BMC-91 filing
A BMC-91 is the certificate of insurance your liability insurer files with FMCSA to prove a for-hire motor carrier has the federal minimum of auto liability, $750,000 for non-hazardous freight in trucks of 10,001 pounds or more. You cannot file it yourself, and FMCSA will not grant the MC operating authority until it is on record. The BMC-91X is the same filing in a form that also allows several insurers to combine limits. The MCS-90 is a different document: an endorsement on your policy, kept at your principal place of business rather than filed with FMCSA as a certificate.
Updated . Written by Andre Beukers, principal at Redoubt, a commercial insurance agency in Salt Lake City, not a government office.
What is a BMC-91?
BMC-91 is FMCSA's form name for a motor carrier's bodily injury and property damage liability certificate of insurance. It is not a paper you hand to anyone. The insurer sends it to FMCSA, and it sits on the carrier's record in FMCSA's licensing and insurance system. The rule that requires it, 49 CFR 387.301T, says no common or contract carrier may operate in interstate commerce, and no operating authority may be issued or stay in force, "unless and until there shall have been filed with and accepted by the FMCSA" a certificate of insurance or other security in the required amounts.
The amounts are set in 387.303T and repeated in FMCSA's own filing chart. For-hire property carriers hauling non-hazardous freight need $750,000 in trucks of 10,001 pounds GVWR or more and $300,000 in lighter vehicles; certain hazardous materials need $1,000,000, and, in the chart's words, carriers of explosives, poison gas or radioactive materials $5,000,000. The chart lists the accepted forms for each as "BMC-91, or BMC-91X, or BMC-82," the last being a surety bond instead of insurance. There is no federal cargo minimum except for household goods movers, who file a BMC-34 on top.
Who needs a BMC-91 filing?
A for-hire motor carrier that applies for or holds interstate operating authority, the MC number. That covers owner-operators running under their own authority, small fleets, and anyone starting a new authority. The filing is what turns a pending MC application into an active one.
Three groups do not need one of their own. A private carrier hauling its own goods does not hold for-hire authority, so 387.301T's filing rule does not reach it, though the federal minimums still apply to hazardous materials carriers under 387.3, and FMCSA's chart lists private carriers of explosives, poison gas or radioactive materials with the same filing forms. A driver leased onto another carrier runs under that carrier's authority: federal lease rules require the lease to give the carrier "exclusive possession, control, and use of the equipment" and "complete responsibility for the operation" of the equipment while the lease runs. And a carrier that stays inside one state answers to that state's rules, which in some states means a Form E rather than a BMC-91; check yours.
Brokers file too, but not a BMC-91. Under 49 CFR 387.307, in effect since January 16, 2026, a property broker must have a $75,000 surety bond or trust fund, filed on Form BMC-84 or BMC-85.
What is the difference between BMC-91 and BMC-91X?
Both prove the same federal liability limit, and FMCSA accepts either for every carrier type in its chart. The difference is whether one insurer stands behind the whole amount. Under 387.313T, a BMC-91 is filed "for the full security limits." A BMC-91X may be filed "to represent full coverage or any level of aggregation," which is what you need when a primary policy and an excess policy from different insurers together reach the required limit; in that case each insurer files its own BMC-91X.
Whichever form your insurer uses, check that the filing is active, in your full and correct legal name, and for at least the limit your operation requires.
What is the difference between BMC-91 and MCS-90?
The BMC-91 is a filing; the MCS-90 is an endorsement. The BMC-91 goes from the insurer to FMCSA and is what gets your authority granted. The MCS-90 is attached to your auto liability policy, and under 49 CFR 387.7(d) it is the proof of financial responsibility "maintained at the motor carrier's principal place of business." What goes to FMCSA is the BMC-91 certificate itself; the MCS-90 stays in your records and must be produced on reasonable request. The form's own cancellation clause adds that a carrier subject to FMCSA registration must also give FMCSA 30 days' notice, transmitted online.
The MCS-90 also changes what the policy does. It obliges the insurer to pay a final judgment for public liability "regardless of whether or not each motor vehicle is specifically described in the policy." The same form provides that "The insured agrees to reimburse the company" for any payment it would not otherwise have owed under the policy, so if the insurer pays a judgment only because of the MCS-90, it can seek reimbursement from you.
A carrier needs both when it holds for-hire authority. A private carrier hauling regulated hazardous materials is held to the 387.7 minimums and the MCS-90 even though it holds no for-hire authority.
How do I get a BMC-91 filed, and how long does it take?
You buy a primary auto liability policy from an insurer that is registered as an FMCSA filer, and the insurer files. FMCSA's instructions put it this way: once an entity applies for operating authority, "a financial responsibility provider must file the appropriate insurance form(s) on behalf of the applicant." New applicants should have the policy ready to bind as soon as the docket number is assigned.
The clock is FMCSA's. If the filing is not on record within 20 days of the application's publication in the FMCSA Register, FMCSA serves a decision giving 60 days before the application is dismissed. FMCSA also warns that the name and address in the filing must match the authority application exactly, and that "any deviation results in the delay of granting of the authority." The insured name has to be the full legal name, with every partner named for a partnership. FMCSA publishes no figure for how long the filing takes to post. One carrier told Redoubt its wait for the filing took "anywhere from fifteen to twenty days."
Check two things first: that the name matches word for word across the policy, the secretary of state filing and the MC application, and, before you bind, that the insurer will file the BMC-91 or BMC-91X and how soon.
What is a Form E filing?
Form E is the state counterpart of the BMC-91. Its full title is the "Uniform Motor Carrier Bodily Injury and Property Damage Liability Certificate of Insurance," a uniform form determined by the National Association of Regulatory Utilities Commissioners. The insurer files it with a state commission to certify coverage for "the obligations imposed upon such motor carrier by the provisions of the motor carrier law of the State." The form itself says cancellation takes "thirty (30) days' notice in writing to the State Commission."
The obligations it certifies come from each state's own motor carrier law. Pennsylvania's Public Utility Commission, for example, says plainly that "ONLY insurance companies can provide the required forms to the Commission" and gives an applicant 60 days to get binding insurance proof filed before the application is dismissed. A carrier that holds both federal and state authority may need a BMC-91 with FMCSA and a Form E with its state. Check your state's motor carrier agency for whether it takes a Form E, an online filing, or neither.
Is a BMC-91 the same as a certificate of insurance for brokers?
No. The BMC-91 is a government filing that shows the federal minimum; it has no certificate holder and says nothing about cargo, general liability or a broker's name. A broker or shipper onboarding you will ask for an ACORD 25 certificate from your agent that meets its own carrier requirements, which can differ from the filing floor. That form describes itself as "issued as a matter of information only" and "confers no rights upon the certificate holder," so it reports the policy rather than replacing the filing. Buyers mix the two up; Redoubt has described the filing on calls as "sort of like a certificate of insurance, but a federally standardized one." You need the filing for the authority and the certificate for the loads.
What happens if the BMC-91 is cancelled?
The insurer or the carrier cancels by filing a BMC-35 notice with FMCSA, and the filing stays in force until 30 days after FMCSA actually receives it. Separately, the MCS-90 and the policy require 35 days' written notice between insurer and carrier. A replacement filing from a new insurer ends the old insurer's liability as of the replacement's effective date, which is how a carrier changes insurers without a gap. FMCSA's filing page says entities must keep proof of insurance on file "to avoid revocation proceedings," so a lapse with no replacement puts the authority at risk.
Can I file my own BMC-91?
No. Under 387.313T the BMC-91 and BMC-91X are certificates filed with FMCSA, and FMCSA's instructions say a financial responsibility provider files on the applicant's behalf. Your part is buying a policy from an insurer that makes federal filings and making sure your legal name matches.
How much does a BMC-91 filing cost?
FMCSA publishes no fee for the insurer's filing; the cost that matters is the auto liability policy behind it. We checked FMCSA's insurance filing requirements page and Part 387 and found no filing fee stated there.
Does the BMC-91 cover cargo?
No. It certifies bodily injury and property damage liability. Federal rules set no cargo minimum except for household goods carriers, who file a BMC-34. Cargo limits come from brokers and shippers, on a certificate.
Where these answers come from
Each entry carries the exact words of the source so you can check it yourself. Forms and statutes change; read the current version before acting.
- 1. 49 CFR 387.301T(a)(1), Surety bond, certificate of insurance, or other securities (eCFR)
“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”
ecfr.gov, accessed October 3, 2026. The unsuffixed 387.301 is suspended; the T section is the operative text. - 2. 49 CFR 387.3, Applicability of the minimum levels of financial responsibility (eCFR)
“This subpart applies to motor carriers operating motor vehicles transporting hazardous materials, hazardous substances, or hazardous wastes in interstate, foreign, or intrastate commerce.”
ecfr.gov, accessed October 3, 2026 - 3. 49 CFR 376.12(c)(1), lease requirements: exclusive possession and responsibilities (eCFR)
“The lease shall provide that the authorized carrier lessee shall have exclusive possession, control, and use of the equipment for the duration of the lease. The lease shall further provide that the authorized carrier lessee shall assume complete responsibility for the operation of the equipment for the duration of the lease.”
ecfr.gov, accessed October 3, 2026 - 4. FMCSA, Insurance Filing Requirements, filing chart (last updated December 5, 2025; Wayback copy of January 11, 2026)
“For-Hire Property Carriers (Non-Hazardous) GVWR ≥ 10,001 pounds $750,000 $0 $0 BMC-91, or BMC-91X, or BMC-82”
web.archive.org, accessed October 3, 2026. One table row read across: entity type, vehicle type, BIPD, cargo, bond, forms. fmcsa.dot.gov returns 403 to scripted requests, so the archived copy was used. - 5. FMCSA, Insurance Filing Requirements, who should file (Wayback copy)
“Once an entity applies for Operating Authority (MC/FF/MX), a financial responsibility provider must file the appropriate insurance form(s) on behalf of the applicant.”
web.archive.org, accessed October 3, 2026 - 6. FMCSA, Insurance Filing Requirements, 20-day and 60-day clocks (Wayback copy)
“If the entity fails to comply within 20 days from the date of publication in the FMCSA Register , an FMCSA decision will be served notifying the entity that their application will be dismissed unless they comply with the requirements within 60 days .”
web.archive.org, accessed October 3, 2026. Spacing before the commas and final period is as the page renders its bold runs. - 7. FMCSA, Insurance Filing Requirements, name and address match (Wayback copy)
“Registered entities are cautioned to ensure that the name and address of their business as set out in all pre-registration filings, such as secretary of state, match exactly the name and address provided in their application for operating authority filings. Any deviation results in the delay of granting of the authority .”
web.archive.org, accessed October 3, 2026 - 8. 49 CFR 387.313T(a)(3), use of certificates in the BMC series (eCFR)
“Form BMC 91 certificates of insurance will be filed with the FMCSA for the full security limits under § 387.303T(b)(1) or (2).”
ecfr.gov, accessed October 3, 2026 - 9. 49 CFR 387.313T(a)(3)(i) and (a)(2)(ii), BMC 91X and aggregation (eCFR)
“Form BMC 91X certificate of insurance will be filed to represent full coverage or any level of aggregation for the security limits under § 387.303T(b)(1) or (2).”
ecfr.gov, accessed October 3, 2026. 387.313T(a)(2)(ii) adds that for aggregation a separate endorsement and Form BMC 91X certificate is required of each insurer. - 10. 49 CFR 387.313T(b), filing and copies (eCFR)
“Certificates of insurance, surety bonds, and notices of cancellation must be filed with the FMCSA.”
ecfr.gov, accessed October 3, 2026 - 11. 49 CFR 387.313T(c), name of insured (eCFR)
“Certificates of insurance and surety bonds 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.”
ecfr.gov, accessed October 3, 2026 - 12. 49 CFR 387.313T(d) and (e), cancellation notice and termination by replacement (eCFR)
“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”
ecfr.gov, accessed October 3, 2026. The prescribed form is BMC-35 for insurance. Paragraph (e) ends the retiring insurer's liability as of the effective date of an accepted replacement certificate. - 13. 49 CFR 387.7(d), proof kept at the principal place of business (eCFR)
“Proof of the required financial responsibility shall be maintained at the motor carrier's principal place of business. The proof shall consist of”
ecfr.gov, accessed October 3, 2026. Item (1) of the list is the Form MCS-90 endorsement issued by an insurer. 387.7(e)(1) makes the proof public on reasonable request. - 14. 49 CFR 387.7(b)(1), continuous coverage and 35-day cancellation (eCFR)
“Cancellation may be effected by the insurer or the insured motor carrier giving 35 days' notice in writing to the other.”
ecfr.gov, accessed October 3, 2026 - 15. FMCSA, Form MCS-90, Endorsement for Motor Carrier Policies of Insurance for Public Liability (OMB 2126-0008; Wayback copy of FMCSA's PDF)
“the insurer (the company) agrees to pay, within the limits of liability described herein, any final judgment recovered against the insured for public liability resulting from negligence in the operation, maintenance or use of motor vehicles subject to the financial responsibility requirements of Sections 29 and 30 of the Motor Carrier Act of 1980 regardless of whether or not each motor vehicle is specifically described in the policy”
web.archive.org, accessed October 3, 2026. The same form adds: "The insured agrees to reimburse the company for any payment made by the company on account of any accident, claim, or suit involving a breach of the terms of the policy, and for any payment that the company would not have been obligated to make ..." - 16. Form E, Uniform Motor Carrier Bodily Injury and Property Damage Liability Certificate of Insurance, blank form hosted by the Montana Public Service Commission
“Such cancellation may be effected by the Company or the insured giving thirty (30) days' notice in writing to the State Commission, such thirty (30) days' notice to commence to run from the date notice is actually received in the office of the Commission.”
psc.mt.gov, accessed October 3, 2026. The form prints a curly apostrophe in days'. - 17. 49 CFR 387.307(a), Property broker surety bond or trust fund (eCFR, 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.”
ecfr.gov, accessed October 3, 2026. The same paragraph names Form BMC-84 for a surety bond and Form BMC-85 for a trust fund. Pulled live from eCFR. - 18. FMCSA, Form MCS-90 (Rev 7/6/2024), cancellation clause (Wayback copy of FMCSA's PDF)
“if the insured is subject to the FMCSA's registration requirements under 49 U.S.C. 13901, by providing thirty (30) days notice to the FMCSA”
web.archive.org, accessed October 3, 2026. The clause continues: "Filings must be transmitted online via the Internet at https://www.fmcsa.dot.gov/registration." The form prints a curly apostrophe in FMCSA's. - 19. Form E, certifying clause (Montana PSC copy)
“covering the obligations imposed upon such motor carrier by the provisions of the motor carrier law of the State in which the Commission has jurisdiction”
psc.mt.gov, accessed October 3, 2026 - 20. FMCSA, Insurance Filing Requirements, overview (Wayback copy)
“Once operating authority is granted, entities are required to maintain proof of insurance and designation of agents for process on file with FMCSA to avoid revocation proceedings.”
web.archive.org, accessed October 3, 2026 - 21. Form E, footer naming its origin (Montana PSC copy)
“This form determined by the National Association of Regulatory Utilities Commissioners”
psc.mt.gov, accessed October 3, 2026 - 22. Pennsylvania Public Utility Commission, Motor Carrier Insurance page
“Certificates of insurance are not binding and therefore are not acceptable. Motor Carriers are not able to provide binding proof of insurance to the Commission. ONLY insurance companies can provide the required forms to the Commission.”
puc.pa.gov, accessed October 3, 2026 - 23. Pennsylvania Public Utility Commission, Motor Carrier Insurance page, filing window
“A time period of 60 days is given to have binding insurance proof filed with the Commission. Applications will be dismissed when insurance agents do not arrange for this evidence to be filed in the allotted time period.”
puc.pa.gov, accessed October 3, 2026 - 24. ACORD 25 (2016/03), Certificate of Liability Insurance, blank form hosted by the New York Department of Financial Services
“THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER.”
dfs.ny.gov, accessed October 3, 2026 - 25. Redoubt call 9bf5360f, 2026-05-27, Redoubt explaining the FMCSA filing to a new carrier
“It's sort of like a certificate of insurance, but a federally standardized one”
Redoubt agency records, accessed May 27, 2026 - 26. Redoubt prospecting call export, VelocityLink Transport Corp, 2026-06-22, on the wait for its federal filing
“it took anywhere from fifteen to twenty days”
Redoubt agency records, accessed June 22, 2026. The carrier's own account of its wait, not an FMCSA figure.
FMCSA will not activate the authority without the filing
The insurer's BMC-91 filing that gates an MC number, and how it differs from a certificate.
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This is general insurance information, not legal advice or a coverage determination. The policy forms, the endorsements the carrier issues, and the holder’s written requirement control.