DOT Insurance Requirements: $750K to $5M by Cargo, MCS-90 and BMC-91

Quick Answer: DOT Insurance Requirements

The Federal Motor Carrier Safety Administration (FMCSA), part of the U.S. Department of Transportation, sets minimum levels of financial responsibility for motor carriers in 49 CFR Part 387. The minimum depends on what you carry and the vehicle's gross vehicle weight rating (GVWR):

Two different documents prove it. The MCS-90 is an endorsement on your policy that you keep at your principal place of business. The BMC-91 or BMC-91X is the certificate your insurer files with FMCSA before for-hire operating authority is granted.

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Who the Federal Minimums Apply To

FMCSA's property-carrier minimums (49 CFR Part 387, Subpart A) apply to:

• For-hire motor carriers transporting property in interstate or foreign commerce
• Any motor carrier — for-hire or private — transporting hazardous materials, hazardous substances or hazardous wastes, in interstate, foreign or intrastate commerce

They do not apply to a private carrier hauling its own non-hazardous goods. Subpart A also excludes non-hazardous freight in vehicles under 10,001 lbs GVWR, but a for-hire carrier with operating authority whose fleet includes only vehicles under 10,001 lbs must still file security of $300,000 under the operating-authority rules (49 CFR 387.303T(b)(1)(i)). Non-bulk hazmat moving only intrastate is also outside them, except highway-route-controlled quantities of radioactive material.

The passenger minimums (49 CFR 387.27) apply to for-hire carriers of passengers in interstate or foreign commerce. They exclude school buses carrying only children and teachers, taxicabs seating fewer than 7 passengers that don't run a regular route, vehicles carrying fewer than 16 people on a single daily commute round trip, and contracted school extracurricular trips.

Property brokers are different: they don't carry these liability limits. Instead they need a $75,000 surety bond (Form BMC-84) or trust fund (Form BMC-85) (49 CFR 387.307).

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DOT Insurance Requirements by Vehicle Type

General Freight (Non-Hazmat)

GVWR under 10,001 lbs:

• Federal minimum: $300,000 for a for-hire carrier with operating authority whose fleet includes only vehicles under 10,001 lbs (49 CFR 387.303T(b)(1)(i)); none for a private carrier of its own non-hazardous goods
• State requirements: vary by state — California, for example, requires $300,000 for carriers that operate only vehicles under 10,000 lbs

GVWR 10,001 lbs or more (for-hire, interstate):

• Minimum required: $750,000 combined bodily injury and property damage liability
• Applies to: box trucks, straight trucks, tractor-trailers

Many shippers and brokers ask for $1,000,000 in their contracts, but that is a commercial requirement, not a federal one.

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Hazardous Materials

The hazmat minimums split into two tiers, and a placard alone does not put you in the top one:

$5,000,000 (49 CFR 387.9, entries 2 and 4):

• Hazardous substances (as defined in 49 CFR 171.8) carried in bulk in cargo tanks, portable tanks or hopper-type vehicles
• Division 1.1, 1.2 or 1.3 explosives in bulk
• Division 2.1 or 2.2 gases in bulk (a bulk propane load, for example)
• Division 2.3 Hazard Zone A, or Division 6.1 Packing Group I Hazard Zone A, material in bulk
• Highway-route-controlled quantities of radioactive (Class 7) material
• In vehicles under 10,001 lbs: the bulk Division 1.1–1.3, 2.3 Zone A and 6.1 PG I Zone A materials and highway-route-controlled radioactive material

$1,000,000 (entry 3):

• Oil listed in 49 CFR 172.101
• Hazardous waste, hazardous materials and hazardous substances not covered by the $5 million entries

These apply to for-hire and private carriers, interstate in any quantity, and intrastate in bulk.

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Passenger Vehicles

Seating 15 or fewer, including the driver: $1,500,000 — vans, shuttles, small buses operated for hire in interstate commerce

Seating 16 or more, including the driver: $5,000,000 — buses, motorcoaches, charter buses

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Required Filings and Documentation

The MCS-90 endorsement (Form MCS-82 if bonded)

• An endorsement attached to your liability policy that guarantees the federally required public-liability protection
• Required as proof of financial responsibility under 49 CFR 387.7(d); you keep it at your principal place of business
• A surety bond instead of insurance uses Form MCS-82
• Insurer and carrier must give each other 35 days' written notice before cancelling (49 CFR 387.7(b))

The BMC-91 / BMC-91X certificate (for operating authority)

• The certificate of insurance your insurer files with FMCSA for a for-hire carrier's operating authority (49 CFR 387.313)
• BMC-91X is used where coverage is aggregated across several insurers
• No for-hire carrier may operate in interstate commerce until this security has been filed and accepted (49 CFR 387.301)
• The insurer can't cancel it until 30 days after it files a notice of cancellation (Form BMC-35) with FMCSA

Household goods carriers must also file cargo insurance (Form BMC-34).

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USDOT Number and Operating Authority (MC Number)

USDOT number: identifies the carrier for safety monitoring and inspections; interstate operators of commercial motor vehicles need one.

Operating authority (MC number): required for for-hire carriers in interstate commerce.

Process:

1. Register with FMCSA and apply for operating authority (the registration fee is $300, 49 CFR 360.3(f))
2. FMCSA publishes a summary of the application in the FMCSA Register so that anyone can oppose it
3. Within 90 days of publication, your insurer files the BMC-91/91X and you (or your process agent) file the BOC-3 designation of process agents (49 CFR 365.109)
4. Authority is granted after the protest period, once the insurance and BOC-3 filings are on record
5. Keep the MCS-90 endorsement with your records

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Types of Commercial Trucking Insurance

Primary Liability (Required)

This is the coverage the federal minimums apply to — see commercial truck insurance requirements for how it fits with the rest of a trucking program.

What it covers:

• Bodily injury to others
• Property damage to others
• Legal defense costs
• Settlements and judgments

Limits: at least $750,000 to $5,000,000, depending on cargo, vehicle and passengers

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Cargo Insurance

What it covers:

• Damage or loss of freight you're hauling
• Customer's goods in your possession
• Loading/unloading damage

Federal requirement: only for household goods carriers (49 CFR 387.301(b)) Broker/shipper requirement: very commonly required by contract

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Physical Damage

What it covers:

• Your truck and trailer
• Collision damage
• Comprehensive (theft, fire, weather)

Federal requirement: none Lender requirement: usually required if financed

Coverage types:

• Stated value: agreed-upon value
• Actual cash value: current market value

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Bobtail/Deadhead Insurance

What it covers:

• Liability when driving the tractor without a trailer
• Gaps between loads

Motor carriers commonly require it of leased owner-operators.

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Non-Trucking Liability (NTL)

What it covers:

• Personal use of a leased truck
• Time when you are not under dispatch

Who needs it: owner-operators leased to motor carriers, usually as a lease requirement.

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DOT Requirements for Owner-Operators

Owner-operators have two options:

Option 1: Operate Under Your Own Authority

Requirements:

• Obtain a USDOT number and operating authority
• Insurance at the federal minimum for your cargo, with the BMC-91/91X filed and the MCS-90 on your policy
• A BOC-3 process-agent filing
• Fuel tax (IFTA) and Unified Carrier Registration (UCR) obligations

Best for: established operators with consistent freight

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Option 2: Lease to a Motor Carrier

Typical arrangement:

• The motor carrier provides primary liability under its own authority
• You carry physical damage for your truck
• You carry non-trucking liability or bobtail coverage, and often occupational accident cover, as the lease requires

Best for: new operators, and those who want less administrative burden

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State vs. Federal Requirements

Intrastate vs. Interstate

Intrastate (within one state):

• Set by the state, not FMCSA — except hazmat, where the federal minimums reach intrastate bulk loads
• May use different limits and forms

Interstate (between states):

• FMCSA's federal minimums apply
• Operating authority required for for-hire carriers
• USDOT number required

Example: California requires intrastate carriers of property to carry at least $750,000 for vehicles of 10,001 lbs or more, and $300,000 if they operate only lighter vehicles (California Vehicle Code § 34631.5). New Jersey requires $1.5 million for New Jersey-based intrastate trucks of 26,001 lbs and over.

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Penalties for Operating Without Required Insurance

Federal penalties

Other consequences

• Personal liability for all damages the policy would have paid
• Lost loads: brokers and shippers check FMCSA's insurance records before tendering freight
• Future insurance cost: a lapse and any violations follow you into underwriting

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How Much Does DOT Insurance Cost?

There is no single price. Premiums depend on:

Carrier factors:

• New authority vs. established (new authorities usually pay more)
• Safety record and inspection history
• Claims history
• Operating radius (local vs. long-haul)

Cargo factors:

• Type of freight (general vs. hazmat)
• Required coverage limits

Driver factors:

• Driving experience and motor vehicle records

Fleet factors:

• Number, age and value of trucks

Ways to Reduce Premiums

1. Improve your safety record — fewer violations and crashes mean lower rates
2. Hire experienced drivers with clean records
3. Install safety equipment — dash cams and collision-avoidance systems
4. Limit operating radius where your business allows
5. Raise deductibles if you can afford them
6. Pay annually to avoid installment fees
7. Get several quotes, including from brokers who specialize in trucking
8. Check trucking associations for group programs

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How to Get DOT Insurance

Step 1: Determine your requirements

• Cargo type (general freight, oil, hazmat tier, passengers)
• GVWR of your vehicles
• Interstate vs. intrastate
• Your federal minimum, and any higher limit your customers require

Step 2: Register with FMCSA

• USDOT number
• Operating authority if you are for-hire ($300 registration fee)
• BOC-3 process-agent designation

Step 3: Get quotes from commercial trucking insurers or specialist brokers

Step 4: Purchase and file

1. Buy the policy with the MCS-90 endorsement
2. Your insurer files the BMC-91 or BMC-91X with FMCSA — within 90 days of your application's publication
3. Check that the filing shows on FMCSA's licensing and insurance records
4. Authority is granted once the protest period has passed and the filings are on record

Step 5: Maintain compliance

• Pay premiums on time — a cancellation notice goes to FMCSA 30 days before the filing ends
• Update the policy when adding or removing trucks
• Renew before expiration and watch your FMCSA filing status

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Frequently Asked Questions

What is the minimum insurance required by DOT?

$300,000 for a for-hire carrier whose fleet has only vehicles under 10,001 lbs; $750,000 for for-hire, non-hazardous freight in vehicles of 10,001 lbs or more; $1,000,000 for oil and most hazardous materials; $5,000,000 for the highest-risk hazardous materials; and $1,500,000 or $5,000,000 for for-hire passenger vehicles seating 15 or fewer, or 16 or more, including the driver.

Does all placarded hazmat require $5 million?

No. The $5 million tier covers specific bulk loads — hazardous substances in bulk tanks or hoppers, bulk Division 1.1–1.3 explosives, bulk Division 2.1, 2.2 and 2.3 (Zone A) gases, bulk 6.1 Packing Group I Zone A material — and highway-route-controlled radioactive material. Other hazardous materials and oil are $1,000,000.

Is the MCS-90 filed with FMCSA?

No. The MCS-90 is an endorsement on your policy, kept at your principal place of business as proof of coverage. What your insurer files with FMCSA for operating authority is the BMC-91 or BMC-91X certificate.

Do private carriers need the $750,000 minimum?

Not for non-hazardous freight. The $750,000 general-freight minimum applies to for-hire carriers. A private carrier hauling its own non-hazardous goods is outside the federal minimum, but any carrier hauling hazardous materials is covered.

What happens if my DOT insurance lapses?

Your insurer must give you 35 days' notice, and must file a cancellation notice (BMC-35) with FMCSA 30 days before the filing is cancelled. Without an accepted filing, a for-hire carrier may not operate in interstate commerce. Failing to maintain the minimums can bring a civil penalty of up to $21,114, with each day counted separately.

Do I need cargo insurance to get operating authority?

Only if you carry household goods. For other freight, cargo insurance is not federally required, but brokers and shippers very commonly require it.

What do freight brokers need?

A $75,000 surety bond (BMC-84) or trust fund (BMC-85), not motor-carrier liability limits (49 CFR 387.307).

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Key Takeaways

• Federal minimums run from $300,000 (for-hire fleets of only small vehicles) and $750,000 (for-hire general freight) through $1,000,000 (oil and most hazmat) to $5,000,000 (highest-risk hazmat and 16+ seat passenger vehicles)
• The MCS-90 stays on your policy; the BMC-91/91X is what your insurer files with FMCSA
• Private carriers of non-hazardous goods fall outside the federal minimum; hazmat carriers do not
• Brokers need a $75,000 bond or trust fund, not liability limits
• Operating without the required coverage risks penalties of up to $21,114, with each day a separate offense
• Cargo insurance is federally required only for household goods carriers
• States set intrastate rules: for example California's $750,000 and New Jersey's $1.5 million

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Important Disclaimer

This guide provides general information about DOT insurance requirements based on federal regulations (49 CFR Part 387). This is not legal or insurance advice. Requirements can change, and specific situations may have additional requirements.

Always verify current requirements with the Federal Motor Carrier Safety Administration (FMCSA) and your state DOT. Consult with a licensed commercial insurance professional and transportation attorney for advice specific to your operations.

Last verified: December 2025

Sources: 49 CFR 387.3, 387.7, 387.9, 387.15, 387.27, 387.33, 387.301, 387.303T (the operative text; § 387.303 suspended at 84 FR 51433, 30 Sep 2019), 387.307, 387.313; 49 CFR Part 386, Appendix B; 49 CFR 360.3 and 365.109; California Vehicle Code § 34631.5; New Jersey Department of Banking and Insurance Bulletin 24-07