FMCSA Insurance Filing Requirements: A Practical Guide for Carriers and Brokers

Operating in the U.S. transportation industry requires more than maintaining vehicles and schedules. Compliance with federal regulations is essential, and the Federal Motor Carrier Safety Administration (FMCSA) plays a central role in ensuring carriers, freight forwarders, and brokers meet required safety and financial standards.

Among the most important compliance elements are insurance filings. These filings verify that companies carry the required financial responsibility to protect both the public and the business itself. Without them, operating authority can be delayed, suspended, or revoked.

Why Insurance Filings Matter

Transportation involves significant financial and legal exposure. Accidents, cargo losses, and liability claims can place a business at risk if insurance documentation is not properly filed. 

FMCSA filings provide proof that minimum levels of coverage are in place before authority is granted. Submitting accurate, timely forms is not just a regulatory formality—it is a condition for legally operating in interstate commerce.

Key FMCSA Insurance-Related Forms

Let’s take a closer look at the most common insurance-related forms one may encounter as part of the FMCSA compliance process.

BMC-91 and BMC-91X: Public Liability Insurance

Who Needs It: For-hire motor carriers operating vehicles over 10,000 lbs in interstate commerce.

What It Covers: Bodily injury, property damage, and environmental restoration.

Coverage Minimums:

• $750,000 for general freight

• $1,000,000 for oil transport

• $5,000,000 for certain hazardous materials

Form Details: BMC-91 is used for a single policy; BMC-91X applies when multiple insurers provide coverage.

BMC-34 and BMC-83: Cargo Insurance

Who Needs It: Household Goods Motor Carriers and Household Goods Freight Forwarders.

What It Covers: Loss or damage to household goods during transport.

Coverage Minimums: $5,000 per vehicle and $10,000 per occurrence.

Form Details: BMC-34 is for insurance policies, while BMC-83 is for surety bonds.

BMC-84 and BMC-85: Surety Bonds and Trust Funds

Who Needs It: Freight brokers and freight forwarders without their own vehicles.

Requirements: $75,000 minimum obligation.

Form Details:

• BMC-84: Proof of a surety bond, with annual premium payments to a bonding company.

• BMC-85: Proof of a trust fund agreement, requiring $75,000 held in escrow.

BOC-3: Designation of Process Agents

Who Needs It: All carriers, brokers, and freight forwarders.

Purpose: Appoints agents in each state to receive legal documents such as lawsuits or summons.

Filing Process: Typically completed electronically through a blanket agent who covers all states.

MCS-90: Endorsement for Hazardous Materials Carriers

Who Needs It: Carriers transporting hazardous materials.

Purpose: Provides public liability coverage under Sections 29 and 30 of the Motor Carrier Act of 1980.

Common Filing Mistakes to Watch Out For

Many carriers and brokers struggle with FMCSA filings not because the requirements are complex, but because of avoidable errors. 

One of the most common issues is mismatched coverage levels. Policies must reflect the exact type of freight or passengers being transported, and even small discrepancies can cause delays or denial of claims. 

Another frequent mistake is relying on outdated forms. Since FMCSA occasionally updates its documentation, submitting older versions can lead to rejection.

Filings also need to stay current. Changes in address, insurance providers, or operations must be reported promptly to remain compliant. 

Finally, there is often a mistaken assumption that insurers handle filings automatically. Some do, but not all, and businesses are responsible for confirming that submissions have been made correctly.

Best Practices for Compliance

The good news is that avoiding these pitfalls is straightforward. Partnering with insurance providers who specialize in the trucking industry reduces the risk of errors. Maintaining a clear system for tracking deadlines and renewal dates ensures filings remain active, preventing interruptions to operating authority. It is also advisable to keep both digital and physical records of all filings and confirmation receipts, even when submissions are electronic.

FMCSA’s online tools, such as the Unified Registration System (URS), make it easier to monitor status and verify compliance, providing a single source of truth for carriers and brokers.

Consequences of Non-Compliance

The consequences of incomplete or inaccurate filings are immediate and often costly. Operating authority cannot be granted until all required documents are approved, which means new carriers may face delays in starting operations. For established carriers, a lapse in coverage or a rejected filing can result in sudden suspension of authority, disrupting schedules and customer relationships.

Financial risk also increases. If an accident occurs without verified coverage on file, the costs may fall directly on the business. There are also legal risks: without a valid BOC-3 agent designated, companies may miss lawsuits or court notices, leading to default judgments.

In conclusion

FMCSA insurance filing requirements are a cornerstone of compliance in the transportation industry. Each form serves a specific purpose, from verifying liability insurance to ensuring legal accountability. By staying current with filing obligations, carriers, freight forwarders, and brokers not only protect their authority to operate but also safeguard their financial stability and reputation. 

Regular policy reviews, accurate filings, and support from experienced insurance professionals help ensure uninterrupted operations and long-term compliance with FMCSA regulations.