Insurance Curator Proving financial responsibility is a daily operational and compliance requirement for motor carriers, brokers and shippers operating in the United States. Federal filings like the BMC-91/BMC-91X are the standard channel for carriers to demonstrate liability coverage to the FMCSA — but there are state-level alternatives and compliance workarounds (especially for intrastate operations). This guide explains what BMC-91/BMC-91X do, federal minimums, practical state alternatives, estimated costs, and step-by-step preparation for issuing certificates and meeting audits.
Key federal requirements at a glance
-
Federal minimum liability levels for interstate motor carriers are set by regulation (49 CFR 387.9): $750,000 minimum for most property carriers; $5,000,000 for certain hazardous materials operations. See FMCSA guidance and the regulation:
-
The BMC-91 and BMC-91X are FMCSA insurance filing forms used by insurers or carriers to certify that required public liability insurance is in force. BMC-91X is the electronic variant used for insurer-to-FMCSA filings.
What BMC-91/BMC-91X actually do
- They provide the FMCSA and public proof that a motor carrier meets the financial responsibility standards required by statute and regulation.
- Filings are typically submitted by the insurer (or an authorized filing agent) to the FMCSA’s insurance database so the carrier can maintain active operating authority or satisfy state/contractual requirements.
- The filing ties a policy to a USDOT or MC number and specifies covered limits and policy term.
State filings and BMC-91/BMC-91X alternatives
Many carriers — particularly intrastate operators — rely on state-specific proof-of-financial-responsibility mechanisms. Alternatives include:
- State-mandated insurance filings (state DOT, DMV or public utilities commission registration).
- Surety bonds filed at the state level (or federal where accepted) in lieu of an insurer BMC filing.
- Trust agreements or trust funds approved by a state regulator for self-insured carriers.
- State financial responsibility certificates for motor carriers (some states accept certificates issued directly to the state).
- Self-insurance authority from state agencies (requires actuarial review, deposits, or collateral).
Example states and practical notes:
- California: Intrastate carriers register and provide financial responsibility documentation with the California DMV/PUC; many carriers file state certificates rather than national FMCSA insurer filings.
- Texas: The Texas Department of Motor Vehicles and Motor Carrier Division accept insurer filings and certain bonds for intrastate authority.
- New York & Florida: Both maintain requirements for intrastate carriers and accept bonds, proof of insurance, or state-specific forms depending on operation type.
Always verify state-specific forms and minimums with the state DOT or DMV because formats and acceptance of alternatives vary by state.
Costs: premiums, bonds and typical ranges (U.S. market)
Below are industry-typical ranges to budget — actual numbers depend on vehicle type, revenue, driver record, claim history, radius of operation and state exposure.
-
Commercial auto liability (single tractor-trailer, established carrier): $6,000–$20,000+ per year for primary liability depending on underwriting factors. (Market research and aggregate rate analyses—see ValuePenguin overview for commercial truck insurance cost trends.)
- Source: ValuePenguin industry data on commercial truck insurance: https://www.valuepenguin.com/commercial-truck-insurance-cost
-
BMC-91/BMC-91X insurer filings: no standardized fee by FMCSA — the cost is embedded in policy premiums. Insurers (e.g., Progressive Commercial, Berkshire Hathaway specialty insurers) include electronic FMCSA filing as part of policy servicing.
- Example provider pages: Progressive Commercial Truck Insurance — https://www.progressivecommercial.com/truck-insurance/
-
Surety bonds (common BMC-91/BMC-91X alternatives or broker bonds):
- Typical surety companies: Travelers, Liberty Mutual Surety, The Hartford Surety and specialized national surety underwriters.
- Premium ranges: roughly 1%–5% of the bond amount for well-qualified applicants (credit-based). Example: for a $75,000 bond, expect annual premium in the $750–$3,750 range depending on credit and underwriting. Less-qualified applicants or start-ups can see higher rates.
- Note: exact percentages vary by surety and risk profile.
-
Cargo coverage: annual premiums often $400–$2,000+ depending on limits and commodities.
Important: the numbers above are typical ranges — obtain firm quotes from insurers or surety brokers (HUB International, Aon, and Marsh specialize in transportation placements).
Comparison table: BMC-91/BMC-91X vs state filings vs surety/trust
| Option | Who files | Typical cost signal | Pros | Cons |
|---|---|---|---|---|
| BMC-91/BMC-91X (FMCSA) | Insurer or filing agent to FMCSA | Embedded in commercial auto premium | National recognition, required for interstate authority, direct FMCSA linkage | Requires insurer participation; premium cost can be high |
| State insurance filing / certificate | Insurer to state DOT/DMV or carrier provides certificate | Part of policy premium or small state fees | Accepted for intrastate authority; may be simpler for local operations | State-by-state variability; may not satisfy federal contracts |
| Surety bond (state or federal acceptance varies) | Issued by surety company | Premium = % of bond (1–5% typical) | Lower upfront cash outlay than full insurance; fast filing | Does not provide defense/settlement funds like insurance; surety underwrites heavily |
| Trust or self-insurance | Carrier with state approval | High administrative cost; collateral required | Potential savings for large fleets | Requires approval, audits, collateral; not for small fleets |
How to prepare and issue compliant certificates and filings
Follow a repeatable workflow to be audit-ready:
- Confirm the applicable jurisdiction and the required form (FMCSA BMC-91/BMC-91X for interstate, or the state’s specific certificate for intrastate).
- Verify minimum limits — federal minimums via 49 CFR 387.9; state minimums from state DOT/DMV websites.
- Engage an insurer or surety:
- For insurance, request that the insurer submit the BMC-91X to FMCSA or the state filing as required.
- For surety, order the bond and confirm the recipient agency and filing method.
- Attach required endorsements (e.g., MCS-90 where required for federal liability insurance). See FMCSA/insurer guidance for exact wording.
- Issue a Certificate of Insurance (COI) to shippers, brokers, or contract counterparties. Include:
- Carrier legal name, MC/USBOT/FFD number and DOT number
- Policy number, insurer name, effective/expiration dates
- Limits and covered vehicles
- Statement of any excluded operations
- Record and archive filings (electronic and paper). Keep proofs of insurer filings, surety bonds and COIs centrally for audits.
For practical guidance on COIs and wording, see: How to Prepare Certificates of Insurance for Carriers, Brokers and Shippers.
Common pitfalls and how to avoid them
- Missing the FMCSA electronic filing or using the wrong form — always confirm insurer will transmit BMC-91X for FMCSA.
- Relying on a COI that lacks the carrier MC or DOT number, or missing the MCS-90 endorsement where required.
- Using a surety bond that is not acceptable to the state or contracting party — confirm acceptance in writing.
- Losing proof of filing before audits — maintain an audit-ready digital folder (policies, BMC filings, COIs and endorsements). See: Audit-Ready Insurance Documentation: Tips to Pass Regulatory and Customer Reviews.
Who can help: vendors and typical pricing examples
- Insurance carriers: Progressive, Nationwide, Travelers — Progressive’s commercial truck insurance program is widely used by small fleets and owner-operators; expect single-truck liability quotes often in the $6k–$12k/year range depending on profile. (Market averages cited by industry cost analyses.)
- Surety providers: Travelers Surety, Liberty Mutual Surety, The Hartford — premium typically 1–5% of the bond amount for qualified applicants.
- Brokers & specialty wholesalers: HUB International, Aon, Marsh — offer placement, BMC filings, and bond sourcing. Fees vary by broker and scope of services.
Action checklist for carriers operating in California, Texas or New York (example)
- Verify whether operation is interstate or intrastate.
- If interstate: ensure insurer will submit BMC-91X to FMCSA and include MCS-90 endorsement if applicable.
- If intrastate (e.g., CA/TX/NY): confirm the state’s accepted proof (insurer filing, bond, or certificate) and upload/submit to the state portal.
- Request COIs that state MC/DOT numbers and list brokers/shippers as certificate holders when required.
- Keep digital copies of insurer BMC filings, bonds, and COIs for at least 4 years.
Final notes
Meeting proof-of-financial-responsibility requirements is both regulatory and contractual — take a proactive approach:
- Confirm applicable federal and state requirements early,
- Request insurer or surety to submit official filings (BMC-91X or state forms),
- Maintain organized records and up-to-date COIs.
For deeper regulatory background and required wording for endorsements and certificates, see:
- FMCSA Insurance Requirements Explained for Trucking and Logistics Insurance Buyers
- Compliance Checklist: Documents, Filings and Coverages for Interstate and Intrastate Carriers
External references:
- FMCSA — Insurance Requirements: https://www.fmcsa.dot.gov/registration/insurance-requirements
- 49 CFR 387.9 — Minimum levels of financial responsibility: https://www.ecfr.gov/current/title-49/part-387/subpart-B/section-387.9
- Commercial truck insurance cost overview (industry averages): https://www.valuepenguin.com/commercial-truck-insurance-cost