Stretch Limos, Vans and Modified FHVs: NYS DOT Rules

If your for-hire vehicle seats 10 or more people (counting the driver) or was changed after it left the factory, TLC's ordinary rules are not enough. Unless NYS DOT exempts it, the vehicle needs a NYS Department of Transportation (DOT) operating authority and a current MC-300 inspection, gets inspected by DOT twice a year, and still needs a TLC visual inspection at Woodside when you apply or renew. An alteration TLC's rules don't allow can cost $10,000 and the license.

This is the only page on TLC Help about stretch limousines, large vans and modified FHVs. For regular cars, see the TLC vehicle inspection guide.

Does this apply to my vehicle?

The rule behind this is §59A-04(q): an applicant for a new or renewal FHV license "must show that the vehicle possesses a current and Valid operating authority license from NYS and a current and Valid MC-300 Vehicle inspection form if the vehicle is not exempt from NYS DOT inspection and operating authority requirements and either ... (1) The vehicle seats 10 or more passengers (including the driver) or (2) The vehicle is a modified vehicle."

The MC-300 inspection, then TLC's visual inspection

TLC's Vehicle Inspections page gives the order: "Vehicles with a seating capacity of 10 or more must be inspected by the NYS DOT, and receive an MC300 sticker before coming to TLC's Woodside Inspection Facility to receive a TLC Visual Inspection." The same is true for every commuter van and paratransit vehicle.

At renewal, TLC's renewal page asks you to upload the passing MC-300 report in TLC UP and says: "The inspection report is valid for one (1) year, and it must be current at the time of renewal."

For modified vehicles that are not DOT-exempt, §59A-28(a)(3)(iii) goes further: TLC's own new, renewal and tri-annual inspections and its safety-standard checks "will be inspections of, and determinations by, the NYS Department of Transportation." TLC still does a visual inspection at application and renewal (§59A-28(a)(3)(iv)).

Twice a year, not three times

What modifications TLC allows

Rule §59A-28(a)(1) starts with a ban: no FHV can be altered after manufacture "to increase its length, width, weight or seating capacity" or "to modify its chassis and/or body design." Then it lists exceptions. Which one fits depends on seats and DOT status:

The same items show up at the application stage. A new license applicant for a modified vehicle (other than in a manufacturer-supported program) must show the modifier's warranty — chassis and frame free from defects for 3 years or 60,000 miles, whichever comes first (§59A-04(s)) — and that the modifier carries $5,000,000 general liability insurance (§59A-04(t)). The vehicle must have been re-registered with NYS after modification (§59A-04(p)).

Before you buy a stretched, raised-roof or converted vehicle

Most problems with these vehicles start at the purchase, because the paperwork for a modification comes from the modifier, not from TLC. Before you pay, ask the seller for documents that match what §59A-28(a) and §59A-04 ask TLC applicants to show:

• Who did the work, and are they registered with NHTSA (the U.S. National Highway Traffic Safety Administration)? The rule requires the modifier to certify this.
• Is the modifier's sticker on the vehicle certifying that the work meets Federal Motor Vehicle Safety Standards (FMVSS)? It must be an original, unaltered sticker for the factory-program route.
• Is there a written warranty covering the chassis and frame for 3 years or 60,000 miles? If the vehicle is used, ask how much of that warranty is left and whether it transfers; TLC's rule speaks only about the warranty being provided, not about used-vehicle transfers.
• Does the modifier carry $5,000,000 in general liability insurance, and can you get proof?
• Was the vehicle re-registered with the NYS DMV after the change? An old registration that describes the original vehicle is a warning sign.
• Does NYS DOT consider it exempt or not? If you are unsure, assume it is covered and ask DOT before you buy.

If the seller cannot answer these, TLC may refuse the license, and an unapproved alteration found later can bring the $10,000 fine.

Common mix-ups

"10 seats" counts the driver for DOT purposes but not for insurance. §59A-04(q) and §59A-26(a)(2) say "10 or more passengers (including the driver)." The insurance tiers in §59A-12(c) count passengers "not including the Driver." A 9-passenger van plus driver is in the DOT group but in the 8–15 insurance tier.

A DOT exemption is not a modification exemption. Even an exempt vehicle must meet the re-registration, sticker, NHTSA, warranty and $5 million rules in §59A-28(a)(4)–(5) if it was altered.

Passing DOT does not replace TLC's visual inspection. You still go to Woodside at application and renewal.

Insurance goes up with seats

TLC's minimums (Get a For-Hire Vehicle License page, read Oct 12, 2026; rule §59A-12(c)):

• 8–15 passengers: $1.5 million per occurrence combined single limit (CSL) + $100,000 personal injury protection (PIP), for black cars, liveries and luxury limousines.
• 16–20 passengers: $5 million per occurrence CSL + $100,000 PIP.

Seats are counted not including the driver for insurance, while the DOT rules above count including the driver — read each rule's wording. More: FHV insurance requirements and FHV insurance carriers explained. Which companies insure TLC vehicles today: TLC insurance market share.

Drivers: 19-A status

TLC's renewal page: "Stretch Limousines require operating authority from the NYS Department of Transportation; and can only be operated by drivers with ACTIVE 19A Status." Rule §80-11(c)(3) applies to any FHV that is not DOT-exempt: the driver must comply with Article 19-A of the NYS Vehicle and Traffic Law, and driving without it "constitutes the same offense as driving a For-Hire Vehicle without a Valid License" — $350 and suspension until compliance for a first violation. If you own the vehicle, check every driver's 19-A status before dispatch.

Owner checklist

Related situations

• Wheelchair accessible conversions are also post-manufacture changes. TLC keeps a list of approved accessible models and converters: approved WAVs.
• Luxury limousine bases dispatch vehicles seating 20 or fewer: see luxury limousine.
• Markings: FHVs may not use taxi yellow or the green cab color, among other rules (§59A-29); see §59A-29(c) for the inspection-sticker rule.
• Daily duties that apply to every owner: FHV owner daily duties.
• Where large vehicles wait: taxi stands by borough.
• Accessible taxi fleet data: wheelchair accessible taxi statistics.

This guide explains TLC rules; it is not legal advice. NYS DOT and NYS DMV set their own requirements for operating authority, 19-A and vehicle approvals, which TLC Help has not summarized here.