Motor carrier insurance requirements: federal minimums, filings and state rules
Motor carrier insurance is the liability coverage a trucking company must carry before it operates. For a for-hire carrier hauling general freight across state lines in a truck rated 10,001 lb or more, federal law sets the minimum at $750,000, with higher tiers for hazardous materials. Your insurer files proof with FMCSA, attaches the MCS-90 endorsement, and must give notice before the coverage can end. Intrastate carriers follow their state's rules.
Contents
The short version
- The federal minimums depend on three facts: for-hire or private, weight rating, and what you haul.
- Proof of insurance reaches FMCSA on Form BMC-91 or BMC-91X, filed by your insurer. No filing, no authority.
- The MCS-90 guarantees payment to the public up to the minimum. It is not extra coverage for you.
- Brokers, shippers, lenders and leases often ask for more than the law. The law is the floor.
Who must meet the federal requirements?
Three federal questions decide what applies to you:
- Do you need a USDOT number? FMCSA requires one for a vehicle with a weight rating or actual weight of 10,001 lb or more (or meeting passenger or hazmat thresholds) used in interstate commerce. Some states, including California, Florida and Texas, also require a USDOT number for intrastate registrants.
- Do you need operating authority (an MC number)? FMCSA says for-hire carriers, and carriers transporting federally regulated commodities in interstate commerce, need authority on top of the USDOT number. Private carriers hauling their own cargo, carriers hauling only exempt commodities, and carriers working only inside an exempt commercial zone do not. FMCSA adds that this "also dictates the level of insurance" you must carry.
- Are you in the scope of the financial responsibility rule? Subpart A of 49 CFR 387 covers for-hire carriers of property in interstate or foreign commerce, and carriers of hazardous materials in interstate, foreign or intrastate commerce. It does not apply to vehicles under 10,001 lb, except for certain high-hazard materials.
In plain terms: a one-truck owner-operator hauling general freight for brokers across state lines needs all three. A leased owner-operator runs under the carrier's authority and filing; see insurance requirements on a lease.
The federal minimums: the full 387.9 table
FMCSA's financial responsibility rule says: "No motor carrier shall operate a motor vehicle until the motor carrier has obtained and has in effect the minimum levels of financial responsibility as set forth in § 387.9." That section's table of public liability limits, as published in 49 CFR 387.9 on eCFR, has four entries:
| Type of carriage | Commodity | Minimum |
|---|---|---|
| (1) For-hire, interstate or foreign commerce, GVWR 10,001 lb or more | Property (nonhazardous) | $750,000 |
| (2) For-hire and private, interstate, foreign or intrastate commerce, GVWR 10,001 lb or more | Hazardous substances in bulk in cargo tanks, portable tanks or hopper-type vehicles; bulk Division 1.1, 1.2 or 1.3 explosives; bulk Division 2.3 Hazard Zone A; bulk Division 6.1 Packing Group I Hazard Zone A; bulk Division 2.1 or 2.2; highway-route-controlled quantities of Class 7 radioactive materials | $5,000,000 |
| (3) For-hire and private, GVWR 10,001 lb or more; interstate or foreign commerce in any quantity, or intrastate in bulk only | Oil listed in 49 CFR 172.101; hazardous waste, hazardous materials or hazardous substances not mentioned in entry (2) or (4) | $1,000,000 |
| (4) For-hire and private, interstate or foreign commerce, GVWR under 10,001 lb | Any quantity of Division 1.1, 1.2 or 1.3; Division 2.3 Hazard Zone A; Division 6.1 Packing Group I Hazard Zone A; highway-route-controlled quantities of Class 7 | $5,000,000 |
The eCFR text we read was current as of October 16, 2026. A correcting rule published on July 21, 2026 changed only wording in entry (2), which FMCSA said had been "inadvertently added"; no dollar amount changed.
Carriers with operating authority: 387.303T
A second set of limits, in subpart C, applies to carriers registered with operating authority. The section numbered 387.303 is suspended indefinitely; the text in force is 387.303T. For property carriers, it sets:
| Fleet or vehicle | Commodity | Minimum |
|---|---|---|
| Fleet with only vehicles under 10,001 lb GVWR | Property (nonhazardous) | $300,000 |
| Freight vehicles of 10,001 lb GVWR or more | Property (nonhazardous) | $750,000 |
| Hazardous materials tiers | As listed in the section | $1,000,000 or $5,000,000 |
| Household goods carriers, cargo | Household goods | $5,000 per vehicle, $10,000 at any one time and place |
The $300,000 tier applies only when every vehicle in the fleet is rated under 10,001 lb, so a hotshot or box truck qualifies only if its weight rating stays below that line; see hotshot insurance and box truck insurance for how weight ratings decide the tier. For passenger carriers, the same section sets $5,000,000 for vehicles seating 16 or more and $1,500,000 for 15 or fewer; this site does not cover passenger operations.
What these limits mean in a claim, and why many operators buy more, is the subject of trucking liability insurance.
How does proof of insurance reach FMCSA?
FMCSA does not accept a certificate from you. Your insurer, or a surety, files on your behalf. FMCSA's insurance filing requirements say the agency "will not grant operating authority registration until the registrant has in effect the minimum levels of financial responsibility on file", and that once you apply, a provider "must file the appropriate insurance form(s) on behalf of the applicant".
| Form | What it is | Who needs it |
|---|---|---|
| BMC-91 | Certificate of liability insurance filed for the full limits | For-hire carriers |
| BMC-91X | Certificate filed for full coverage or any level of aggregation; required of each insurer when coverage comes from more than one | For-hire carriers, including layered coverage |
| BMC-82 | Surety bond in place of a liability insurance filing | Carriers using a bond |
| BMC-34 (or BMC-83 bond) | Cargo liability certificate; BMC-32 is the cargo endorsement | Household goods carriers |
| BMC-84 or BMC-85 | $75,000 surety bond or trust fund | Brokers and freight forwarders, not carriers |
| BMC-35 | Notice of cancellation of a filing | Written notice to FMCSA before a filing ends |
| MCS-90 (or MCS-82 for bonds) | Endorsement attached to the liability policy; kept at your principal place of business, not issued per truck | All for-hire and interstate motor carriers |
| BOC-3 | Designation of process agents, one for each state you operate in or through | All carriers with authority (not insurance) |
Two filing rules matter most for new carriers. First, the deadline: if the filing is not made within 20 days of your application's publication in the FMCSA Register, FMCSA serves a decision saying the application will be dismissed unless you comply within 60 days. Second, names: any difference between the name and address on the filing and on the authority application delays the grant. The full sequence is in new authority truck insurance.
FMCSA is moving registration and filings to a new system, Motus; until it is open to all users in 2026, filers continue in the current system.
The MCS-90 in one paragraph
The MCS-90 is required by 49 CFR 387.15 and must be issued in the exact name of the carrier. It obliges the insurer to pay final judgments for public liability caused by the carrier's vehicles, up to the required minimum, even if the policy would not otherwise pay, and the carrier agrees to reimburse the insurer in that case. It excludes injuries to the carrier's own employees and the cargo. Our page on the MCS-90 endorsement explains each clause.
Keeping coverage continuous
Federal rules are built to avoid gaps. Under 49 CFR 387.7, policies "shall remain in effect continuously until terminated", and either the insurer or the carrier must give the other 35 days' written notice to cancel. Separately, 387.313T says a filing cannot be cancelled or withdrawn until 30 days after written notice reaches FMCSA (Form BMC-35). FMCSA requires carriers with authority to keep proof of insurance and their process agent designation on file "to avoid revocation proceedings".
The practical consequence: short-term or stop-and-start coverage is hard to reconcile with an active authority. Our page on short-term truck insurance looks at where temporary policies do fit.
State requirements for intrastate carriers
A carrier that never crosses a state line, and does not haul hazardous materials, answers mainly to its state. Rules differ a lot. Three examples from the official sources we read:
| State | Who | Minimum liability | Caveat |
|---|---|---|---|
| Texas (TxDMV) | Private or for-hire carriers over 26,000 lb | $500,000; hazmat $1,000,000 or $5,000,000; household goods vehicles of 26,000 lb or less $300,000 | Registration (a TxDMV number) is also triggered by farm vehicles of 48,000 lb or more, placarded hazmat and movers |
| California (DMV) | For-hire property under 10,001 lb (Code V); property in vehicles of 10,001 lb or more (Code U) | $300,000 CSL; $750,000 CSL; hazmat and oil $1,000,000; bulk petroleum $1,200,000; certain tank loads $5,000,000 | Amounts from the DMV's motor carrier permit handbook dated 2016; we could not read the current Vehicle Code text, so confirm with the DMV |
| Florida (statute) | Commercial motor vehicles by gross vehicle weight | $50,000 (26,000 to under 35,000 lb); $100,000 (35,000 to under 44,000 lb); $300,000 (44,000 lb and up) | Vehicles subject to the federal rules in 49 CFR 387 must carry the federal minimums instead |
Sources: TxDMV's "TxDMV Number" page; the California DMV's MC 500 M Motor Carrier Permit Handbook, which also says a carrier's permit is suspended if its primary coverage is cancelled and that certificates cannot be cancelled on less than 30 days' notice from the insurer; and Florida Statutes section 627.7415 (2025). Texas is covered in more detail in commercial truck insurance in Texas.
Interstate for-hire work brings the federal minimum with it, even if your state's number is lower. A Florida truck of 44,000 lb that hauls for hire across state lines needs at least $750,000, not $300,000.
Requirements that come from contracts, not law
The federal and state minimums are only the legal floor. Most of the other lines on a one-truck policy are required by someone you signed with:
- Brokers and shippers set liability and cargo limits in their agreements. Many ask for more than the federal minimum; read each agreement for the exact figure and certificate wording. Cargo is covered in motor truck cargo insurance.
- Lenders set their own physical damage requirements for a financed truck in the loan agreement.
- Carriers you lease to must say in the lease who provides each coverage and what they charge back (49 CFR 376.12).
Our owner-operator truck insurance pillar puts these together for each setup, and the coverage planner lists the requirement behind each line for your operation.
Find your requirement in five questions
- Do you cross state lines, or haul hazardous materials? If neither, start with your state's rules.
- Are you for hire? If you haul others' property for pay across state lines, you need operating authority and the federal filing.
- What is the truck's weight rating? Under 10,001 lb with authority: $300,000 for nonhazardous freight. 10,001 lb or more: $750,000.
- What do you haul? Oil and most hazmat: $1,000,000. The bulk and high-hazard list in entry (2) or (4): $5,000,000. Household goods: add the cargo filing.
- What do your contracts say? Take the highest of the legal minimum and every contract you sign.
Sources
- 49 CFR 387.9, Financial responsibility, minimum levels, eCFR, consulted October 20, 2026. Also read: 49 CFR 387.3, 387.7, 387.15, 387.303T and 387.313T.
- Insurance Filing Requirements, FMCSA (last updated March 26, 2026), consulted October 20, 2026.
- MC 500 M Motor Carrier Permit Handbook, California DMV (rev. 3/2016), consulted October 20, 2026.
- Section 627.7415, 2025 Florida Statutes, Florida Senate, consulted October 20, 2026.
- "TxDMV Number", Texas Department of Motor Vehicles, consulted October 20, 2026.
FAQ
Is the $750,000 minimum per truck or per policy?
The federal rule sets a minimum level of financial responsibility for the motor carrier, and the MCS-90 applies to all vehicles operated under the policy that are subject to the federal requirements. It is not issued per vehicle. How the limit applies to each accident is set by your policy, so read its limit wording.
Do private carriers need to meet the federal insurance minimums?
For nonhazardous property, the federal financial responsibility part covers for-hire carriers, so a private carrier hauling its own nonhazardous goods is outside it. Private carriers of hazardous materials are covered, and state minimums can apply to private carriers too (Texas includes them above 26,000 lb).
Who files the BMC-91X, me or my insurer?
Your insurer, or another financial responsibility provider, files it on your behalf. FMCSA says that once you apply for operating authority, the provider must file the appropriate insurance forms for the applicant.
Is the federal minimum enough coverage?
It is enough to satisfy FMCSA, not necessarily your contracts. Many broker-carrier agreements ask for more than the federal minimum, and a serious accident can cost more than any minimum. The limit you need is the highest of the law, your contracts and your own risk tolerance.
Related
- MCS-90The MCS-90 endorsement explained: who needs it, what the insurer guarantees to the public, its exclusions, and why the reimbursement clause matters to you.
- New authorityNew authority truck insurance step by step: the FMCSA filing your insurer must make, the 20-day deadline, the limits that apply and how to prepare your file.
- LiabilityTrucking liability insurance explained for one truck: what primary liability pays, the $750,000 federal minimum, CSL vs split limits, MCS-90 and excess.
Updated October 20, 2026