FMCSA insurance requirements depend on the legal entity, authority type, vehicle, seating capacity, cargo, and operation. A USDOT number alone does not create the same filing obligation for every carrier. Start with the current FMCSA insurance-filing chart and the registration record in Motus.
For property carriers subject to the federal requirements, the current rules include:
The governing tables are in 49 CFR 387.9 and 49 CFR 387.303. Contract requirements can exceed a federal minimum, but $1 million liability or $100,000 cargo should not be presented as universal private-market requirements.
Effective January 16, 2026, revised broker and freight-forwarder rules also govern available security, drawdowns, suspension, and which institutions may serve as BMC-85 trustees.
FMCSA launched Motus for all users on May 19, 2026. Registrants use it to apply for and manage USDOT numbers and operating authority, submit biennial updates, update business information, reinstate suspended authority, reapply after revocation, and track registration actions. Public users can search registration records in Motus.
FMCSA still issues MC, MX, and FF docket numbers. New registrants can also see USDOT-number suffixes identifying registration or authority types. Those suffixes do not replace docket numbers today and are not vehicle markings. A filing must match the exact legal entity and specific authority record shown in Motus.
Required proof is submitted electronically by an FMCSA-registered financial-responsibility filer. The eligible filer depends on the form: an insurer handles insurance certificates, a surety handles bond forms, and an eligible financial institution handles a trust filing. A certificate of insurance sent to a customer is not a substitute.
Motus may identify a pending reason such as process-agent filing, financial-responsibility filing, or FMCSA review. FMCSA publishes no universal one-, two-, or three-business-day posting guarantee. Track the specific action and confirm accepted authority status before operating.
For BMC-91 or BMC-91X, prescribed cancellation generally does not become effective until 30 days after FMCSA receives it. An accepted replacement can terminate the prior certificate on the replacement's effective date. If required proof is absent when cancellation becomes effective, the authority is exposed to suspension or revocation proceedings.
A carrier may not perform for-hire interstate operations that require an inactive, suspended, or revoked authority. That does not mean every private or exempt interstate movement is prohibited; the authority requirement depends on the operation. Motus distinguishes reinstating a suspended authority from reapplying after revocation.
A written lease must address the authorized carrier's statutory responsibility, but insurance coverage is controlled by the lease and policy wording. “Under dispatch” is not a complete coverage test. The parties should identify primary liability, non-trucking or bobtail coverage, cargo, physical damage, deductibles, and reporting responsibilities in the actual documents.
Confirm the legal entity, authority, limits, filings, and contract requirements before binding or replacing coverage. Use the commercial truck insurance overview or start the commercial trucking application.
Reviewed August 17, 2026. This is general information, not legal advice or a coverage determination. Confirm current FMCSA, Motus, contract, and policy requirements for the actual entity and operation.
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