Trucking Insurance Requirements: FMCSA Minimum Coverage Guide

By CarrierLens Compliance Team • Last updated: 2026-05-01

FMCSA sets mandatory minimum insurance requirements for all for-hire motor carriers as a condition of operating authority. These minimums are significantly higher than standard commercial auto liability limits, and falling below them — even for a single day — results in automatic authority revocation. This guide covers every federal insurance requirement, how they are filed with FMCSA, and the consequences of coverage gaps.

Why FMCSA Sets Insurance Minimums

Federal insurance requirements ensure that injured parties — other motorists, cargo owners, the public — have a financially solvent source of recovery when a commercial vehicle is involved in an accident. Unlike state insurance requirements, which may be as low as $25,000 for personal vehicles, FMCSA minimums reflect the catastrophic damage potential of large commercial motor vehicles.

FMCSA Minimum Liability Insurance Requirements

Minimum limits are set by commodity type and vehicle weight under 49 CFR Part 387:

• General freight, non-hazmat, vehicles under 10,001 lbs: $750,000
• General freight, non-hazmat, vehicles over 10,001 lbs: $750,000 (most common for Class 8 trucks)
• Household goods: $750,000
• Passenger transportation (1–15 passengers): $1,500,000
• Passenger transportation (16+ passengers): $5,000,000
• Hazardous materials — certain categories: $1,000,000 to $5,000,000 depending on commodity
• Oil listed in §172.101: $1,000,000
• Explosive, poison gas, certain radioactive materials, other listed hazmat: $5,000,000

The MCS-90 Endorsement

The MCS-90 is a mandatory endorsement on the insurance policy of every for-hire motor carrier. It is not a separate policy — it is an amendment to your existing commercial auto liability policy. The MCS-90 ensures that your insurer will pay claims up to the FMCSA minimum even if the specific vehicle involved in an accident would not normally be covered (for example, a hired or borrowed vehicle not listed on the policy).

Key facts about the MCS-90:

• Required for all motor carriers holding FMCSA operating authority
• Applies regardless of whether the vehicle is owned, hired, or non-owned
• Creates a direct right of action for injured third parties against the insurer
• Does not protect the carrier or insurer against claims by the carrier's own employees

BMC-91 and BMC-91X: Filing Insurance with FMCSA

Your insurance company must file proof of coverage directly with FMCSA — you cannot submit it yourself. The two filing forms are:

• BMC-91: Certificate of Liability Insurance. Filed for all motor carriers. This is the most common filing and confirms your liability policy meets FMCSA minimums.
• BMC-91X: Used instead of BMC-91 if your carrier is self-insured or uses a surety bond in lieu of insurance. Rarely used by standard carriers.

Insurance brokers submit the BMC-91 electronically through FMCSA's filing portal. Processing takes 1–3 business days. Your authority is not activated until the BMC-91 is on file and accepted.

Cargo Insurance Requirements

FMCSA requires cargo insurance only for household goods movers. For all other commodity types, cargo insurance is voluntary — but practically required for business reasons, as most shippers and brokers require it as a condition of accepting loads.

• Household goods movers: BMC-34 filing required. Minimum $5,000 per vehicle or $10,000 per occurrence.
• All other for-hire carriers: No federal minimum, but shipper/broker contracts typically require $100,000 or more.

What Happens If Insurance Lapses

Insurance continuity is one of the most critical ongoing compliance requirements because the consequences of lapse are automatic and immediate:

• The insurer files an automatic BMC-35 cancellation notice with FMCSA 30 days before the cancellation date
• If coverage is not replaced before the cancellation date, FMCSA automatically revokes the carrier's operating authority
• Reinstatement requires a new BMC-91 filing and a $80 reinstatement fee
• Operating under revoked authority carries civil penalties up to $16,000 per day

Additional Insurance Carriers Typically Need

Beyond FMCSA minimums, a fully protected trucking operation typically carries:

• Physical damage — covers damage to your own trucks and trailers
• Cargo insurance — covers cargo in transit regardless of fault
• General liability — covers non-driving incidents at shipper/receiver facilities
• Workers' compensation — required in most states for employee drivers; not required for true owner-operator independent contractors
• Bobtail or non-trucking liability — covers the tractor when it is not under dispatch