FMCSA insurance requirements — what has to be on file and what happens when it lapses

The minimums (49 CFR 387)

Public liability (bodily injury / property damage)

Non-hazardous freight, vehicles over 10,001 lbs	$750,000
Oil, some hazardous materials	$1,000,000
Hazardous substances, explosives, gases in bulk	$5,000,000
Household goods movers — cargo	$5,000 per vehicle / $10,000 per occurrence

Most shippers and brokers won't tender a load below $1,000,000 liability and $100,000 cargo regardless of the legal minimum, which is why the filings you see on report cards are almost always $1M.

The forms

• BMC-91 / BMC-91X — liability (BIPD). Your insurer files it electronically with FMCSA; you can't file it yourself.
• BMC-34 — cargo. Only required for household goods carriers and freight forwarders since 2011, but brokers ask for it anyway.
• BMC-84 / BMC-85 — the $75,000 broker/forwarder surety bond or trust fund. Not something a carrier needs.
• MCS-90 — the endorsement on your policy itself (not filed) that makes the insurer pay the public even if you broke a policy condition.

What a lapse does

When an insurer cancels, it files a BMC-35 notice. FMCSA then sends the carrier a notice giving 30 days to get a new filing on record before the operating authority is revoked. Reinstating costs $80 and takes a few days once the new BMC-91X is filed — but during the gap, brokers' compliance tools flag you as "not authorized" and loads dry up immediately. This is why the report card treats a missing liability filing as a serious mark.

What moves your premium

Underwriters look at the same public data on your report card: driver and vehicle OOS rates, crash history, years in business, and radius of operation. New authorities pay the most in year one and typically see the biggest drop at renewal if the first-year record is clean. The cheapest lever most owner-operators ignore is fixing wrong records through DataQs before shopping the renewal.

Sources: 49 CFR Part 387, FMCSA insurance filing requirements.