Trucking Insurance Requirements for New Carriers: What FMCSA Requires Before Your First Load

Insurance is the single most expensive line item in a new carrier's first year, and the rules surrounding it are some of the most misunderstood. This guide covers what FMCSA requires, what your insurer files on your behalf, and what auditors will verify during your New Entrant Safety Audit.

Federal minimum coverage limits

Under 49 CFR Part 387, for-hire motor carriers must maintain minimum public liability coverage based on cargo type:

• $750,000 -- general freight non-hazardous, vehicles with GVWR 10,001 lbs or more
• $1,000,000 -- oil transported by for-hire motor carriers and certain hazardous materials
• $5,000,000 -- certain hazardous substances and many bulk hazmat shipments
• $300,000 -- household goods carriers (with additional cargo coverage requirements)

Most owner-operators hauling general freight carry $1,000,000 in primary liability because that is the level required by most freight brokers and shippers, even though FMCSA's minimum is $750,000. Insurance markets and broker contracts effectively make $1M the working minimum.

What your insurer files with FMCSA

Your insurance carrier -- not you -- must file proof of coverage directly with FMCSA using one of these forms:

1. BMC-91 or BMC-91X

   Proof of public liability coverage. BMC-91X is the consolidated form used by most modern insurers. This is the filing FMCSA looks for in SAFER before activating your authority.

2. BMC-34

   Proof of cargo insurance, required for household goods carriers.

3. BMC-84 or BMC-85

   Broker surety bond or trust fund, required only for freight brokers (not motor carriers).

After binding coverage, confirm with your insurance agent that the BMC-91X has been transmitted to FMCSA and that it shows on SAFER. Authority is not active until the filing is accepted.

MCS-90 endorsement

The MCS-90 is an endorsement attached to your liability policy under 49 CFR 387.15 that guarantees the public will be paid for negligent operations even if the policy would otherwise exclude coverage. It is not an additional policy -- it sits on top of your existing liability coverage. Auditors will ask to see proof that the MCS-90 endorsement is in force.

Cargo insurance

Cargo coverage is required by federal regulation only for household goods carriers. However, almost every broker contract requires general freight carriers to carry at least $100,000 in cargo insurance, so in practice you will need it to get loads. Typical cargo coverage runs $100,000-$250,000 with a deductible of $1,000-$2,500.

Physical damage and other coverages

Physical damage on your truck and trailer is not required by FMCSA but is required by lienholders and by most leasing companies. Workers' compensation may be required depending on your state and your employment structure. Non-trucking liability (bobtail) is needed by leased owner-operators when not under dispatch.

What the audit verifies

During the New Entrant Safety Audit, FMCSA will:

• Confirm your BMC-91X filing is active on SAFER
• Request a current certificate of insurance
• Confirm the MCS-90 endorsement is in force
• Confirm cargo coverage if you operate as a household goods carrier
• Cross-check your coverage limits against your cargo type

Common insurance mistakes

• Buying a policy from an insurer that does not file BMC-91X directly with FMCSA
• Letting coverage lapse for even one day -- FMCSA receives automatic cancellation notices
• Operating before SAFER shows the filing as accepted
• Carrying $750,000 when broker contracts require $1,000,000

How ClearToHaul helps

ClearToHaul is not an insurance agency, but the Done-For-You Compliance Package verifies your BMC-91X filing is accepted on SAFER, confirms the MCS-90 endorsement, and builds the insurance documentation into your audit binder so the auditor finds it on the first request.