Short answer: FMCSA does not require a motor carrier to buy commercial general liability (CGL). Federal rules require certain carriers to maintain minimum financial responsibility for public liability arising from motor-vehicle operations. CGL addresses a different set of business exposures and is often purchased because a contract requires it or because the operation has meaningful premises and non-auto risks.
Under 49 CFR 387.7, a covered motor carrier may satisfy federal financial-responsibility requirements through insurance, a surety bond, or authorized self-insurance. When insurance is used, the MCS-90 is attached to the policy. For operating authority, an insurer or other registered filer submits a BMC-91 or BMC-91X when required. FMCSA's insurance-filing chart identifies the form and minimum that apply to each authority and operation type.
The MCS-90 is not a CGL requirement and it is not a broad grant of coverage to the motor carrier. It can require the insurer to pay certain final judgments even when the policy would not otherwise cover the loss, and the carrier may have to reimburse the insurer. The FMCSA MCS-90 explanation should be read alongside the policy and Part 387.
A CGL policy may respond to some bodily-injury, property-damage, personal-injury, and advertising-injury claims arising from premises or non-auto operations. Examples can include a visitor falling at a dispatch office or damage caused by a non-auto business activity. Every example remains subject to the insuring agreement, definitions, exclusions, conditions, and endorsements.
Loading and unloading deserves special attention. Depending on the forms and the facts, an auto policy may treat part of the activity as use of an auto while a CGL policy may contain an auto exclusion. Mobile equipment, completed operations, property in the insured's care, pollution, and employee injuries are also form-dependent. Read the auto and CGL policies together instead of assuming one begins exactly where the other ends.
A customer, broker, warehouse, port, municipality, or other contracting party may require CGL, specified limits, additional-insured status, primary-and-noncontributory wording, or a waiver of subrogation. Those terms come from the agreement, not from FMCSA. They must be checked contract by contract, including any required form edition and the operations for which additional-insured status applies.
A certificate of insurance is evidence of coverage; it does not rewrite the policy. If the contract asks for a term that the policy or endorsement does not provide, the certificate alone does not cure the mismatch.
Placing multiple lines with one insurer may simplify administration, but it does not erase exclusions or guarantee that every claim falls neatly into one policy.
Is CGL required by FMCSA?
No. FMCSA's public-liability rules and insurance filings concern financial responsibility for specified motor-carrier operations. CGL may still be required by a private or public contract.
Does CGL cover the freight?
Do not assume it does. CGL often limits or excludes property in the insured's care, custody, or control. Motor truck cargo may cover a qualifying freight loss, subject to its own terms.
Is the MCS-150 an insurance filing?
No. The MCS-150 is the Motor Carrier Identification Report and is used for identification and biennial updates. BMC-91/BMC-91X are insurance filings; the MCS-90 is a policy endorsement.
Review the contracts, auto policy, CGL policy, and umbrella together. Truscott can help identify which requirements apply to the operation and compare eligible trucking markets. Start with the commercial truck insurance overview or submit the operation through the commercial trucking application.
Sources checked August 17, 2026. Policy forms, contracts, and regulatory requirements can change; verify the current rules and the operation's actual documents.
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