Insurance Curator Keeping a carrier audit-ready means maintaining the right mix of insurance coverages, state and federal filings, and clean documentary proof. This checklist focuses on U.S. trucking and logistics insurance requirements — interstate (FMCSA-regulated) and intrastate (state-regulated) — and explains what documents, endorsements and filings carriers, brokers and shippers must track and produce.
Sources: FMCSA (general regulations and registration): https://www.fmcsa.dot.gov, Progressive Commercial (market guidance): https://www.progressivecommercial.com, and industry reporting (Insurance Journal): https://www.insurancejournal.com.
Quick summary (why this matters)
- Interstate carriers must meet FMCSA financial responsibility minimums and register with FMCSA (MC number and USDOT), and maintain federal-compliant insurance and documentation.
- Intrastate carriers follow state financial responsibility rules that can vary widely (California, Texas, Florida and New York have different cargo and liability thresholds and filing protocols).
- Brokers and shippers often contractually require higher limits and specific endorsements (additional insured, waiver of subrogation, primary & noncontributory).
- Failure to produce proofs (Certificates of Insurance, BMC-91/BMC-91X alternatives, state filings, required endorsements) leads to regulatory fines, broker deactivation, and claim exposure.
Interstate vs Intrastate — at-a-glance comparison
| Element | Interstate (FMCSA) | Intrastate (State) |
|---|---|---|
| Primary regulator | FMCSA / DOT | State DMV / Public Utilities Commission |
| Registration | Motor Carrier (MC) & USDOT | State-specific registration |
| Minimum primary liability (typical) | Starts at $750,000 for non-hazardous property; higher limits for certain hazmat loads (see FMCSA) | Varies by state — often equal or higher than federal minimums for specific commodities |
| Cargo coverage | Not federally required for some private-carriers; commonly required by brokers/contracts | State rules + contracts — many states expect cargo insurance |
| Financial responsibility filings | Proof-of-insurance filed in FMCSA portal; BMC alternatives (surety/trusts) for some operations | State SR-22/other forms per state rules |
| Common endorsements required | MCS-90 / MCS-90-like endorsements, additional insured, primary & noncontributory, waiver of subrogation | State-specific endorsements or named insured requirements per customer contract |
For FMCSA guidance visit: https://www.fmcsa.dot.gov
Required documents every carrier must maintain (baseline)
- USDOT number, MC number (if operating interstate for-hire)
- Certificate(s) of Insurance (COI) showing:
- Policy limits, effective dates, policy numbers
- Named insured and vehicles covered
- Required endorsements listed on COI
- Insurance policy declarations pages (primary liability, auto physical damage, cargo, general liability)
- MCS-90 endorsement or proof of state-required financial responsibility where applicable
- BMC-91 / BMC-91X alternatives documentation (surety bond or trust fund receipts) if required by brokers or states
- Driver qualification files, vehicle maintenance logs, IFTA/IRP, proof of registration
- Cargo loss control procedures and bill of lading forms
See how to prepare Certificates correctly: How to Prepare Certificates of Insurance for Carriers, Brokers and Shippers
Filings & proof of financial responsibility (what to file and where)
- FMCSA insurance filings: use the FMCSA Registration & Insurance portal for filing evidence of insurance for interstate operations.
- Brokers and shippers will often ask for:
- COI listing them as additional insured or certificate holder
- MCS-90 or state equivalent
- BMC-91 / BMC-91X alternatives (see note below)
- State filings: check each state DMV/Pub. Utilities Commission for intrastate carriers — requirements differ for cargo types (e.g., household goods, hazardous wastes).
For alternatives to BMC-91/BMC-91X and state filing details: State Filings and BMC-91/BMC-91X Alternatives: Proof of Financial Responsibility for Trucking
Required endorsements and common endorsement wording
- MCS-90 (or equivalent) — obligates the insurer to pay final judgment up to limits for public liability claims arising from transporting interstate;
- Additional Insured (AI) — often required by brokers/shippers; wording must state AI status is “primary and noncontributory” when contractually required;
- Waiver of Subrogation — important for shippers requiring protection for loss recovery;
- Primary and Noncontributory — insurer must pay before other policies;
- Severability of Interests — preserves coverage for individual drivers/operators on the policy.
Reference for typical endorsements and wording: Required Endorsements and Endorsement Wording Every Carrier Must Carry
How to prepare and issue a Certificate of Insurance (COI) — practical steps
- Pull the policy declarations page and endorsements.
- Ensure the COI lists:
- Carrier name exactly as on policy
- Policy number(s), effective/expiry dates
- Limits per coverage (Auto Liability, Cargo, Gen Liab, Workers’ Comp)
- Any endorsements required by the contracting party (AI, waiver, primary & noncontributory)
- Attach scanned copies of the endorsement pages (MCS-90, AI endorsement) when a broker or shipper requests proof.
- Use the broker’s or shipper’s required COI wording verbatim; if a state-mandated phrase is required, include it.
- Maintain a COI log (issue date, recipient, purpose) for audit trails.
A step-by-step COI guide: How to Prepare Certificates of Insurance for Carriers, Brokers and Shippers
Sample checklist — documents to have ready for brokers, shippers, and audits
- Valid USDOT and MC numbers (interstate)
- Certificate(s) of Insurance with current effective dates
- Policy Declarations for Auto Liability, Cargo, General Liability, Physical Damage
- Endorsements: MCS-90, Additional Insured, Primary & Noncontributory, Waiver of Subrogation
- Proof of surety bond/trust (when required by broker/customer)
- Driver qualification files and drug & alcohol program documentation
- Vehicle registration, IFTA, IRP as applicable
- Current safety rating and CSA snapshot
- Digital copies stored in a secure, searchable folder
For audit-readiness tips: Audit-Ready Insurance Documentation: Tips to Pass Regulatory and Customer Reviews
Pricing benchmarks and carriers (U.S. market examples)
Insurance pricing varies by equipment, commodities, driving history, radius, revenue, and state. Below are industry ballpark ranges (2024 market context). Use these as a starting point — obtain live quotes for accuracy.
| Coverage | Typical annual cost (single truck, U.S.) | Example providers |
|---|---|---|
| Primary Auto Liability ($1M limit) | $7,000 – $20,000+ | Progressive Commercial, Great West Casualty, Berkshire Hathaway Specialty |
| Cargo insurance ($100k limit) | $1,000 – $6,000 | Progressive, Great West |
| Physical damage (comprehensive & collision) | $2,000 – $10,000 | Progressive, Berkshire Hathaway |
| Occupational/Workers’ Comp | Depends on payroll & classification | Local carriers, national markets |
Notes:
- Owner-operators with clean records often see lower-end premiums ($6k–$10k for liability), while high-risk fleets (tanker, hazmat, longhaul with poor CSA) may exceed $20k per truck annually.
- Progressive Commercial publishes market guidance and quote capability at https://www.progressivecommercial.com.
- Specialty trucking insurers such as Great West Casualty (part of Great West) and Berkshire Hathaway Specialty are common carriers for trucking risks. Industry reporting on premium trends is available at Insurance Journal: https://www.insurancejournal.com.
State examples:
- Texas and Florida often have competitive renewable markets but can show higher cargo theft exposure for certain lanes.
- California (CA) often requires stricter compliance and may have higher premiums due to regulatory and claim frequency.
- New York (NY) tends to have higher auto-liability and physical-damage costs in urban modes.
State-specific notes (TX, CA, FL, NY)
- Texas: Intrastate permitting and filings handled by Texas Department of Motor Vehicles; confirm cargo and liability limits for household goods and hazardous materials.
- California: Strict intrastate consumer protection for household goods; frequent audits; carriers often need higher limits and clearly documented endorsements.
- Florida: Seasonal freight flows increase exposure; ensure cargo and theft coverage during peak periods.
- New York: Urban exposure increases physical damage and liability frequency; insurers price accordingly.
Always check the state DOT or PUC website for current intrastate filing requirements.
Best practices to avoid common compliance gaps
- Keep COIs current — automate renewals and delivery to key brokers and shippers.
- Store endorsements (MCS-90, AI wording) as PDFs and attach them to COI requests.
- Review customer contracts for specific insurance language — don’t assume standard COI wording is sufficient.
- Run quarterly internal audits against the sample checklist above and track expirations.
- If you receive a state or FMCSA demand (MCS-90 or state financial responsibility), consult your insurer and legal counsel immediately.
For handling endorsement demands and MCS-90 responses: Responding to MCS-90 and State Financial Responsibility Demands in Trucking Insurance Claims
Closing checklist (action items)
- Verify your carrier’s FMCSA filings and insurance evidence are current.
- Confirm contractually required endorsements and exact wording before hauling.
- Maintain a searchable digital library of COIs, endorsements and policy dec pages.
- Get quotes from multiple carriers (Progressive Commercial, Great West, Berkshire Hathaway Specialty) and evaluate coverage and pricing tradeoffs.
For deeper guidance on FMCSA compliance and insurance requirements, see: FMCSA Insurance Requirements Explained for Trucking and Logistics Insurance Buyers.