Commercial Truck Insurance Requirements (FMCSA + State Minimums) — 2026 Guide

Federal (FMCSA) Minimum Liability Requirements: The Baseline

FMCSA financial responsibility rules in 49 CFR Part 387 set minimum public liability limits for many for-hire interstate carriers, commonly starting at $750,000 CSL for general freight and increasing for hazmat and passengers.

When federal rules apply (interstate + for-hire)

FMCSA insurance requirements generally apply when you’re for-hire and operating in interstate commerce (crossing state lines, or hauling loads that are part of interstate commerce).

• Interstate + for-hire authority: expect FMCSA filings and minimums to apply.
• Intrastate-only: your state’s DOT/PUC/PSC rules may apply instead (and can be higher).
• Private carrier (hauling your own goods): can still have insurance requirements, but the filing/authority setup can differ.

Pro tip: Don’t confuse “10,001+ lbs triggers DOT stuff” with “insurance minimums are always the same.” Weight triggers some compliance rules, but insurance minimums are mainly driven by operation type and what you haul.

FMCSA minimum liability limits (quick table)

FMCSA liability is typically discussed as CSL (Combined Single Limit), meaning one total limit per accident for bodily injury plus property damage.

Reality check (owner-operator perspective): the cheapest legal minimum can cost you revenue if it blocks you from better broker freight. Many dispatchers won’t even send a rate confirmation if you’re under their limit.

Hazmat & Passenger Hauling: Higher Minimums (and Why)

Hazmat and passenger carriers often face $1,000,000–$5,000,000 federal liability minimums because claims can include multi-vehicle injuries, fires, environmental cleanup, and higher litigation severity than general freight.

Hazardous materials transport minimums

Hazardous material truck insurance minimums jump because the potential claim size jumps—fires, cleanup costs, shutdowns, and higher injury severity.

• Minimums are tiered: often $1M to $5M CSL based on hazmat class/commodity.
• Shippers commonly require higher than the legal minimum: plus specific documentation before tendering.
• Small paperwork mistakes become “no load” problems: one wrong assumption can turn into a refused pickup.

Scenario: hauling fuel is a different risk profile than hauling dry van general freight. Your insurance (and filings) need to match what you actually run, not what you plan to run someday.

Passenger carriers

Passenger operations carry different liability exposure, and if you’re moving people (especially 16+ passengers), minimum limits are higher and contracts often require limits above minimums plus very specific certificates.

Bottom line: passenger and hazmat are high-stakes categories—get limits, filings, and certificates reviewed before your first trip.

Commercial Truck Insurance Requirements by State: How to Check (and What Changes)

State rules can set higher intrastate minimum liability limits and require extra proof-of-insurance filings through agencies like a state DOT, PUC, or PSC, even when federal FMCSA minimums are lower.

Do states have higher requirements than federal?

Yes—some states require higher minimums for intrastate operations and/or require additional state-specific filings. Even if a state’s minimum matches the FMCSA baseline, brokers and shippers can still require higher limits as a condition of doing business.

• Higher intrastate liability minimums for certain vehicle classes or cargo
• Public utility / commission rules (PUC/PSC) for for-hire intrastate authority
• State-specific proof-of-insurance filings (varies by state and operation)

State comparison framework (use this table to stay organized)

Don’t rely on forum advice for compliance. Use a simple framework, then verify with the state agency and your agent.

How to verify your state requirements (quick checklist):

• Confirm whether you’re intrastate-only or interstate.
• Identify your authority type (for-hire, private, exempt, etc.).
• Check your state DOT/PUC/PSC site for “minimum financial responsibility” rules.
• Ask your agent/insurer: “What filings are required for my exact operation, and when will they post?”

Examples (how requirements and costs vary by state)

If you want state-specific cost context (which matters for budgeting your cost-per-mile), start here:

• Texas example: How Much Does Commercial Truck Insurance Cost in Texas?
• Florida example: How Much Does Commercial Truck Insurance Cost in Florida?

Required Filings & Endorsements Explained (BMC-91/91X, MCS-90, COIs)

FMCSA authority can be delayed or suspended if required proof-of-insurance filings (like BMC-91/BMC-91X) are missing, incorrect, or dropped, even when the underlying policy exists and premiums are paid.

What’s required vs what’s an endorsement

People use “filings” and “endorsements” like they’re the same thing, but they’re not.

BMC-91 vs BMC-91X (proof of liability filing)

Think of BMC-91/91X as “proof to the government that you have the liability coverage you’re required to carry.”

• BMC-91: typically used when one insurer provides the required coverage.
• BMC-91X: can apply when multiple insurers share the required coverage.

Business risk: if your filing isn’t correct or doesn’t post, you can be stuck in “not authorized” status—or face authority suspension—meaning no loads, no revenue.

MCS-90 (why it matters, when it’s required)

The MCS-90 endorsement is tied to federal financial responsibility and is designed as a compliance backstop to protect the public in certain required situations.

• MCS-90 is not “extra insurance you can rely on” the same way normal coverage works.
• It does not replace cargo coverage, physical damage, or correct limits for your actual operation.
• It does not fix a policy that doesn’t match your lanes/cargo/authority.

If you’re unsure whether you need it (or when it applies), ask for a written confirmation based on your authority, cargo, and lanes.

How the filing process works (step-by-step)

1. Buy the right policy (limits + operation match).
2. Your insurer files BMC-91/91X electronically (plus state filings if needed).
3. You confirm it posts (don’t assume—verify).
4. You maintain continuous coverage (non-pay cancellations can spike pricing later).

What to ask your agent (so you don’t get burned):

• “What filing(s) are required for my authority?”
• “When will they post—and how do I confirm?”
• “Can you issue COIs fast for brokers (additional insureds if needed)?”
• “If I add hazmat, reefer, or expand radius, what changes?”

For new authorities, this checklist helps you avoid delays: Start Your Trucking Company: 6 Steps to Prep Your FMCSA Authority Application.

Is Cargo Insurance Required for Commercial Trucks?

Cargo insurance is usually contract-required by brokers and shippers (often at $100,000 per truck) rather than mandated by a single nationwide legal minimum for every for-hire carrier.

Cargo insurance is often required to get loads and get paid, and requirements vary by authority type, commodity, and contract language.

• Liability covers injuries/damage to others.
• Cargo coverage helps keep one freight claim from wiping out your month.
• Many brokers want $100,000 cargo as a starting point.
• Reefer, high-value freight, and specialized shipments can require higher limits and tighter terms.

Common “gotchas” to review before you sign

• Unattended vehicle / theft exclusions
• Temperature-control requirements (reefer compliance and logs)
• Improper securement language (especially if you’re doing your own load checks)
• Commodity exclusions (electronics, pharmaceuticals, alcohol, etc.)

How Much Does Compliance Cost? Benchmarks + What Drives Your Premium

New authority insurance for one truck commonly budgets around $900–$1,800+ per month for primary liability plus cargo for general freight, while hazmat and tougher lanes can push premiums much higher.

National benchmark ranges (set expectations)

Commercial truck insurance pricing moves with loss trends, your operation, and your authority profile. These are ballpark ranges to help you budget (not a guarantee):

• New authority, 1 truck (general freight, OTR): often $900–$1,800+/month for primary liability + cargo (varies widely).
• Established authority, cleaner history: often improves, but still depends on lanes, radius, and claims.
• Hazmat: commonly higher due to limit requirements and severity risk.
• Hotshot (for-hire): can be cheaper than semi in some cases, but claims, radius, and new authority status can still hit hard.

The key point: the “minimum required” policy isn’t always the “minimum affordable” long-term—cheap coverage that causes rejections, cancellations, or uncovered losses gets expensive fast.

Top factors that change your cost

If you’re trying to control cost-per-mile, these levers typically move premiums:

• Driving history + violations
• DOT/CSA exposure and inspection outcomes
• Operating radius (local vs regional vs OTR)
• Cargo type (general freight vs hazmat vs reefer)
• Garaging location (theft and claim frequency matter)
• Truck value + physical damage deductible
• Authority age (new venture pricing is real)
• Payment history (lapses/non-pay cancellations spike rates)

For a deeper breakdown of rating factors, read Truck Insurance Costs 2025: What Affects Your Rates? and Truck Insurance Costs 2025: Your Guide to Rates & Savings.

Penalties for Not Meeting Requirements (and How to Avoid Getting Shut Down)

Missing required limits or letting your liability filing drop can trigger authority suspension and immediate load loss, because brokers and enforcement can see coverage and filing status in near real time.

Non-compliance isn’t just a fine. For an owner-operator, it’s usually a revenue stop.

What can happen when requirements aren’t met:

• Authority suspension (dead in the water)
• Roadside problems at the chicken coop (delays, inspections, and sometimes out-of-service depending on the issue)
• Lost loads due to expired/incorrect COIs
• Higher premiums and fewer options at renewal
• Personal asset exposure when a claim blows past limits or coverage doesn’t apply

Real-world failure scenarios we see

• Filing lapse: you paid late, insurer cancels, filing drops—brokers see it immediately.
• Wrong limit for hazmat: you book a higher-class load than your policy supports.
• Named insured mismatch: your authority is under one entity, policy is under another.
• Operation drift: you started local, then ran OTR or added a trailer type without updating the policy.

Prevention checklist (simple, effective)

• Set a renewal calendar + autopay where possible.
• Confirm filings posted (don’t assume).
• Keep COIs accessible on your phone (email + cloud folder).
• Update your agent when you change radius, cargo, trailer type, or driver setup.

Compliance impacts pricing long-term. This is why a clean record matters: DOT Record & Trucking Insurance: How a Clean Score Protects Your Margins. If you’re trying to save money without cutting corners, use Affordable Trucking Insurance: Save Without Losing Coverage and Top 5 Mistakes Truckers Make That Increase Insurance Costs — And How to Avoid Them.

The Logrock Difference: Insurance Built for Business Owners

Owner-operators and small fleets typically need coverage built around lanes, cargo, and filings, because a policy that’s “technically insured” can still fail broker requirements or authority activation if documentation isn’t right.

Logrock works with owner-operators and small fleets who don’t have time for paperwork surprises. We focus on what actually keeps your business running:

• Correct limits for your lanes and cargo (so you can book loads)
• Filing-ready setups (so your authority doesn’t stall)
• Fast COIs and clean documentation (so you’re not stuck at pickup)
• Practical guidance to control premiums without gambling coverage

This is commercial truck insurance as a business tool—not a checkbox.

Next Steps: Confirm Your Minimums, Then Build a Policy That Actually Gets You Loads

FMCSA minimums are a starting point, but state intrastate rules and broker contracts often set the real working requirement, so your policy must match your lanes, cargo, and authority type to avoid downtime.

Your next step is simple: confirm your operation type, confirm your cargo class, confirm your required filings, and keep coverage continuous—because downtime is what kills margins.

Related reading: Truck Insurance Costs 2025: Your Guide to Rates & Savings, Affordable Trucking Insurance: Save Without Losing Coverage, and DOT Record & Trucking Insurance: How a Clean Score Protects Your Margins.