49 CFR Part 387 filing-path guide

BMC-91 and BMC-91X Motor Carrier Insurance Filings

Identify the public-liability filing lane, give the registered filer an exact entity match, and verify the federal record without confusing it with a policy endorsement, cargo form, broker bond, or BOC-3.

The carrier buys and maintains coverage; a registered financial responsibility filer submits BMC-91 or BMC-91X.

A policy document in the carrier’s files is not the same as proof currently on file with FMCSA.

Reviewed against current FMCSA, Motus, and eCFR materials on .

For-hire non-hazardous property, 10,001 lb GVWR or more

Give the docket and exact entity match to the registered filer immediately

Current FMCSA chart row
FMCSA’s current filing chart lists a $750,000 bodily-injury and property-damage public-liability minimum for a for-hire non-hazardous property carrier using vehicles with GVWR of 10,001 pounds or more.
Forms in that lane
The chart lists BMC-91, BMC-91X, or the BMC-82 surety-bond path. The registered filer must match the filing to the entity, docket, policy structure, and effective coverage.
Who acts and what they do
After FMCSA assigns the MC, FF, or MX docket, the applicant should contact its insurance or financial responsibility provider. A registered electronic filer—not the carrier applicant—submits BMC-91 or BMC-91X on the applicant’s behalf.
Boundary to preserve
The $750,000 chart row is not a universal recommendation or quote. Cargo, commodity, contract, State, shipper, lender, and hazardous-material requirements can be different or higher. FMCSA will not grant operating authority until the required financial responsibility is in effect and on file. BOC-3 is a separate process-agent filing, and applying or buying a policy does not itself authorize operations.
Verify before relying on authority
Match the legal name, business address, USDOT number, and docket exactly; then verify the filing and authority status in current FMCSA public systems before operating.
Open the current FMCSA source

Selections stay in this browser. Nothing is sent or stored. This guide does not quote coverage, choose a policy or filer, submit a filing, or determine authority status.

Current FMCSA filing chart

Match the operation before using a minimum

These are FMCSA’s current summarized federal filing minimums for the listed categories. They are not quotes or recommended limits. Verify the actual authority, vehicle, passenger capacity, commodity, material, quantity, and controlling Part 387 table.

FMCSA public liability filing minimum summary
Listed operationPublic liabilityApplicable filing laneSeparate form
For-hire non-hazardous property, GVWR under 10,001 lb$300,000BMC-91, BMC-91X, or BMC-82None in the chart row
For-hire non-hazardous property, GVWR 10,001 lb or more$750,000BMC-91, BMC-91X, or BMC-82None in the chart row
For-hire carrier of certain hazardous materials$1,000,000BMC-91, BMC-91X, or BMC-82Verify material category
Listed explosives, poison gas, or radioactive-material category$5,000,000BMC-91, BMC-91X, or BMC-82Verify current Part 387 table
For-hire household goods, GVWR 10,001 lb or more$750,000BMC-91, BMC-91X, or BMC-82$5,000 cargo via BMC-34 or BMC-83
For-hire passenger carrier, 15 or fewer passengers$1,500,000BMC-91, BMC-91X, or BMC-82None in the chart row
For-hire passenger carrier, 16 or more passengers$5,000,000BMC-91, BMC-91X, or BMC-82None in the chart row

Filing workflow

The provider files; the entity owns the exact match and ongoing status

  1. 1

    Classify the authority

    Identify motor carrier, passenger, household-goods, hazardous-material, broker, and forwarder roles independently.

  2. 2

    Match the entity

    Provide the registered filer the exact legal name, address, USDOT number, docket, and operation.

  3. 3

    File electronically

    The registered insurance, surety, or financial institution filer submits the correct form and effective structure.

  4. 4

    Verify the record

    Confirm the filing and authority in the current official system; escalate mismatches before operating.

Form map

Similar-looking documents do different jobs

BMC-91 / BMC-91X

Electronic public-liability certificate filing made with FMCSA by a registered financial responsibility filer. The current Motus supporting-company workflow distinguishes filing details, including a Primary or Excess option for BMC-91X.

MCS-90 / MCS-90B

Public-liability endorsement to the insurance policy. It is not the BMC certificate filed in the federal authority record and should not be used as proof that the filing posted.

BMC-34 / BMC-83

Separate cargo-insurance certificate or surety lane used where the FMCSA chart requires cargo proof, including the listed household-goods category.

BMC-84 / BMC-85 and BOC-3

BMC-84/85 supports broker or forwarder financial responsibility. BOC-3 designates process agents. Neither substitutes for a motor-carrier public-liability filing.

Current Motus lane

Use the live Motus workflow; treat older L&I instructions as migration context

FMCSA’s current Registration Video Library publishes Motus filing tutorials for BMC-91 and BMC-91X. The Insurance Filing Requirements page still includes dated instructions about claiming an existing L&I filer account and migrating active filings. Because the system changed during 2026, use the live Motus supporting-company workflow and current FMCSA status—not an old bookmark—and resolve any conflicting record with the registered filer or FMCSA.

Verify the carrier, docket, filing, and authority as one chain

USDOTData can help resolve the public carrier identity and available insurance context. Current authority and filing decisions must be confirmed in FMCSA’s official system.

BMC-91 and BMC-91X questions

What is a BMC-91 filing?

BMC-91 is an electronic certificate of motor-carrier public-liability insurance filed with FMCSA by a registered financial responsibility filer. It provides evidence for the regulated entity and authority record; the carrier does not download and submit the form itself.

What is the difference between BMC-91 and BMC-91X?

FMCSA accepts both in the public-liability certificate lane. Current Motus supporting-company instructions expose a Primary or Excess option for BMC-91X. The registered insurance or financial responsibility filer should select the form and layering that match the actual policy arrangement and current FMCSA workflow.

Can a motor carrier file BMC-91 or BMC-91X itself?

No, not as an ordinary carrier applicant. FMCSA says the forms must be submitted electronically by a registered electronic filer representing an insurance company, surety company, or financial institution. The carrier supplies exact entity and docket information and verifies the resulting record.

How much insurance does a carrier need for a BMC-91 or BMC-91X filing?

It depends on entity type, operation, vehicle, passenger capacity, commodity, and hazardous-material category. FMCSA’s current summary ranges from $300,000 for the listed light non-hazardous property category to $5,000,000 for specified passenger or hazardous-material categories. The table is a regulatory minimum summary, not a coverage recommendation.

Is an MCS-90 endorsement the same as a BMC-91 filing?

No. MCS-90 is a public-liability endorsement to a policy, while BMC-91 or BMC-91X is the financial responsibility filing made with FMCSA. A carrier can have policy paperwork without a matching active federal filing, so both lanes must be handled correctly.

Does BMC-91 satisfy household-goods cargo insurance?

No. FMCSA’s chart lists the public-liability BMC-91/BMC-91X/BMC-82 lane and a separate BMC-34 or BMC-83 cargo filing for the listed for-hire household-goods category. One does not replace the other.

Do brokers use BMC-91 or BMC-91X?

Not solely for broker authority when the entity does not operate vehicles as a motor carrier. FMCSA lists BMC-84 or BMC-85 for broker and freight-forwarder financial security. An entity that also operates as a motor carrier must evaluate that separate authority and public-liability lane.

Current federal sources

Use the live FMCSA materials and current regulation for controlling filings, amounts, roles, and system workflow.

BMC-91 and BMC-91X Filing Guide: Forms and Minimums | USDOTData