META DESCRIPTION: Learn what FMCSA insurance filings prove, how BMC-91 and BMC-91X work, and why a filing is not the same as reviewing a trucking policy.
What Does an FMCSA Insurance Filing Prove for an Arizona Trucking Company?
You’re getting a trucking business ready to operate, and someone asks whether your insurance is filed with the FMCSA.
You already have an insurance certificate. Isn’t that enough?
Not necessarily.
For motor carriers that require federal operating authority, an FMCSA insurance filing is a formal record of required financial responsibility submitted to the federal agency by an authorized insurance or financial-responsibility provider. It serves a different purpose from an ordinary certificate of insurance.
Understanding the distinction can help Arizona trucking operators avoid delays and identify questions to ask before accepting a load.
Why Does FMCSA Require Insurance Filings?
The Federal Motor Carrier Safety Administration establishes financial-responsibility requirements for certain motor carriers, brokers and freight forwarders.
For entities applying for operating authority, FMCSA requires the applicable proof of financial responsibility to be on file before authority is granted.
The requirements depend on factors such as the type of operation, cargo, vehicle and operating authority. They are not identical for every trucking business.
FMCSA also requires registered entities to maintain applicable filings to avoid proceedings that could revoke their operating authority.
What Are BMC-91 and BMC-91X?
BMC-91 and BMC-91X are forms used to provide evidence of motor carrier bodily injury and property damage liability insurance to FMCSA.
The insurance provider, rather than the trucking company, makes the required filing.
These forms should not be confused with the certificate of insurance a customer or broker might request for its own records.
FMCSA explains the filing process in its insurance filing requirements.
Does the Filing Prove That Every Possible Loss Is Covered?
No.
An FMCSA filing establishes evidence of the financial responsibility required for the relevant federal authority. It is not a substitute for reviewing the actual insurance policy.
A trucking company’s coverage can involve separate questions about cargo, physical damage to its own trucks, trailers, deductibles, exclusions, drivers and particular operations.
A filing also doesn’t establish that a particular shipment meets every insurance requirement imposed by a broker or shipper.
How Much Liability Insurance Does FMCSA Require?
There is no single minimum that applies to every motor carrier.
FMCSA’s published filing chart identifies, for example, a $750,000 bodily injury and property damage requirement for certain for-hire carriers of nonhazardous property using vehicles with a gross vehicle weight rating of at least 10,001 pounds.
Other operations have different requirements. Certain hazardous-materials operations may require $1 million or $5 million, depending on the materials and applicable rules.
These are federal financial-responsibility requirements for specified operations, not a universal recommendation about how much coverage a trucking company should purchase.
Contracts and the actual risks of an operation may call for different limits. Verify the applicable category rather than assuming another carrier’s number applies to your business.
What About Cargo Insurance?
Liability for bodily injury and property damage is different from coverage for freight being transported.
FMCSA’s filing chart distinguishes public liability requirements from cargo filing requirements. For example, it identifies federal cargo-insurance filing requirements for certain household-goods carriers.
A general-property carrier should not conclude that its freight is adequately insured merely because its FMCSA public-liability filing is active.
Review cargo coverage separately, including the commodities transported, limits, exclusions and contractual obligations.
What Is the MCS-90 Endorsement?
The MCS-90 is a federal endorsement associated with motor carrier public liability requirements.
It has a specific regulatory purpose and should not be treated as an ordinary promise that every accident or loss involving the business is covered under its commercial auto policy.
FMCSA identifies the MCS-90 among its relevant insurance and endorsement forms. Its application can be legally complex, so questions about a particular claim or policy should be reviewed with a qualified insurance or legal professional.
Who Files the Insurance Paperwork?
The trucking company does not ordinarily submit its own BMC-91 or BMC-91X filing.
FMCSA states that the insurance company or another authorized financial-responsibility filer must submit the applicable forms electronically.
That makes accurate business information important. A mismatch between the business information used for operating authority and the information supplied for the filing can delay the process.
When arranging coverage, confirm that the insurer has the correct legal business name, address and identifying information for the authority application.
Can I Operate as Soon as I Buy the Policy?
Don’t assume purchasing a policy automatically means the required federal operating authority has been granted.
For an applicant that requires operating authority, FMCSA must receive the applicable filings and complete the relevant registration process.
Check the actual status of the authority rather than relying on a payment receipt or a newly issued certificate of insurance.
What Happens If the Filing Is Canceled?
An active insurance policy and the required filing need to be managed carefully.
FMCSA states that registered entities are responsible for maintaining required filings and that failure to do so can lead to revocation proceedings.
If you change insurers, renew coverage or restructure the business, confirm that the necessary filings remain in place. A lapse can create an operating-authority problem even if the company believes its insurance paperwork is otherwise in order.
What Should an Arizona Trucking Owner Review?
Before relying on an insurance filing, confirm the type of operating authority, the cargo carried and the vehicles used.
Then review the federal financial-responsibility requirement that applies to that operation. Separately review the commercial auto policy, cargo coverage, physical damage coverage and any contractual insurance requirements.
Arizona-based operations also need to consider applicable state requirements. Federal filing requirements should not be mistaken for a complete summary of every insurance or registration obligation a business may have.
FMCSA Insurance Filing FAQs
Is a certificate of insurance the same as an FMCSA filing?
No. A certificate of insurance is commonly used to summarize policy information for another party. An FMCSA filing is submitted through the federal agency’s required process to establish applicable financial responsibility.
Can a trucking company file BMC-91 itself?
FMCSA states that the required insurance filing is made by the insurance company or another authorized filer, not by the motor carrier itself.
Does a BMC-91 filing prove cargo is insured?
No. BMC-91 concerns bodily injury and property damage liability. Cargo coverage should be reviewed separately.
Does every trucking company need the same insurance limit?
No. Federal requirements vary by operation, vehicle and cargo. Contractual requirements can also differ from federal minimums.
Does an active insurance filing mean I have operating authority?
Not by itself. Confirm the actual authority status with FMCSA. Insurance filings are one part of the applicable registration process.
Verify the Filing and the Coverage
An FMCSA filing answers a specific regulatory question. It doesn’t answer every question about the insurance protecting your trucks, drivers, cargo and business.
For an Arizona trucking operation, review both the filing status and the underlying policies before assuming a certificate or an insurance payment settles the matter.
AZ Insurance Agency lists commercial auto and other business insurance among its products. Visit its agency page or contact page for product inquiries, and confirm state licensing and availability for your operation.