CMV Insurance Requirements: Minimums, Filing & Compliance
CFR Reference: 49 CFR 387 | Max Fine: $18,758
Motor carriers must maintain minimum levels of financial responsibility (insurance) to operate. A lapse in coverage can mean fines up to $18,758 per day, revocation of operating authority, and vehicle impoundment.
What It Is
Federal financial responsibility requirements under 49 CFR 387 mandate that motor carriers maintain insurance or surety bonds at specified minimum levels. This is proven by filing a BMC-91 (Form E, Uniform Motor Carrier Bodily Injury and Property Damage Certificate of Insurance) or BMC-34 (surety bond) with FMCSA. The filing is made by the insurance company, not the carrier. Coverage must be continuous with no gaps.
Who Needs It
All motor carriers operating CMVs in interstate or foreign commerce that are required to register with FMCSA. This includes for-hire carriers, private carriers, and freight brokers (who have separate surety bond requirements). Minimum amounts vary by cargo type.
Deadline & Frequency
Insurance must be continuous. Renewals are typically annual. The insurance company is responsible for filing the BMC-91 with FMCSA and for notifying FMCSA of any cancellation (35 days notice required). Carriers should verify their insurance filing status on the FMCSA SAFER system. Start renewal discussions with your insurer 60 days before expiration.
Step-by-Step Process
- 1
Determine your minimum coverage level
General freight carriers: $750,000. Household goods carriers: $300,000. Passengers (16+): $5,000,000. Oil/hazmat: $1,000,000-$5,000,000 depending on the material. These are federal minimums. Some states and shippers require higher limits. Most carriers carry $1,000,000 as the practical minimum for general freight.
- 2
Obtain a policy from a DOT-authorized insurer
Work with an insurance broker experienced in commercial trucking. The policy must be from a company authorized to file BMC-91 forms with FMCSA. Not all insurance companies are authorized filers. Verify before binding coverage.
- 3
Verify BMC-91 filing with FMCSA
After binding coverage, your insurer files the BMC-91 with FMCSA. Check your carrier's status on the FMCSA SAFER website (search by USDOT number) to confirm the filing appears. It can take a few days to process. Your FMCSA record should show 'INSURED' under the insurance/financial status.
- 4
Monitor for lapses
If your insurer cancels or non-renews your policy, they must file a BMC-91X (cancellation form) with FMCSA with 35 days notice. Once the cancellation takes effect, your operating authority can be revoked. Set up alerts for policy renewal dates and never let coverage lapse, even for a day.
Consequences of Non-Compliance
- Fines up to $18,758 per day of operation without required insurance.
- FMCSA may revoke operating authority.
- Vehicles may be impounded at roadside inspections if insurance cannot be verified.
- Uninsured carriers face unlimited personal liability in accident claims.
- Brokers and shippers will not dispatch loads to uninsured carriers.
Frequently Asked Questions
- What is the minimum insurance for a trucking company?
- For general freight carriers: $750,000 minimum bodily injury and property damage liability. For household goods: $300,000. For hazmat (non-bulk): $1,000,000. For hazmat (bulk): $5,000,000. For passenger carriers (16+): $5,000,000. Most carriers carry at least $1,000,000 regardless of the minimum because shippers and brokers require it.
- What is a BMC-91 filing?
- The BMC-91 (Form E) is a certificate of insurance filed by your insurance company with FMCSA proving that your carrier meets the minimum financial responsibility requirements. It is not something you file yourself. Your insurer handles the filing and any cancellation notices (BMC-91X).
- What happens if my trucking insurance lapses?
- If your BMC-91 filing is cancelled and no replacement is filed, FMCSA can revoke your operating authority. You will not be able to legally operate until coverage is restored and a new BMC-91 is filed. Reinstatement involves filing new insurance, paying any outstanding fines, and potentially reapplying for authority.