and any local trips added to an itinerary.
- Explain who pays, including bundled transportation services.
- Distinguish charter, regular-route, taxicab, and other service models.
- Check the exemption against the actual operation.
Sources: WMATC Compact, Articles I and XI–XIV · WMATC Jurisdiction FAQs
A Virginia-only trip has a different starting point.
The Compact excludes transportation solely within Virginia. That exemption does not eliminate Virginia operating, registration, insurance, or other applicable obligations. A trip from Virginia into DC or Maryland needs its own analysis.
Read about state-line crossingsWMATC is different from WMATA.
WMATC regulates covered passenger carriers for hire. WMATA operates Metro, and its transportation is excluded by the Compact. Federal, state, local, and airport requirements may also need review for your operation.
Understand the agency’s roleCommon route questions
Similar-looking trips can have different requirements.
These examples show where to begin. They assume passenger transportation for hire and do not resolve every service exception.
| Example | Starting point | Why it matters |
|---|---|---|
| DC to DC | Both endpoints are within the District. | A covered for-hire service can require authority even without crossing a border. |
| Montgomery County to Prince George’s County | Both endpoints are within the Maryland portion. | Maryland-only service is not the same as the Virginia-only Compact exemption. |
| Dulles to DC | The airport is within the defined District. | Generally covered for-hire transportation unless an applicable exemption changes the analysis. |
| Arlington to Dulles | The transportation is solely within Virginia. | The Compact’s Virginia-only exemption applies; other requirements still need review. |
| Outside-District charter with a local layover | The original party and itinerary matter. | Analyze the out-of-District charter guidance, including whether new passengers join. |
Sources: WMATC Jurisdiction FAQs · WMATC Compact, Articles I and XI–XIV
Do not expand the service area by assumption. All of Loudoun County is not included simply because Dulles is. The Compact’s BWI provision is limited to specified taxicab matters. Read the airport and Loudoun answer
Coverage, endorsements & status
A renewed policy is only part of the insurance picture.
The carrier needs qualifying coverage and the required WMATC filing. Compare the insured name, limits, policy periods, and Commission endorsement. For layered coverage, review the filings supporting each required layer.
If an endorsement terminates without timely replacement, the regulations provide for automatic suspension. The carrier must address the Commission’s requirements and obtain the required lift-suspension order before restarting covered operations.
- Verify the certificate’s seating restriction and required limits.
- Coordinate the correct endorsement with the authorized insurer.
- Obtain the required Commission verification when termination is approaching.
- Read every suspension ground before assuming one correction resolves the case.
Sources: WMATC Insurance Filing FAQs · WMATC Rules of Practice and Procedure and Regulations
Restricted authority
15 or fewer persons, including the driver. The ordinary minimum is $1.5 million in combined single limit liability coverage for this authority category.
Unrestricted authority
Authority for any vehicle size. The ordinary minimum is $5 million. Switching to smaller vehicles does not by itself amend the certificate or reduce that requirement.
Sources: WMATC authority application and fee schedule · WMATC Carrier Application Process
If a lapse has already occurred, preserve the operating record.
Keep dispatch logs, manifests, invoices, and client records for the relevant dates. A coverage gap can require supported proof that operations stopped. Correcting the endorsement and explaining past conduct are separate tasks.
Sources: WMATC Insurance Filing FAQs · WMATC Rules of Practice and Procedure and Regulations
Insurance suspension questionsRates, fares & contracts
Make the quote, contract, invoice, and tariff agree.
A rate sheet on your website is not a substitute for the applicable filed tariff. Review both the amount charged and the rules that determine the charge.
General tariffs
Review the services and rates offered to customers generally. Compare hourly minimums, waiting time, additional charges, and other transportation terms with the current filing.
Contract tariffs
Review the complete executed agreement, service period, fixed rates, attachments, amendments, and extensions. A new customer agreement may need regulatory work before service starts.
Filing date and effective date are different. Proposed changes generally require at least seven calendar days after filing before taking effect, unless the Commission orders an earlier date or rejects the tariff. Effective tariffs generally remain in place for at least 60 days unless the Commission orders otherwise.
Sources: WMATC Tariff FAQs · WMATC Compact, Articles I and XI–XIV
When can prices change?Reports, fees & fleet changes
Keep the carrier record aligned with the business.
A certificate does not require an ordinary annual renewal, but the carrier still has recurring obligations. Changes to vehicles, names, ownership, insurance, or service can create work between annual reports.
Calendar the obligation
Identify the report, fee, insurance termination, tariff, inspection, or order deadline. Assign a responsible person and a backup, with time to correct a rejected or incomplete filing.
Keep proof of completion
Retain the filed document, payment confirmation, acceptance or receipt, and any follow-up. A drafted report or sent email does not establish that every requirement is satisfied.
Review each fleet change
Check capacity, registrations, safety inspections, markings, insurance, and vehicle leases. State-specific registration sequences can matter for new applicants.
Sources: 2026 WMATC Annual Report and Fee Instructions · WMATC Carrier Application Process · WMATC Vehicle Inspection FAQs
2026 reporting-year reference
The report and annual fee are separate obligations.
The 2026 instructions required carriers holding authority on January 1 to file the complete report and pay the $175 annual fee by January 31. They specified separate $150 late charges and May 1 suspension for unresolved reporting and fee obligations. Use the instructions for the year at issue.
Adding a bus, selling a van, or changing a trade name? Review the change before it reaches the road. The vehicle and company information should remain consistent across your authority, insurance, registrations, tariffs, and contracts.
Investigations, suspension & show cause
Answer the order with a record that supports your position.
An enforcement notice can raise several issues at once. We review what is alleged, what the order requires, which operations are restricted, and what evidence supports a response.
Respond to the actual grounds
- Identify the deadline and every requested document.
- Build a dated chronology of filings and operations.
- Preserve trip, dispatch, payment, and customer records.
- Document corrections without obscuring earlier events.
Evaluate the next procedural step
A response, hearing, request to lift a suspension, application for reconsideration, or petition for judicial review serves a different purpose. An insurance correction may not resolve a reporting, fitness, or prior-operations issue.
Do not assume that asking the Commission to reconsider an order pauses its requirements.
Sources: WMATC Compact, Articles I and XI–XIV · WMATC Insurance Filing FAQs · WMATC Rules of Practice and Procedure and Regulations
Reconsideration
The Compact provides a 30-day period from publication of a final order to apply for reconsideration and specify the claimed errors. The order and procedural posture require prompt review.
Judicial review
The Compact provides a separate 60-day window after determination of reconsideration for review in the specified federal courts of appeals. Reconsideration is a prerequisite, and a stay requires separate attention.
Sources: WMATC Compact, Articles I and XI–XIV
Bring the notice before the deadline passes.
Include all pages, attachments, and delivery information. The first task is identifying what must be addressed and when.
Transfers, acquisitions & control
The purchase agreement does not carry the authority across on its own.
A carrier transaction can involve the certificate holder, ownership, management, assets, contracts, and insurance at the same time. The regulatory analysis should begin while the deal is being structured.
We review certificate and control-transfer requirements, the seller’s operating status, pending proceedings, and the filings needed for the proposed structure. The agreement can then address approval conditions, cooperation, responsibility for existing issues, and the planned handoff.
- Confirm the entity that actually holds authority.
- Review restrictions, suspensions, orders, and unpaid obligations.
- Identify the required approval and any temporary-approval issue.
- Coordinate the closing, insurance, contracts, and operating transition.
Sources: WMATC Compact, Articles I and XI–XIV · WMATC authority application and fee schedule
Do not rent another company’s number. The Compact prohibits a different person from leasing, renting, or otherwise using the certificate holder’s operating authority. A compliant vehicle lease is a separate question. Read the authority-use answer
Prepare for a useful consultation
Bring the records that explain the operation.
You do not need a perfect file to start a conversation. Tell us what is missing and identify any upcoming filing, hearing, trip, or closing date.
Authority and business identity
Certificate, orders, applications, entity records, approved trade names, ownership chart, and proposed transaction documents.
Service and vehicles
Origins and destinations, service contracts, passenger arrangements, fleet list, seating capacities, registrations, inspections, and leases.
Filings and insurance
Policies, WMATC endorsements, termination notices, written confirmations, tariffs, annual reports, and payment receipts.
A pending investigation
The complete notice or order, response dates, correspondence, trip manifests, dispatch and billing records, and evidence of corrective action.
Working with Shin Law Office
Connect the regulatory detail to the business decision.
Whether you are preparing for a first trip, responding to a suspension, or buying a carrier, the legal work should address the practical question in front of you.
Define the issue
Review the service, authority, business structure, and immediate deadline.
Build the file
Identify missing records and compare the filings with actual operations.
Prepare and respond
Address the application, compliance requirement, transaction, or proceeding.
Plan the next obligation
Identify remaining conditions, follow-up work, and responsibilities.
Meet the attorney
Anthony I. Shin, Esq.
Passenger carrier compliance touches the entire business: the entity that holds authority, the services sold, the vehicles operated, and the records maintained. Shin Law Office helps carriers review those connections and prepare a supported next step.
Learn more about Anthony ShinNorthern Virginia offices · Regional carrier matters
Meet with us in Leesburg or Fairfax.
Tell us where your business is based, where passengers are picked up and dropped off, and which filing or order needs attention. We assist with WMATC matters involving operations in the DC, Maryland, and Virginia compact region.
Request a consultationLeesburg
118 Edwards Ferry Road, N.E.
Unit 110
Leesburg, VA 20176
Fairfax
8300 Arlington Boulevard
#B2
Fairfax, VA 22031
Office: 571-445-6565 · Cell: 571-215-8823 · Fax: 703-442-8938
Answers before you call
WMATC compliance questions.
Direct answers about jurisdiction, applications, insurance, tariffs, reports, enforcement, and ownership changes.
Does crossing a border matter?Conditional grant or certificate?Insurance suspensionAnnual reportsResponding to an orderBuying or selling authority
Discuss your matter What is WMATC, and what does it regulate?
The Washington Metropolitan Area Transit Commission is the compact agency that regulates covered passenger transportation for hire in the Metropolitan District. Its work includes operating authority, tariffs, insurance compliance, and enforcement. It is different from WMATA, which operates Metro, and it does not replace every other regulator.
Do I have to cross a state line for WMATC authority to apply?
No. Covered trips entirely within DC, or between points in the Maryland portion of the Metropolitan District, can require WMATC authority. Transportation solely within Virginia is excluded by the Compact. Route endpoints, compensation, service type, and exemptions must be reviewed together.
What areas are in the WMATC Metropolitan District?
The District includes DC; Alexandria, Falls Church, Arlington County, and Fairfax County; the part of Loudoun County occupied by Washington Dulles International Airport; and Montgomery and Prince George’s counties in Maryland, with the political subdivisions and other areas described in the Compact. The entire Northern Virginia region is not included.
Does a Dulles airport shuttle need WMATC authority?
A covered for-hire trip from Dulles to DC or the Maryland portion of the Metropolitan District generally requires authority unless an exemption applies. A trip solely within Virginia has a Compact exemption. Airport access, vehicle permits, and other applicable requirements require a separate review.
Are Leesburg, all of Loudoun County, and BWI inside the same service area?
No. The ordinary Metropolitan District includes the Dulles Airport portion of Loudoun County, not all of Loudoun or Leesburg. The Compact has a limited BWI provision for specified interstate taxicab matters; it is not a general expansion of the District for all bus and shuttle services.
Can a trip that starts outside the Metropolitan District be exempt?
WMATC’s jurisdiction guidance describes an out-of-District charter scenario in which the same chartered party travels into the District and takes local trips during its layover without adding new passengers. That analysis is fact-specific. Regular-route service and a change in the passenger group can raise different questions.
Are limousines, taxicabs, or rideshare vehicles automatically exempt?
No blanket exemption applies just because a vehicle is called a limousine, sedan, SUV, or rideshare vehicle. The Compact and regulations distinguish qualifying bona fide taxicab service and authorized transportation network operations. Seating capacity, affiliation, service model, and applicable rates and insurance rules matter.
Do hotel shuttles, NEMT providers, and government contractors need a review?
Yes. Compensation can be bundled with another service, so no separate passenger ticket does not automatically mean no transportation for hire. Non-emergency medical transportation is not automatically ambulance service. A private government contractor should not assume that the exemption for transportation performed by government covers its own operations.
How do I apply for a WMATC Certificate of Authority?
The application identifies the operator and proposed service and supplies required entity or trade-name records, verification, and fees. WMATC evaluates fitness and public interest. An accepted application moves through further review, and a conditional grant requires additional compliance steps before the certificate is issued.
Can I operate after receiving a WMATC number or conditional grant?
Do not treat an assigned number or conditional grant as a final operating certificate. Complete the conditions in the order, confirm issuance and effective authority, and satisfy applicable insurance, vehicle, and tariff requirements before beginning covered service. The actual certificate and orders determine what is authorized.
How long does a WMATC application take?
There is no reliable single completion date for every applicant. Completeness, requests for information, protests, insurance filings, vehicles, inspections, and compliance with the conditional grant affect timing. Use the deadlines in your own notices and orders rather than planning a launch around an estimated approval date.
What is the difference between restricted and unrestricted authority?
Restricted authority limits operations to vehicles designed to seat 15 or fewer persons, including the driver, and ordinarily requires $1.5 million in combined single limit liability coverage. Unrestricted authority permits any vehicle size and ordinarily requires $5 million. The certificate’s restriction matters; a smaller current fleet does not itself amend unrestricted authority.
Does a commercial auto policy satisfy the WMATC insurance filing requirement?
A policy or ordinary certificate of insurance is not a substitute for the required WMATC Certificate of Insurance and Policy Endorsement. Confirm the correct insured entity, limits, dates, and authorized insurer filing. When an endorsement is terminating, obtain the required written verification from WMATC before continuing operations on or after that date.
What happens if the WMATC insurance endorsement expires?
Failure to replace the endorsement before termination triggers automatic suspension of operating authority under Regulation 58-12. Covered operations must stop. Address the replacement filing, outstanding fees, any additional suspension grounds, and the Commission’s lift-suspension requirements. A later policy purchase alone does not authorize restarting.
What records matter if WMATC alleges an insurance gap?
Preserve policies, endorsements, filing confirmations, trip manifests, dispatch logs, invoices, and relevant customer records. WMATC may require supported verification that operations stopped during a coverage gap. Give accurate, complete information; a corrected filing does not erase questions about earlier operations.
What is a WMATC tariff?
A tariff states the rates, fares, and related practices applicable to covered transportation. A general tariff applies to customers generally; a contract tariff addresses a qualifying transportation agreement. Quotes, invoices, surcharges, and contract terms should be compared with the applicable tariff in effect for the service.
Can I change prices as soon as I submit a new tariff?
Generally, a proposed tariff change must state an effective date at least seven calendar days after filing, unless the Commission orders an earlier date or rejects the tariff. An effective tariff generally remains in effect for at least 60 days unless the Commission orders otherwise. Confirm the applicable effective date before charging the new rate.
Does a signed customer contract replace a contract tariff filing?
No. A customer agreement does not remove the applicable tariff requirements. A contract tariff needs the complete executed agreement and required terms. Amendments, extensions, and replacements should be reviewed for filing before they change the service or outlast the existing contract tariff.
When are WMATC annual reports and fees due?
For 2026, carriers holding authority on January 1 were required to file a complete annual report and pay the $175 annual fee by January 31. The 2026 instructions imposed separate $150 late charges for a late report and late annual fee, and specified May 1 suspension for unresolved obligations. Check the instructions for the relevant reporting year.
Does a WMATC certificate have to be renewed every year?
The certificate is not an annual license renewal. Under the Compact it remains effective until amended, suspended, or terminated, subject to applicable requirements. Annual reports, annual fees, continuous insurance compliance, and other ongoing duties still apply. Do not confuse an unchanged certificate number with current operating status.
Can I add a vehicle without updating my WMATC records?
Review the vehicle’s seating capacity, registration, safety inspection, insurance, markings, and any lease or Commission inspection requirement before using it. A newly purchased vehicle must fit the carrier’s authority. A larger vehicle can require a change in authority and insurance, not just an updated fleet list.
Must every vehicle display the carrier name and WMATC number?
Marking requirements depend on the vehicle category and seating capacity. The general rule requires carrier identification and the WMATC number, while specified luxury sedans, SUVs, and limousines have limited exceptions. Confirm the applicable category and any waiver documentation before relying on an exception.
What should I do after receiving a show cause order?
Preserve the complete order and identify the response date, requested records, allegations, and any operating restriction. Assemble a factual chronology and evidence for each issue. A response should address the stated grounds and any supported corrective action; simply paying a fee may not resolve the entire proceeding.
What penalties can WMATC impose for unauthorized operations?
Consequences can include suspension or revocation, civil forfeiture, and court enforcement. The Compact provides civil forfeitures for knowing and willful violations of up to $1,000 for a first violation and $5,000 for a subsequent violation, with each day treated separately. The allegations, record, orders, and governing provisions determine exposure.
Can I seek reconsideration or appeal a WMATC order?
The Compact provides a 30-day period from publication of a final order for an application for reconsideration that specifies the claimed errors. It provides judicial review within 60 days after determination of that application in the specified federal courts of appeals. Reconsideration must be addressed before appeal, and neither process automatically stays the order. Have counsel evaluate the actual order promptly.
Can I buy or sell a WMATC certificate with the business?
A certificate transfer requires Commission approval. Certain mergers, substantial asset transactions, and acquisitions of control also require approval. Determine the transaction structure, current authority status, pending obligations, and approval conditions before setting the operational handoff. A signed purchase agreement alone does not transfer the right to operate.
Can a different company rent or use another carrier’s WMATC number?
The Compact prohibits a person other than the authority holder from leasing, renting, or otherwise using that authority. A vehicle lease is a different arrangement and has its own requirements. Do not use another company’s number as a shortcut while an application or acquisition is pending.
What should I bring to a WMATC consultation?
Bring the certificate and orders, legal entity and ownership records, routes, vehicle list and capacities, insurance and endorsements, tariffs, annual filings, and any notices. For an acquisition, include the proposed transaction documents. For enforcement, identify the earliest response date and preserve dispatch, trip, billing, and customer records.
Know what must happen before the next trip.
Bring the application, insurance notice, rate change, Commission order, or proposed deal. We can help identify the requirements and the next step.
Mention the earliest known response, filing, insurance, or closing date.
Based in Loudoun County and serving clients across Virginia, Washington DC, and Maryland, we know that when everything’s on the line, the right attorney doesn’t just make a difference, they determine the outcome.
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Copyright © 2026 Shin Law Office, PLC. All rights reserved.
Reproduction of any content on this site is prohibited except for individual, non-commercial, informational use. This limited permission does not allow modification, distribution, or incorporation of any content into other works or publications in any medium. You may not reproduce or distribute content from this site to any third party.