1. Carrying insurance and filing it are two different obligations
The carrying rule is 49 CFR 387.7(a): "No motor carrier shall operate a motor vehicle until the motor carrier has obtained and has in effect the minimum levels of financial responsibility as set forth in § 387.9 of this subpart." Under § 387.3(a) it applies to "for-hire motor carriers operating motor vehicles transporting property in interstate or foreign commerce," and under § 387.3(b) to any carrier of hazardous materials, including private and intrastate carriers, subject to the weight exception in § 387.3(c). Proof under this rule is kept at your principal place of business (§ 387.7(d)) as a Form MCS-90 endorsement or a Form MCS-82 surety bond. Nothing under § 387.7 is filed with FMCSA.
The filing rule is subpart C. § 387.301T(a)(1): "No common or contract carrier ... shall engage in interstate or foreign commerce, and no certificate or permit shall be issued to such a carrier or remain in force unless and until there shall have been filed with and accepted by the FMCSA surety bonds, certificates of insurance, proof of qualifications as self-insurer, or other securities or agreements, in the amounts prescribed in § 387.303T." Read the last clause of the first sentence again: "or remain in force." The filing is a condition of keeping authority, not just getting it.
Household goods carriers carry a second filing obligation, § 387.301T(b), for cargo: no certificate is issued or remains in force until security is filed "conditioned upon such carrier making compensation to individual shippers for all property belonging to individual shippers and coming into the possession of such carrier."
Subpart C has two parallel sets of sections. §§ 387.301, 387.303, 387.313 and 387.323 are suspended (82 FR 5307–5308, effective January 14, 2017; §§ 387.303, 387.313 and 387.323 were later amended and "again suspended indefinitely"). The "T" sections are operative and are what we quote. §§ 387.307, 387.311 and 387.315 have no twin and are operative as written.
How we verified this: we read the full XML of 49 CFR part 387 from the eCFR API for the text in effect 2026-09-01, retrieved 2026-09-14, including every effective-date note, and 49 U.S.C. 13905 and 13906 from the Legal Information Institute the same day.
2. The minimum limits
Table 1 to § 387.9, Schedule of Limits, Public Liability, quoted in full:
| Type of carriage | Commodity transported | Minimum limit |
|---|---|---|
| (1) For-hire (In interstate or foreign commerce, with a gross vehicle weight rating of 10,001 or more pounds) | Property (nonhazardous) | $750,000 |
| (2) For-hire and Private (In interstate, foreign, or intrastate commerce, with a gross vehicle weight rating of 10,001 or more pounds) | Hazardous substances, as defined in 49 CFR 171.8, transported in bulk in cargo tanks, portable tanks, or hopper-type vehicles; in bulk Division 1.1, 1.2 or 1.3 materials; in bulk Division 2.3, Hazard Zone A material; in bulk Division 6.1, Packing Group I, Hazard Zone A material, in bulk Division 2.1 or 2.2 material; or highway route controlled quantities of a Class 7 material, as defined in 49 CFR 173.403 | $5,000,000 |
| (3) For-hire and Private (In interstate or foreign commerce, in any quantity; or in intrastate commerce, in bulk only; with a gross vehicle weight rating of 10,001 or more pounds) | Oil listed in 49 CFR 172.101; hazardous waste, hazardous materials, or hazardous substances defined in 49 CFR 171.8 and listed in 49 CFR 172.101, but not mentioned in entry (2) or (4) of this table | $1,000,000 |
| (4) For-hire and Private (In interstate or foreign commerce, with a gross vehicle weight rating of less than 10,001 pounds) | In bulk Division 1.1, 1.2, or 1.3 material; in bulk Division 2.3, Hazard Zone A material; in bulk Division 6.1, Packing Group I, Hazard Zone A material; or highway route controlled quantities of a Class 7 material as defined in 49 CFR 173.403 | $5,000,000 |
The filing schedule at § 387.303T(b) repeats those four rows for freight vehicles and adds limits § 387.9 does not have:
| Kind of equipment | Transportation provided | Minimum limit | Section |
|---|---|---|---|
| Fleet including only vehicles under 10,001 pounds GVWR | Property (non-hazardous) | $300,000 | § 387.303T(b)(1)(i) |
| Any vehicle with a seating capacity of 16 passengers or more (including the driver) | Passengers | $5,000,000 | § 387.303T(b)(1)(ii)(A) |
| Any vehicle designed or used to transport 15 passengers or less (including the driver) for compensation | Passengers | $1,500,000 | § 387.303T(b)(1)(ii)(B) |
| Household goods, cargo, "carried on any one motor vehicle" | Cargo liability | $5,000 | § 387.303T(c)(1) |
| Household goods, cargo, losses "occurring at any one time and place" | Cargo liability | $10,000 | § 387.303T(c)(2) |
For a new dry-van or reefer carrier the answer is the first row of the first table: $750,000. Shippers and brokers routinely require $1,000,000 by contract. That is a commercial term. FMCSA's public data on 2026-09-14 shows 64,292 BMC-91X filings at $750,000 and 30,057 at $1,000,000, so both are common, and only the first is the federal floor.
3. The forms, one by one
Every form below is named in the operative text of § 387.311 or § 387.313T. The "filings on record" column is the count of each form code in FMCSA's Motus insurance feed on 2026-09-14, so you can see which ones you will actually encounter.
| Form | What it certifies | Regulation text | Filings on record |
|---|---|---|---|
| BMC-91 | Bodily injury and property damage liability, always at the full required minimum | § 387.311(a): "Each Form BMC 91 certificate of insurance filed with the FMCSA will always represent the full security minimum limits required for the particular carrier, while it remains in force" | 2,552 |
| BMC-91X | Bodily injury and property damage liability, at the full limit or a stated amount, primary or excess | § 387.311(a): "will represent the full security limits ... or the specific security limits of coverage as indicated on the face of the form. If the filing reflects aggregation, the certificate must show clearly whether the insurance is primary or, if excess coverage, the amount of underlying coverage" | 99,841 |
| BMC-90 / MCS-90 | The endorsement attached to the policy behind a BMC-91 or 91X | § 387.313T(a)(3)(ii): BMC-90 "will be used with each filing of Form BMC 91 or Form 91X certificate ... which certifies to coverage not governed by the requirements of the Department of Transportation"; (a)(4): an MCS-90 is required when the limits "involve coverage also required by the Department of Transportation" | Not a filing |
| BMC-82 | Surety bond in place of a liability policy | § 387.313T(a)(5): "When surety bonds are used rather than certificates of insurance, Form BMC 82 is required" | 217 |
| BMC-34 | Cargo liability certificate for household goods carriers | § 387.313T(a)(3)(ii): "Form BMC 32 endorsement and Form BMC 34 certificate of insurance and Form BMC 83 surety bonds are used for the limits of cargo liability under § 387.303T(c)" | 4,166 |
| BMC-83 | Cargo surety bond, same purpose as BMC-34 | § 387.311(b): "Each form BMC 83 surety bond filed with the FMCSA must be for the full limits of liability required under § 387.303(c)" | 31 |
| BMC-84 | Property broker or freight forwarder surety bond | § 387.307(a): "Evidence of a surety bond must be filed using FMCSA's prescribed Form BMC-84" | 5,804 |
| BMC-85 | Property broker or freight forwarder trust fund agreement | § 387.307(a): "Evidence of a trust fund with a financial institution must be filed using FMCSA's prescribed Form BMC-85" | 193 |
| BMC-35 / BMC-36 | Notice of cancellation of a policy (35) or a surety bond (36) | § 387.313T(d), quoted in section 6 | 5,783 (BMC-35) |
Two forms, BMC-91MX and BMC-40, appear in the same sections but not in the table: the first is for Mexico-domiciled private carriers under § 387.303T(b)(4), the second is the self-insurance application under § 387.309, which requires "a current 'satisfactory' safety rating" and is not a path open to a new carrier.
Aggregation is allowed and is why BMC-91X dominates. § 387.313T(a)(2)(ii): when "insurance is provided by more than one insurer" to reach the limit, "a separate Department of Transportation prescribed form endorsement and Form BMC 91X certificate is required of each insurer." A primary policy plus an excess policy is two filings, each marked primary or excess.
4. Brokers and freight forwarders: $75,000, and a suspension clock measured in business days
§ 387.307(a), effective January 16, 2026: "A broker must have a surety bond or trust fund of $75,000 in effect. FMCSA will not register a broker until a surety bond or trust fund for the full limits of liability prescribed herein is in effect. The broker registration shall remain in effect only as long as a surety bond or trust fund remains in effect." A trust fund under § 387.307(b) "must contain assets aggregating to $75,000 that can be liquidated to cash within 7 calendar days," limited to "cash, irrevocable letters of credit issued by a federally insured depository institution, and Treasury bonds."
Freight forwarders are held to the same instrument and amount. § 387.403T(c): "The FMCSA will not issue a freight forwarder license until a surety bond or trust fund for the full limit of liability prescribed in § 387.405 is in effect," and § 387.405 sets that limit as "identical to that prescribed for brokers at 49 CFR 387.307." A household goods freight forwarder also files cargo security under § 387.403T(a).
The broker rule has its own suspension mechanism, faster than the 30-day cancellation in section 6. Under § 387.307(e)(1), the surety or trustee must notify FMCSA "by electronic means" when a payment or a determination of insolvency "causes the surety bond or trust fund to fall below $75,000," and under (e)(4) that notice "must be made within 2 business days." FMCSA then warns the broker that its authority "will be suspended within 7 business days of service of the notice" unless the broker shows the notice was in error, the bond is restored, or the claims were paid without touching it (§ 387.307(e)(5)). After that, "FMCSA will enter a suspension of the broker's authority" (§ 387.307(e)(6)).
5. Who files, how, and what it costs
You do not file any of these. § 387.313T(b): "Certificates of insurance, surety bonds, and notices of cancellation must be filed with the FMCSA," and the operative electronic-filing rule, § 387.323T(a), speaks only to insurers: "Insurers may, at their option and in accordance with the requirements and procedures set forth in paragraphs (a) through (d) of this section, file forms BMC 34, BMC 35, BMC 36, BMC 82, BMC 83, BMC 84, BMC 85, BMC 91, and BMC 91X electronically, in lieu of using the prescribed printed forms." Under § 387.323T(b), "Each insurer must obtain authorization to file electronically by registering with the FMCSA."
The suspended § 387.323(a) reads "Insurers must electronically file"; it is suspended, so the operative word is "may." In practice FMCSA's April 29, 2026 Motus notice (91 FR 23144) describes "financial responsibility filers (such as insurance/surety companies and other financial institutions)" using the new system for "submitting or removing filings," and every filing in the public feed carries the date FMCSA received it.
Your insurer also has to be eligible. § 387.315: a certificate "will not be accepted by the FMCSA unless issued by an insurance or surety company that is authorized (licensed or admitted)" in each state you are authorized to operate in, or in your home state with a designated process agent, or as an eligible surplus lines insurer. And the name has to match. § 387.313T(c): certificates "shall be issued in the full and correct name of the individual, partnership, corporation or other person to whom the certificate, permit, or license is, or is to be, issued. In the case of a partnership, all partners shall be named." A certificate in a trade name that does not match the docket is a rejected filing, and a rejected filing is a missed 20-day deadline.
That deadline is § 365.109T(a)(5): financial responsibility "is indicated by filing within 20 days from the date an application notice is published in the FMCSA Register." The only FMCSA charge attached to the filing is billed to the insurer, not to you: § 360.3T(f)(51), "A service fee for insurer, surety, or self-insurer accepted certificate of insurance, surety bond, and other instrument submitted in lieu of a broker surety bond — $10 per accepted certificate, surety bond or other instrument." Whether the insurer passes it through is between you and them. Premiums are a private price; we publish no figure for them, and say why on the startup costs page.
6. Cancellation: 30 days to FMCSA, 35 days between you and the insurer
§ 387.313T(d): "surety bonds, certificates of insurance and other securities or agreements shall not be cancelled or withdrawn until 30 days after written notice has been submitted to the FMCSA at its offices in Washington, DC, on the prescribed form (Form BMC-35, Notice of Cancellation Motor Carrier Policies of Insurance under 49 U.S.C. 13906, and BMC-36, Notice of Cancellation Motor Carrier and Broker Surety Bonds, as appropriate) by the insurance company, surety or sureties, motor carrier, broker or other party thereto, as the case may be, which period of thirty (30) days shall commence to run from the date such notice on the prescribed form is actually received by the FMCSA."
The carrying rule has its own, longer clock. § 387.7(b)(1): policies "shall remain in effect continuously until terminated. Cancellation may be effected by the insurer or the insured motor carrier giving 35 days' notice in writing to the other. The 35 days' notice shall commence to run from the date the notice is transmitted."
Replacement avoids both. § 387.313T(e): an accepted certificate "may be replaced by other certificates of insurance, surety bonds or other security, and the liability of the retiring insurer or surety ... shall be considered as having terminated as of the effective date of the replacement," provided the replacement is acceptable to FMCSA. Switching insurers is therefore a filing sequence: the new BMC-91X is received and accepted, and only then does the old one end. A BMC-35 received before the replacement is on file starts a 30-day countdown to the condition in the next paragraph.
When the countdown ends with nothing on file, § 387.301T(a)(1) is no longer satisfied and the certificate does not "remain in force." 49 U.S.C. 13905(f)(1)(A) lets FMCSA "suspend the registration of a motor carrier, a freight forwarder, or a broker for failure to comply with requirements of the Secretary pursuant to section 13904(e) or 13906," without the notice-and-proceeding step ordinary revocations require. FMCSA's authority-history feed records the result with one reason string, quoted exactly: "Involuntary Suspension - insurance cancellation effective; no active insurance meeting minimum coverage on file." Between January 1 and September 14, 2026 the feed holds 5,198 such changes, against 320 for a cancelled BOC-3 alone and 167 for both. Insurance is the leading cause of a docket going Inactive, by a wide margin.
7. How the filings appear in FMCSA's public insurance data
FMCSA publishes every accepted filing and cancellation in its Motus insurance feed, and our lookup shows the ten most recent rows for a docket. The columns, using the names in FMCSA's data dictionary:
- Form. The form code exactly as filed: BMC-91X, BMC-91, BMC-34, BMC-82, BMC-83, BMC-84, BMC-85, or BMC-35 for a cancellation.
- Type. FMCSA's dictionary defines the type code as "1 = BI&PD 2 = Cargo 3 = Bond 4 = Trust Fund," and the class code as "P = Primary E = Excess."
- Coverage. The maximum the insurer will pay, with a separate underlying-limit column for excess policies. FMCSA's data dictionary still describes the column as "Amount (in thousands)," which was true of the retired Licensing and Insurance feed, but the current Motus feed returns the full amount: a $750,000 BMC-91X shows as 750000.00 and the broker bond as 75000.00. Read the number, not the dictionary.
- Effective is the policy's effective date. Filed is, in the dictionary's words, the "Date FMCSA received the policy." The gap between them is the insurer's filing lag. A gap between the last filing's effective date and today, with a BMC-35 in between, is a lapse.
The operating authority table on the same record shows the minimum bodily injury and property damage coverage FMCSA has set for that docket beside the amount last filed, and whether cargo insurance or a surety bond is required and on file. A required-but-not-filed cell is the condition § 387.301T(a)(1) describes.
How we verified this: form-code counts and coverage-amount distributions were queried from FMCSA's "Motus Insur - All With History" dataset (c5y8-a4uz) and suspension counts from "Motus AuthHist - All With History" (yu5v-wbh6), both on data.transportation.gov, on 2026-09-14. Column definitions are quoted from the dataset's published data dictionary.
What this page does not cover
- This is not legal advice, and CarrierStat is not affiliated with FMCSA or any government agency. Verify with FMCSA and your insurer before relying on a filing.
- Premiums. No dollar figure on this page is a price. Every amount is a regulatory minimum or a bond limit.
- Passenger carrier applicability beyond the two seating-capacity rows is not walked through here; see appendix A to part 387. The transit-provider rule at § 387.303(b)(1)(iii) exists only in the suspended section and has no operative twin.
- Suspended sections are labeled. §§ 387.301, 387.303, 387.313 and 387.323 have suspended twins; the "T" text is operative and is what we quote.
Sources
49 CFR part 387 — § 387.3 (applicability), § 387.7 (requirement, 35-day notice, proof kept at principal place of business), Table 1 to § 387.9, §§ 387.301T and 387.303T (filing requirement and limits), § 387.307 (broker bond, effective Jan. 16, 2026), § 387.309 (self-insurance), § 387.311 (bonds and certificates), § 387.313T (forms, filing, 30-day cancellation, replacement), § 387.315 (insurer eligibility), § 387.323T (electronic filing), §§ 387.403T and 387.405 (freight forwarders). The suspended §§ 387.301, 387.303, 387.313 and 387.323 are cited only where labeled. eCFR API, text in effect 2026-09-01, retrieved 2026-09-14; human-readable at ecfr.gov. Part 387 was last amended by 91 FR 45653 (July 21, 2026), a technical corrections rule; the limits above are unchanged by it.
49 CFR 365.109T(a)(5) (20-day filing) and 49 CFR 360.3T(f)(51) ($10 insurer service fee). Same snapshot.
49 U.S.C. 13905 and 13906 — retrieved 2026-09-14 from law.cornell.edu.
91 FR 23144 (Availability of Motus, Apr. 29, 2026) — retrieved 2026-09-14 from federalregister.gov.
FMCSA Motus insurance and authority-history feeds (data.transportation.gov, c5y8-a4uz and yu5v-wbh6) — queried 2026-09-14. FMCSA's own web pages return HTTP 403 to automated retrieval, so nothing on this page is sourced from fmcsa.dot.gov.
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