How Aggregate Limits Work in Trucking Policies and When They Can Create Coverage Issues

Understanding aggregate limits and how they operate in trucking and logistics insurance is essential for fleet owners, brokers, and risk managers. Aggregate limits can silently consume policy capacity, leaving a trucking business exposed after multiple claims in a policy period. This article explains how aggregate limits work, where they commonly appear in trucking programs, real-world scenarios where they create problems, and practical strategies to plug coverage gaps without overpaying.

Key concepts: per-occurrence vs aggregate limits

• Per-occurrence (per-claim) limit: The maximum the insurer will pay for a single covered loss/event (e.g., $1,000,000 per accident).
• Aggregate limit: The maximum the insurer will pay over the entire policy period (usually 12 months) for a particular coverage or set of coverages (e.g., $2,000,000 policy aggregate for general liability).

Both limits can appear in trucking policies — and the interaction between them drives whether a program survives a year with multiple losses.

Sources and regulatory background:

• FMCSA rules require evidence of financial responsibility and mandate endorsements like the MCS-90 in many cases, which can affect how limits operate: https://www.fmcsa.dot.gov/regulations/mcs-90
• General consumer guidance on commercial auto insurance and limits from the NAIC: https://content.naic.org/consumer_commercial_auto.htm
• Market guidance on truck insurance costs and how liability exposures influence pricing (useful for budgeting): https://www.progressivecommercial.com/knowledge-center/articles/how-much-does-commercial-truck-insurance-cost/

Where aggregate limits commonly appear in trucking programs

• Commercial General Liability (CGL): Typically has a policy aggregate and a per-occurrence limit (e.g., $2,000,000 aggregate / $1,000,000 per occurrence).
• Commercial Auto Liability: Often written with per-occurrence limits rather than aggregates for auto liability, but some insurers or endorsements may impose aggregates for subsets (e.g., hired/non-owned autos).
• Motor Truck Cargo: Cargo limits often are written on a per vehicle or per occurrence basis and may also have a policy aggregate or per-loss sublimits (e.g., $100,000 per truck / $500,000 aggregate).
• Umbrella/Excess: Typically attaches over primary limits; umbrella policies often have their own aggregates or can be eroded by defense costs depending on wording.
• Pollution or environmental coverages: Frequently have low aggregate limits or sublimits that are consumed quickly by cleanup costs and defense.

How aggregate limits can create coverage issues — common scenarios

1. Multiple soft collisions or minor cargo losses

   • Several smaller claims over the policy year add up and exhaust a cargo or CGL aggregate, leaving the fleet unprotected for a catastrophic claim later.

2. One large liability claim plus defense costs

   • A large jury verdict plus insurer-paid legal defense costs can quickly eat into both per-occurrence and aggregate limits, especially if defense costs are outside the limit.

3. Silent depletions from defense and allocation

   • Some policies allocate defense costs inside the limit; bellwether cases with heavy defense spend reduce the available limit for settlements.

4. MCS-90 obligation

   • The MCS-90 endorsement (required by FMCSA for interstate carriers) guarantees payment of judgments up to the certificate limits. While MCS-90 isn’t a separate limit, it obligates the carrier and interacts with primary policy limits — an exhausted primary can create regulatory and financial exposure. See FMCSA guidance: https://www.fmcsa.dot.gov/regulations/mcs-90

5. Aggregate application across multiple coverages

   • An insurer may apply an overall policy aggregate that aggregates distinct coverages (e.g., a single combined aggregate for products/completed operations and general liability). This increases the chance of coverage exhaustion.

Example pricing context (U.S. market focus: Los Angeles, Houston, Miami)

Insurance pricing in trucking varies by vehicle type, commodity, radius, claims history and state legal environment. To give budgeting context (estimates based on market guidance and insurer published ranges):

• Progressive Commercial (owner-operators and small fleets) cites broad commercial truck insurance ranges—owner-operators often see $6,000–$25,000/year for liability-focused programs depending on exposures and limits. See Progressive guidance: https://www.progressivecommercial.com/knowledge-center/articles/how-much-does-commercial-truck-insurance-cost/
• Market examples by city (typical annual liability + cargo premium ranges for a single straight truck or small tractor in 2025 market conditions):
  • Los Angeles, CA: $10,000–$30,000+ (higher litigation environment, higher exposures)
  • Houston, TX: $8,000–$22,000
  • Miami, FL: $9,000–$24,000
• Larger fleets, hazardous materials, or long-haul OTR operations frequently pay much more; specialty insurers (Great West Casualty Company, Sentry) often underwrite fleets but pricing is account-specific.

Note: These are market-estimate ranges for budgeting. Actual quotes require underwriting review (driving records, cargo, industry, radius). Progressive and major regional underwriters like Great West are active in these markets.

Practical strategies to manage aggregate exposure and avoid underinsurance

• Prefer per-occurrence cargo limits or per-truck schedules rather than low policy aggregates whenever feasible. Per-truck scheduling can prevent one driver’s claim from depleting coverage for the whole fleet.
• Negotiate defense cost handling — insist that defense costs be outside the limit when possible to preserve limits for settlements.
• Purchase umbrella/excess layers with clear follow-form wording to extend per-occurrence limits after primary limits are exhausted. Review umbrella aggregates and whether they erode via defense or other coverages.
• Split aggregates by coverage — instead of a single combined aggregate, structure separate aggregates for CGL, cargo, and hired/non-owned to reduce cross-consumption.
• Buy higher aggregates selectively — if your freight profile shows moderate frequency but low-severity claims, prioritize higher aggregates on cargo and GL rather than blanket increased primary per-occurrence limits.
• Use deductible/co-insurance layers strategically** — higher deductibles lower premium and shift frequency risk to you, but ensure you have the cash-flow to meet deductibles if aggregates are near exhaustion.
• Monitor claims activity and trigger mid-term adjustments — if claims frequency spikes mid-policy, discuss increasing aggregates or adding an excess layer rather than waiting for renewal.
• Audit policy wordings annually to spot aggregate traps: exclusions with carve-outs, cross-class aggregates, and defense-inside-the-limit clauses. (See Audit Guide: Reviewing Policy Wordings to Plug Gaps Without Overpaying for Trucking Insurance: https://insurancecurator.com/audit-guide-reviewing-policy-wordings-to-plug-gaps-without-overpaying-for-trucking-insurance/)

Comparison: How different coverages typically handle aggregates

Red flags to watch in policy wordings

• “Per policy period” or vague aggregate definitions that could aggregate unrelated coverages.
• Defense costs included within limits (erodes limits for settlements).
• Blanket aggregates across cargo + GL + auto — increases depletion risk.
• MCS-90 interactions not clarified — could produce enforcement/regulatory exposure when primary limits are exhausted.

Next steps for fleet owners and brokers

• Request policy wordings and endorsements at renewal and have a coverage audit performed (internal or broker-led). Use the Audit Guide referenced above for a checklist: https://insurancecurator.com/audit-guide-reviewing-policy-wordings-to-plug-gaps-without-overpaying-for-trucking-insurance/
• Consider getting quotes from multiple carriers (Progressive Commercial, Great West, Sentry, regional specialists) and compare how they treat aggregates, defense costs, and excess attachment.
• If you rely on brokers or TPA arrangements, insist on clear placement memoranda that call out aggregates and per-occurrence limit treatment.

For deeper reading on related topics and endorsements that affect aggregates and exhaustion risk, see:

• Common Endorsements in Trucking and Logistics Insurance and When to Add Them
• The MCS-90 Endorsement: What It Does and Why It Matters for Trucking Insurance
• How to Choose Policy Limits That Balance Protection and Premiums for Trucking Fleets

Understanding aggregate behavior and designing a program with appropriate per-occurrence and aggregate choices (and excess layers where needed) prevents surprise coverage gaps and keeps fleets moving — without overpaying for protections you don’t need.