Short answer: your insurance company, not you, files proof of insurance with FMCSA, and FMCSA says carriers shouldn’t send certificates in themselves.[1] Which form gets filed depends on what you haul and how your coverage is built. Without the right filing on record, FMCSA won’t issue your operating authority or keep it in force.[2] Here’s what each form means, what changed in 2026, and how state filings work.
Which federal filing you need
| Operation | Federal minimum | Filing |
|---|---|---|
| For-hire freight, trucks under 10,001 lb | $300,000 | BMC-91, BMC-91X or BMC-82 |
| For-hire freight, 10,001 lb or more | $750,000 | BMC-91, BMC-91X or BMC-82 |
| Certain hazardous materials | $1,000,000 | BMC-91, BMC-91X or BMC-82 |
| Explosives, poison gas, radioactive materials | $5,000,000 | BMC-91, BMC-91X or BMC-82 |
| Household goods movers | $750,000 liability, plus cargo | BMC-91, 91X or 82, plus BMC-34 or BMC-83 |
| Freight brokers and forwarders | $75,000 | BMC-84 or BMC-85 |
Source: FMCSA’s filing requirements chart.[3] Household goods cargo coverage must be at least $5,000 per vehicle and $10,000 per occurrence.[4]
BMC-91 vs BMC-91X vs BMC-82
- BMC-91: one insurer certifies the full federal limit.[5] It always represents the full minimum.[6]
- BMC-91X: can show full coverage or any layer of it.[5] It isn’t only for stacked coverage, but when two or more insurers combine limits, each one files its own BMC-91X and shows whether its coverage is primary or excess.[5][6]
- BMC-82: a surety bond used in place of an insurance certificate, written for the full limit.[6][5]
Cargo filings: only for household goods
FMCSA requires cargo filings only from household goods carriers and household goods freight forwarders, on a BMC-34 certificate or a BMC-83 surety bond.[1][5] FMCSA’s records show cargo and bond coverage at the federal minimum even if you bought more.[7] So when a broker asks for proof of $100,000 cargo, what it needs is a certificate of insurance from your agent, not your FMCSA record. See motor truck cargo insurance.
The MCS-90: kept on file, not filed
- Who needs it. FMCSA’s chart lists the MCS-90 endorsement, or the MCS-82 for surety bonds, for all for-hire and interstate motor carriers.[3]
- Where it goes. Proof is kept at your principal place of business.[8] For exempt carriers without operating authority, FMCSA says the form isn’t required to be filed with FMCSA.[1] It must be issued in your exact legal name.[9]
- What it does. It attaches to your liability policy, not to individual trucks.[10] The insurer agrees to pay final judgments for public liability whether or not the truck is listed on the policy, but not for injuries to your own employees or damage to the cargo you haul.[11]
- The catch. If the insurer pays a claim your policy wouldn’t otherwise have covered, you agree to reimburse it.[11] In other words, it protects the public on a reimbursement basis.[12] Keep every truck and driver listed correctly.
Freight brokers: new $75,000 rules from January 16, 2026
A broker must keep a $75,000 surety bond (BMC-84) or trust fund (BMC-85) in effect. Trust funds are now limited to cash, irrevocable letters of credit and Treasury bonds. If a payment drops the fund below $75,000, the surety must tell FMCSA within 2 business days, and the broker’s authority is suspended within 7 business days of notice unless it’s restored.[13] See freight broker insurance and bonds.
BOC-3: your process agents
Only a process agent can file Form BOC-3 for a motor carrier, a post office box isn’t an acceptable agent address,[14] and you need an agent in every state where you’re authorized to operate and every state you drive through.[15] A blanket designation through a process agent company can cover every state at once.[16]
Cancellations, lapses and revocation
- 30 days’ notice. Your insurer cancels a federal filing on Form BMC-35 (BMC-36 for bonds), and the cancellation takes effect 30 days after FMCSA actually receives it. A replacement filing ends the old insurer’s liability on the date the new coverage takes effect.[5]
- 35 days on the policy. Separately, cancelling the policy itself between you and the insurer takes 35 days’ written notice.[8]
- Revocation. FMCSA describes the process this way: its first notice goes out 3 days after it learns of the cancellation, you then have 30 days to get a new filing on record, and if you don’t, it issues a decision revoking your authority.[7]
- Name changes. After a legal name change, an amended BOC-3 and insurance filing must reach FMCSA within 30 days, or your authority is at risk.[1]
When you switch insurers, make sure the new filing is on record before the old one ends.
What changed in 2026: filings moved to Motus
FMCSA retired the legacy Licensing and Insurance (L&I) system for filings and moved registration to Motus in May 2026, and said the public would be able to search registration records there.[17][18] FMCSA says the old L&I site is now only for reviewing historical records, and Motus filings aren’t shown on it.[18] So if L&I doesn’t show your new filing, that alone doesn’t mean it’s missing. Ask your agent for the filing confirmation, and call FMCSA at 1-800-832-5660 if anything looks wrong.
State filings: Form E, Form H and Form K
States that issue their own intrastate authority use uniform forms: Form E proves liability insurance, Form H proves cargo insurance, and Form K cancels coverage. Forms G, J and L are the bond versions.[19]
- Texas: Form E for liability, Forms H and I for cargo, Form K to cancel, and only your insurance company can file them. A Form E filing costs $100.[20]
- Kansas: the insurance company files Form E electronically, and the commission doesn’t accept ACORD certificates.[21]
- Ohio: insurers file Form E for intrastate carriers, and Forms E and H for household goods movers.[22]
- Georgia: Form E is required for for-hire carriers, filed by the insurance company, not the agent.[23]
- California: uses its own forms, an MC 65 M certificate of insurance[24] and an MC 66 M to cancel, with 30 days’ notice. If no new certificate arrives, the permit is suspended from the cancellation date.[25]
See what each state requires in our truck insurance requirements by state table.
Frequently asked questions
Who files my BMC-91 or BMC-91X: me or my insurance company?
Your insurance company files it with FMCSA. FMCSA says carriers shouldn’t send insurance certificates in themselves.[1]
What’s the difference between a BMC-91 and a BMC-91X?
A BMC-91 shows one insurer covering the full federal limit. A BMC-91X can show full coverage or one layer, and each insurer in a stack files its own.[5]
Is the MCS-90 my liability insurance?
No. It’s an endorsement on your liability policy that guarantees payment of public-liability judgments, and you must reimburse the insurer for anything your policy wouldn’t otherwise cover.[11][12]
What happens if my insurance is cancelled?
The insurer files a BMC-35, which takes effect 30 days after FMCSA receives it. If no new filing is on record, FMCSA issues a decision revoking your authority.[5][7]
I only haul inside my state. Do I need Form E?
Often yes, if your state requires intrastate authority, as Texas, Kansas, Ohio and Georgia do. California uses its own MC 65 M form instead.[20][21][24]
Need a BMC-91X or Form E filing?
Call 360-450-2211 or start your quote. We quote trucking operations in the 48 contiguous states from our office in Vancouver, Washington, Monday to Friday, 7 a.m. to 5 p.m. Pacific.
Related coverage
Sources
- [1] FMCSA: Ask FMCSA, insurance questions
- [2] 49 CFR 387.301T: surety bonds and policies of insurance
- [3] FMCSA: Insurance filing requirements
- [4] 49 CFR 387.303T: security for the protection of the public, minimum limits
- [5] 49 CFR 387.313T: forms and procedures
- [6] 49 CFR 387.311: bonds and certificates of insurance
- [7] FMCSA L&I: Carrier search help
- [8] 49 CFR 387.7: financial responsibility required
- [9] 49 CFR 387.15: forms
- [10] FMCSA: Form MCS-90 endorsement
- [11] FMCSA: MCS-90 form (Rev. 2017)
- [12] IRMI: MCS-90 endorsement
- [13] 49 CFR 387.307: broker financial security
- [14] FMCSA: Form BOC-3, designation of process agents
- [15] 49 CFR 366.4T: who must designate process agents
- [16] 49 CFR 366.5T: blanket designations
- [17] Federal Register (Apr. 29, 2026): Availability of Motus, FMCSA's new registration system
- [18] FMCSA: Ask FMCSA, Motus and L&I questions (May 2026)
- [19] Minnesota Rules chapter 8855: motor carrier insurance forms
- [20] Texas DMV: TxDMV number and insurance filings
- [21] Kansas Corporation Commission: Transportation FAQs
- [22] PUCO: Intrastate motor carriers and registration
- [23] Georgia DPS: Intrastate motor carrier application (2025)
- [24] California DMV: Motor carrier permits
- [25] California DMV: Motor carrier permit handbook (MC 500 M)
General information only, checked September 2026. Rules change; confirm with the agency that issues your permits. Coverage availability, terms and filings depend on underwriting and the policy issued; a quote request does not bind insurance.
Published by Class Insurance Agency, an affiliated office of AIC Insurance. General information only; coverage depends on the actual policy and underwriting. For a question or correction, contact our team.