Shuttle service insurance
A business starting a shuttle service needs a commercial auto policy written for passengers, and its required limit turns on routes and seats. The Utah Insurance Department says an un-endorsed personal auto policy does not cover passengers for hire. FMCSA counts a carrier as for-hire whether paid directly or indirectly, and 49 CFR 387.33T sets $1,500,000 for an interstate vehicle seating 15 or fewer, driver included, and $5,000,000 at 16 or more. Salt Lake City Code 5.71.140 applies the federal passenger levels on city streets, fare or no fare, and Utah Code 31A-22-305(5)(b) requires $25,000/$500,000 uninsured motorist coverage.
What insurance do you need when starting a shuttle service?
A new shuttle service needs a policy naming passenger transport, because the Utah Insurance Department says un-endorsed personal policies do not cover passengers for hire. The department's business-use page, read October 12, 2026, says "your un-endorsed personal auto policy does not cover you if you transport passengers for hire (public livery)." Utah Code 31A-22-304 sets $30,000 per person, $65,000 per accident and $25,000 for property damage on a motor vehicle liability policy issued or renewed on or after January 1, 2025, and Utah Code 31A-22-305(5)(b)(i), effective May 6, 2026, requires anyone "engaged in the business of, or that accept payment for, transporting natural persons by motor vehicle" to carry uninsured motorist coverage of at least $25,000 per person and $500,000 per accident.
Is a free hotel or courtesy shuttle still a for-hire passenger service?
A free shuttle can still be for-hire carriage under FMCSA's guidance, because compensation counts whether it comes from the rider or from someone else. FMCSA's page on licensing and insurance for for-hire passenger carriers, last updated July 31, 2019, says "You can be a for-hire passenger carrier regardless of whether: You are compensated directly or indirectly for the transportation service provided; The compensation is paid or not paid by the passengers; or You have a non-profit status."
Salt Lake City Code 5.71.010 treats a vehicle as a ground transportation vehicle whether or not a fare is collected, and separately defines courtesy and hotel vehicles by whether a separate charge is made. The code's ground transportation vehicle carries people on city streets "for commercial purposes, regardless of whether a fee or fare is collected," and its courtesy vehicle carries customers "without making a specific separate charge to the passenger for such transportation."
Tell the insurer how each ride is paid for: a fare, a contract with a hotel, venue or employer, or a ride bundled free with another service; an application that leaves payment out describes a different operation.
| How the ride is paid for | FMCSA's for-hire guidance | Salt Lake City Code 5.71.010 |
|---|---|---|
| Riders pay a fare per trip or per seat | For-hire: compensated directly | Ground transportation vehicle |
| A hotel, venue or employer pays the shuttle company | For-hire: compensated indirectly, not by the passengers | Ground transportation vehicle; a hotel vehicle when run for a lodging business and riders pay a separate fare |
| The ride comes free with a room, ticket or purchase | The test is compensation, direct or indirect; a rider paying nothing does not settle it | Ground transportation vehicle; a courtesy vehicle when there is no separate charge |
Whose insurance rules apply to an airport, city or out-of-state shuttle route?
A shuttle's routes decide whose insurance rule applies: FMCSA for interstate trips, Salt Lake City on city streets, the airport for airport pickups, and Utah for the rest.
Tell the insurer every route and stop, because each holder sets its own requirement; the table pairs each route with its holder, and the list after it quotes each holder's rule:
| Where the shuttle runs | Whose rule applies | What to tell the insurer |
|---|---|---|
| Across a state line, or a Utah trip that starts or ends outside Utah (49 CFR 390.5T(3)) | FMCSA, 49 CFR 387.27(a) | Which routes leave Utah and where riders' journeys start or end |
| Salt Lake City streets | Salt Lake City Code 5.71.140 | Pickups and drop-offs inside city limits |
| Salt Lake City International Airport | Salt Lake City Department of Airports | Whether the shuttle serves the airport |
| One daily commute round trip carrying fewer than 16 workers | Outside the federal limits, 49 CFR 387.27(b)(3) | Who rides and how many trips run each day |
| Elsewhere inside Utah only | Utah; the for-hire passenger figure is open | Each vehicle's seats and weight |
- FMCSA: 49 CFR 387.27(a) applies the federal passenger limits to "for-hire motor carriers transporting passengers in interstate or foreign commerce," and 49 CFR 390.5T(3) counts a trip "Between two places in a State as part of trade, traffic, or transportation originating or terminating outside the State or the United States" as interstate.
- FMCSA's exception: 49 CFR 387.27(b)(3) leaves out of the federal limits "A motor vehicle carrying less than 16 individuals in a single daily round trip to commute to and from work."
- Salt Lake City: Salt Lake City Code 5.71.140(A) requires every ground transportation vehicle on city streets to carry the levels of 49 CFR 387.33, UDOT or USDOT, "whichever levels are higher"; eCFR marks 387.33 suspended since January 14, 2017, and 387.33T prints the same figures in force.
- Salt Lake City International Airport: its ground transportation page, read October 12, 2026, says "Vehicle Insurance must be emailed or faxed to the Ground Transportation office by your insurance company or agent before scheduling an appointment."
- Utah: UDOT rule R909-1-3(1) adopts 49 CFR Parts 387 through 399 for intrastate commercial motor carriers under Utah Code 72-9-102(3), and R909-1-4 sets no figure for a for-hire passenger carrier; no source read says whether the federal passenger limits reach a shuttle running only inside Utah, so as of October 12, 2026 that figure is an open question.
How do seats, vehicle type and riders change what a shuttle policy must cover?
Seat count sets the federal limit, and more than 8 passengers for compensation makes an interstate vehicle a commercial motor vehicle under 49 CFR 390.5T. That definition covers a vehicle that "Is designed or used to transport more than 8 passengers (including the driver) for compensation," and Utah Code 72-9-102(3)(b)(i) makes a vehicle run only inside Utah an intrastate commercial vehicle when it "is designed to transport more than 15 passengers, including the driver." FMCSA's passenger page says "Minimum levels of financial responsibility are determined by highest seating capacity of a vehicle within a fleet," so give the insurer each vehicle's seating.
The Massachusetts CAR manual rates airport buses, shuttle buses and employer van pools as separate classes. The manual, effective March 1, 2026, defines an Airport Bus as "an automobile for hire that transports passengers between airports and other passenger stations, or motels," lists "courtesy buses, shuttle buses" under Bus Not Otherwise Classified, and gives van pools for employee commuting a class of their own. 49 CFR 387.27(b)(1) excepts "A motor vehicle transporting only school children and teachers to or from school" from the federal passenger limits, so say plainly when riders are school children, patients, employees or event groups.
What should a shuttle service's insurance policy include before the first ride?
A shuttle policy is ready for the first ride when its liability limit meets the highest rule its routes trigger and its paperwork matches each holder's requirement. 49 CFR 387.31(a) says no motor carrier shall operate a vehicle transporting passengers "until the motor carrier has obtained and has in effect" the federal minimums, so the policy is bound before the first interstate run. The policy and its paperwork carry four items:
- Liability at the highest limit any of the shuttle's routes triggers, and uninsured motorist coverage at the Utah Code 31A-22-305(5)(b)(i) passenger floor on every passenger vehicle
- For interstate for-hire work, proof kept at the principal place of business: 49 CFR 387.31(d)(1) names the Form MCS-90B endorsement issued by the insurer
- For interstate for-hire work, cancellation only on 35 days' written notice under 49 CFR 387.31(b)(1)
- For Salt Lake City streets and the airport, Salt Lake City Corporation as additional insured under Salt Lake City Code 5.71.140(D), on an airport certificate carrying 30 days' cancellation notice and an authorized agent's signature
What do you send to get a shuttle service quoted, and what happens next?
Redoubt reviews a shuttle service from six items: vehicles and seats, routes and riders, payment, shifts, drivers, and business details. Text the list below to Redoubt; we will say what can be bound now, what needs the carrier, and what to send back. Paid shuttle work is placed case by case; send us the vehicles, routes and who rides, and we'll tell you on the first call whether we can quote it.
- Each vehicle: type, year, make, model, seating with the driver, and value
- Who rides and where: hotel guests, airport travelers, event groups, employees, patients or school children, with the regular routes and stops
- How passengers pay: a fare, a contract with a hotel, venue or employer, or rides free with another service
- How many shifts each vehicle runs in a day
- Every driver: name, date of birth, license number and class, and age
- The USDOT number if the business has one, a paragraph on what the business does, and the date coverage has to start
Sources: 32
Does a shuttle service file Form MCS-150 with FMCSA?
A shuttle that is a motor carrier operating in interstate commerce does: 49 CFR 390.19T(a)(1) requires a motor carrier "conducting operations in interstate commerce" to file Form MCS-150, and 49 CFR 390.5T counts a vehicle carrying more than 8 passengers, driver included, for compensation as a commercial motor vehicle.
What does shuttle service insurance cost?
FMCSA's November 28, 2014 notice on financial responsibility relays its report to Congress: underwriting "is specific to individual motor carriers and there are no uniform pricing practices."
Where these answers come from
Each entry carries the exact words of the source so you can check it yourself. Forms, rules and carrier pages change; read the current version before acting.
- 1. Utah Insurance Department, Business Use Of Your Auto
“Please keep in mind that your un-endorsed personal auto policy does not cover you if you transport passengers for hire (public livery).”
insurance.utah.gov, accessed October 12, 2026 - 2. Utah Code 31A-22-304(2), motor vehicle liability minimums from January 1, 2025
“a policy issued or renewed on or after January 1, 2025, containing motor vehicle liability coverage may not limit the insurer's liability under that coverage below the following: (a) (i) $30,000 because of liability for bodily injury to or death of one person”
le.utah.gov, accessed October 12, 2026. (2)(a)(ii) sets $65,000 for two or more persons and (2)(a)(iii) $25,000 for property damage. - 3. Utah Code 31A-22-305(5)(b)(i), uninsured motorist coverage for passenger carriers
“All persons, including governmental entities, that are engaged in the business of, or that accept payment for, transporting natural persons by motor vehicle, and all school districts that provide transportation services for their students, shall provide coverage for all motor vehicles used for that purpose, by purchase of a policy of insurance or by self-insurance, uninsured motorist coverage of at least $25,000 per person and $500,000 per accident.”
le.utah.gov, accessed October 12, 2026 - 4. FMCSA, Licensing and Insurance Requirements for For-Hire Motor Carriers of Passengers, who is for hire
“You can be a for-hire passenger carrier regardless of whether: You are compensated directly or indirectly for the transportation service provided; The compensation is paid or not paid by the passengers; or You have a non-profit status.”
fmcsa.dot.gov, accessed October 12, 2026. A sentence and the list under it. The page prints "Last updated: Wednesday, July 31, 2019". - 5. FMCSA, Licensing and Insurance Requirements for For-Hire Motor Carriers of Passengers, fleet seating
“Minimum levels of financial responsibility are determined by highest seating capacity of a vehicle within a fleet operated by an interstate for-hire motor carrier of passengers.”
fmcsa.dot.gov, accessed October 12, 2026. The page prints "Last updated: Wednesday, July 31, 2019". - 6. Salt Lake City Code 5.71.010, definition of ground transportation vehicle
“GROUND TRANSPORTATION VEHICLE: Any motor vehicle used for the transportation of persons using Salt Lake City streets for commercial purposes, regardless of whether a fee or fare is collected.”
codelibrary.amlegal.com, accessed October 12, 2026. The section's history line reads Ord. 50-25, 2025 and Ord. 66-14, 2014. Applies inside Salt Lake City only. - 7. Salt Lake City Code 5.71.010, definition of courtesy vehicle
“COURTESY VEHICLE: Any motor vehicle regularly operated on Salt Lake City streets for transportation of customers and/ or baggage without making a specific separate charge to the passenger for such transportation.”
codelibrary.amlegal.com, accessed October 12, 2026. The same section defines a hotel vehicle (run for a lodging business, with a separate fee or fare), a van (6 to 12 passenger seats) and a minibus (16 to 24). Applies inside Salt Lake City only. - 8. Salt Lake City Code 5.71.140(A), insurance required
“Every ground transportation vehicle shall be covered by automobile liability insurance, when the vehicle is available for or being used for the transportation of persons using Salt Lake City streets for commercial purposes, at the minimum levels of coverage set forth by the federal motor carrier safety administration, 49 CFR 387.33, or by the Utah department of transportation, or by the United States department of transportation, whichever levels are higher.”
codelibrary.amlegal.com, accessed October 12, 2026. The ordinance cites the unsuffixed 49 CFR 387.33, which eCFR marks suspended; 387.33T prints the same figures. Applies inside Salt Lake City only. - 9. Salt Lake City Code 5.71.140(C) and (D), cancellation copies and additional insured
“Each ground transportation business shall send a copy of any notice of cancellation or reduction of insurance coverage to the department immediately upon such cancellation or reduction. D. Salt Lake City Corporation shall be named as an additional insured in all insurance contracts.”
codelibrary.amlegal.com, accessed October 12, 2026. Applies inside Salt Lake City only. - 10. Salt Lake City International Airport, Ground Transportation Operating Requirements, insurance sent before registration
“Vehicle Insurance must be emailed or faxed to the Ground Transportation office by your insurance company or agent before scheduling an appointment.”
slcairport.com, accessed October 12, 2026. The same page sets the airport's liability figures by seating capacity and links the certificate checklist; taxi-insurance owns those figures. - 11. Salt Lake City Department of Airports, Ground Transportation Certificate of Insurance Checklist, December 2023, additional insured
“Salt Lake City Corporation must be named as additional insured.”
slcairport.com, accessed October 12, 2026. The form names the certificate as the ACORD 25 and Salt Lake City Corporation as certificate holder, and sets $1,500,000 per occurrence on a Business Auto Coverage Form at 15 seats or fewer and $5,000,000 at 16 or more. - 12. Salt Lake City Department of Airports, Ground Transportation Certificate of Insurance Checklist, December 2023, cancellation
“Thirty Days’ notice of cancellation must be included.”
slcairport.com, accessed October 12, 2026. Same PDF, the Cancellation Paragraph line; the curly apostrophe is as the PDF prints it. - 13. Salt Lake City Department of Airports, Ground Transportation Certificate of Insurance Checklist, December 2023, authorized agent
“Certificate must bear the signature of an authorized agent.”
slcairport.com, accessed October 12, 2026. Same PDF, the Authorized Representative line. - 14. 49 CFR 387.27(a), applicability of the passenger carrier subpart, eCFR
“This subpart applies to for-hire motor carriers transporting passengers in interstate or foreign commerce.”
ecfr.gov, accessed October 12, 2026. No suspension note on 387.27. - 15. 49 CFR 387.27(b)(1), exception for school runs, eCFR
“The rules in this subpart do not apply to— (1) A motor vehicle transporting only school children and teachers to or from school;”
ecfr.gov, accessed October 12, 2026 - 16. 49 CFR 387.27(b)(3), exception for commuter round trips, eCFR
“A motor vehicle carrying less than 16 individuals in a single daily round trip to commute to and from work;”
ecfr.gov, accessed October 12, 2026 - 17. 49 CFR 387.33T, schedule of limits for for-hire passenger carriers, eCFR
“(a) Any vehicle with a seating capacity of 16 passengers or more, including the driver $5,000,000 (b) Any vehicle with a seating capacity of 15 passengers or less, including the driver 1,500,000”
ecfr.gov, accessed October 12, 2026. Table cells of the schedule, 83 FR 22877, May 17, 2018. The T section is the text eCFR prints in force; the unsuffixed section is marked suspended since January 14, 2017. - 18. 49 CFR 387.33, effective date note, eCFR
“At 82 FR 5307, Jan. 17, 2017, § 387.33 was suspended, effective Jan. 14, 2017.”
ecfr.gov, accessed October 12, 2026. The suspended 387.33(a) prints the same $5,000,000 and 1,500,000 figures as 387.33T. - 19. 49 CFR 390.5T, definition of interstate commerce, paragraph (3), eCFR
“Between two places in a State as part of trade, traffic, or transportation originating or terminating outside the State or the United States.”
ecfr.gov, accessed October 12, 2026. eCFR marks the unsuffixed 390.5 suspended indefinitely, again on July 21, 2026; 390.5T is the text in force. - 20. 49 CFR 390.5T, definition of commercial motor vehicle, paragraph (2), eCFR
“Is designed or used to transport more than 8 passengers (including the driver) for compensation;”
ecfr.gov, accessed October 12, 2026. The definition covers a vehicle used on a highway in interstate commerce to transport passengers or property; paragraph (3) adds more than 15 passengers not for compensation. - 21. Utah Code 72-9-102(3)(b)(i), definition of intrastate commercial vehicle, passengers
“is designed to transport more than 15 passengers, including the driver;”
le.utah.gov, accessed October 12, 2026. One of several alternative tests in 72-9-102(3) for a vehicle used for business, compensation, or profit only within Utah; (3)(b)(ii) adds more than 12 passengers at 13,000 pounds GVWR or more. - 22. Utah Admin. Code R909-1-3(1), adoption of federal regulations
“Parts 387 through 399, and Part 40, as amended by the Federal Register through June 22, 2023, are incorporated by reference, except for 49 CFR Parts 391.11(b)(1) and 391.49 as they apply to intrastate drivers only. Therefore, these requirements apply to a motor carrier as defined in 49 CFR Part 390.5, and intrastate commercial motor carriers as defined in Subsection 72-9-102(3),”
adminrules.utah.gov, accessed October 12, 2026. The sentence continues by excluding passenger vehicles designed for 12 or fewer passengers, driver included, under 13,000 pounds GVWR or GCWR; R909-1-3(4) sets a 21-year driver minimum for 16 or more passengers. The rule does not say whether 49 CFR 387 Subpart B limits then apply to intrastate passenger carriers. - 23. Utah Admin. Code R909-1-4, insurance for private intrastate or interstate motor carriers
“Each intrastate private motor carrier must have a minimum amount of $750,000 liability. (3) Each interstate and intrastate for-hire and private motor carriers transporting any quantities of oil listed in 49 CFR 172.101;”
adminrules.utah.gov, accessed October 12, 2026. Subsection (3) continues with hazardous waste, materials and substances at $1,000,000 and an MCS-90 endorsement; subsection (1) defines a private motor carrier as one transporting property or passengers by commercial motor vehicle that is not for-hire. The rule states no figure for for-hire passenger carriers. - 24. 49 CFR 387.31(a), passenger carriers, financial responsibility required, eCFR
“No motor carrier shall operate a motor vehicle transporting passengers until the motor carrier has obtained and has in effect the minimum levels of financial responsibility as set forth in § 387.33 of this subpart.”
ecfr.gov, accessed October 12, 2026. No suspension note on 387.31; its cross-reference is to the suspended 387.33, whose figures 387.33T prints. - 25. 49 CFR 387.31(b)(1), cancellation on 35 days' notice, 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 12, 2026 - 26. 49 CFR 387.31(d), where proof is kept, eCFR
“Proof of the required financial responsibility shall be maintained at the motor carrier's principal place of business.”
ecfr.gov, accessed October 12, 2026. Paragraph (d)(1) names the Form MCS-90B endorsement issued by an insurer; (d)(2) names the Form MCS-82B surety bond. - 27. CAR Commercial Automobile Insurance Manual, Section V, Airport Bus or Airport Limousine
“Airport Bus or Airport Limousine – an automobile for hire that transports passengers between airports and other passenger stations, or motels.”
commauto.com, accessed October 12, 2026. Commonwealth Automobile Reinsurers (Massachusetts residual market) Commercial Automobile Insurance Manual, Section V Public Transportation, effective 2026.03.01; Primary only for CAR's own class plan; a Utah insurer's class plan is its own. - 28. CAR Commercial Automobile Insurance Manual, Section V, Bus Not Otherwise Classified
“Bus Not Otherwise Classified – this classification includes buses that do not meet any of the prior definitions including, but not limited to, automobiles such as country club buses, cemetery buses, real estate development buses, courtesy buses, shuttle buses, and buses owned by or operated for day care centers.”
commauto.com, accessed October 12, 2026. Commonwealth Automobile Reinsurers (Massachusetts residual market) Commercial Automobile Insurance Manual, Section V Public Transportation, effective 2026.03.01; Primary only for CAR's own class plan; a Utah insurer's class plan is its own. - 29. CAR Commercial Automobile Insurance Manual, Section V, Van Pools
“Van Pools – an automobile of the station wagon, van, truck or bus type used to provide prearranged commuter transportation for employees to and from work and is not otherwise used to transport passengers for a charge.”
commauto.com, accessed October 12, 2026. Commonwealth Automobile Reinsurers (Massachusetts residual market) Commercial Automobile Insurance Manual, Section V Public Transportation, effective 2026.03.01; Primary only for CAR's own class plan; a Utah insurer's class plan is its own. - 30. 49 CFR 390.19T(a)(1), who files Form MCS-150, eCFR
“A U.S.-, Canada-, Mexico-, or non-North America-domiciled motor carrier conducting operations in interstate commerce must file a Motor Carrier Identification Report, Form MCS-150.”
ecfr.gov, accessed October 12, 2026. The T section is the text eCFR prints in force; the unsuffixed section is marked suspended since January 14, 2017. - 31. FMCSA, Financial Responsibility for Motor Carriers, Freight Forwarders, and Brokers, advance notice, November 28, 2014
“The insurance underwriting process is specific to individual motor carriers and there are no uniform pricing practices (other than limits that might be imposed by State regulations).”
federalregister.gov, accessed October 12, 2026. A finding of the report to Congress as the notice relays it. - 32. Redoubt, commercial auto insurance guide, what to send
“Text Redoubt the broker packet, the lender's insurance letter, the platform's upload screen or the renewal itself, with the vehicles and the date you need it by. We will say what can be bound now, what needs the carrier, and what to send back.”
www.redoubt.insure, accessed October 12, 2026
A limo, bus or shuttle operator has to meet a passenger-carrier limit
Limo, party bus and charter bus operators: the federal and Utah passenger limits and who writes the coverage.
Elsewhere on the site
A new shuttle service starts with its routes, riders and payment
Text Redoubt each vehicle's type, year, make, model, seating and value, who rides where, how they pay, each vehicle's shifts, every driver's name, date of birth, license number, class and age, any USDOT number, what the business does and the start date, and we will talk it through on the first call and say what needs the carrier and what to send back.
This is general insurance information, not legal advice or a coverage determination. The policy forms, the endorsements the carrier issues, and the requirement in writing from whoever is asking control.