--- title: "BMC-91 and BMC-91X filings explained" url: "https://rookiefeed.com/guides/bmc-91-filing-explained" updated: "2026-10-03" --- # BMC-91 and BMC-91X filings explained > A BMC-91 or BMC-91X is the certificate an insurer files with FMCSA to prove a motor carrier has the required bodily injury and property damage (BIPD) liability coverage. FMCSA won't activate for-hire operating authority without one on record. For nonhazardous freight in trucks of 10,001 pounds or more, the federal minimum is $750,000. ## What the form is The carrier doesn't file a [BMC-91](https://rookiefeed.com/glossary/bmc-91). Its insurer does, electronically, directly with FMCSA. The filing certifies that the insurer has issued a policy meeting the carrier's federal public liability requirement under 49 CFR Part 387. Under 49 CFR 387.313, a BMC-91 is filed for the full required limit by one insurer. A BMC-91X can represent full coverage or any level of aggregation, which is how coverage stacked from more than one insurer, or one insurer's layer of it, gets filed. For a seller reading the record, both mean the same thing: liability coverage is on file. A separate filing, the [BMC-34](https://rookiefeed.com/glossary/bmc-34), covers cargo liability where it's required (mainly household goods carriers). Most general freight carriers don't have one, even if they carry cargo insurance. ## Federal BIPD minimums The minimum the filing has to meet depends on what the carrier hauls and the truck's weight rating. From 49 CFR 387.303 and FMCSA's insurance requirements: | What the carrier hauls | Vehicle weight rating | Minimum BIPD | | --- | --- | --- | | Nonhazardous property (general freight) | 10,001 lbs or more | $750,000 | | Nonhazardous property | Under 10,001 lbs | $300,000 | | Oil, and hazardous materials not in the $5 million class | 10,001 lbs or more | $1,000,000 | | Certain hazardous substances and materials in bulk | 10,001 lbs or more | $5,000,000 | | Certain explosives and radioactive materials | Under 10,001 lbs | $5,000,000 | ## BMC-91 vs BMC-34 BMC-91 and BMC-91X are liability filings: they show the carrier carries the bodily injury and property damage ([BIPD](https://rookiefeed.com/glossary/bipd)) coverage its operation requires. BMC-34 is a different form, the Household Goods Motor Carrier Cargo Liability Certificate of Insurance. It covers the cargo, not liability to the public. Only household goods carriers (movers) have to file evidence of cargo insurance with FMCSA, under 49 CFR 387.303(c). A general freight carrier can carry cargo insurance without filing a BMC-34, so a missing BMC-34 on a dry van or flatbed carrier isn't a gap. ## How the filing fits into getting authority - The carrier applies for [operating authority](https://rookiefeed.com/glossary/operating-authority) (since May 14, 2026, through FMCSA's [Motus](https://rookiefeed.com/glossary/motus) system). - FMCSA reviews the application. Its guidance is 20 to 25 business days once the application is complete. - The insurer files the BMC-91 or BMC-91X, and a [process agent](https://rookiefeed.com/glossary/process-agent) files the [BOC-3](https://rookiefeed.com/glossary/boc-3). - Once both are on record, the authority is granted and goes active, and the carrier can haul for hire across state lines. - See how long that takes in practice in [how long MC authority takes](https://rookiefeed.com/guides/how-long-does-mc-authority-take). ## What the filing tells a seller - The insurer's name: who wrote the carrier's liability policy. Useful context for an insurance agent quoting against it, and for a factor sizing up a new client. - The effective date: when that insurer's coverage began. It hints at when a renewal may come up, but the filing itself has no expiration date. - The amount on file: whether the carrier carries the minimum or more. - That the carrier is real: a paid policy is a sign of a business that intends to run, which matters when you're sorting real carriers from paper ones. ## What it doesn't tell you - The premium, the policy term, or the agency that sold it. - Cargo, physical damage, occupational accident or non-trucking liability coverage. None of these are part of the BIPD filing. - Whether the policy will last. Under 49 CFR 387.313 the filing stays in effect until it's cancelled, and the insurer has to give FMCSA 30 days' written notice (Form BMC-35) before cancelling. A cancellation notice on the record is the signal that coverage is ending. - Timing, exactly. Agents report filings that were submitted after binding and still lagged in FMCSA's records after the Motus move, so a missing filing isn't proof of no coverage. ## Situations you'll see on the record - Filing on record, authority still pending: the insurance is done, but FMCSA is still reviewing the application or waiting on the BOC-3. The carrier can't haul for hire yet. - Two BIPD filings on one docket: usually an old insurer and a new one, or a BMC-91X layer. The most recent filing is the one to read for the current insurer. - A cancellation notice (BMC-35) with no replacement: the carrier has about 30 days before its authority is at risk. For an agent, that's the most time-sensitive record there is. - Amount on file above the minimum: the carrier bought higher limits, sometimes to meet a broker's or shipper's requirements. Worth asking which loads they're chasing. - No filing on a granted carrier: rare, since grants need the filing, and usually a sign FMCSA's records haven't caught up yet. ## Filings on new carriers right now 98.9% of the 5,591 carriers granted for-hire authority in the 30 days ending October 19, 2026 had a BIPD amount on file when we last checked. Which insurers wrote them is in [who insures new trucking companies](https://rookiefeed.com/guides/who-insures-new-trucking-companies); daily volumes are on the [stats page](https://rookiefeed.com/new-trucking-authority-stats). Rookiefeed puts the insurer, BIPD amount and filing effective date on every newly granted carrier, next to the owner's name, phone and email, by 7am Central. Rookiefeed is $59 a month for one state once a week, $149 for one state every day, $299 for up to 8 states and $599 for every state, and you can cancel any time. You can try a [free list](https://rookiefeed.com/list-builder) first. ## Questions ### What is a BMC-34 filing? BMC-34 is the Household Goods Motor Carrier Cargo Liability Certificate of Insurance. Insurers file it with FMCSA to show a household goods carrier has the required cargo coverage. Only household goods carriers have to file cargo insurance evidence with FMCSA; general freight carriers file BMC-91 or BMC-91X for liability instead. ### What is a BMC-91 filing? It's a certificate an insurer files with FMCSA proving a motor carrier carries the federally required bodily injury and property damage liability coverage. FMCSA won't activate a carrier's for-hire operating authority until a BMC-91 or BMC-91X is on record. ### What's the difference between a BMC-91 and a BMC-91X? Under 49 CFR 387.313, a BMC-91 certifies the full required limit from one insurer, while a BMC-91X can represent full coverage or any level of aggregation, such as a layer of stacked coverage. Either one satisfies the federal liability filing requirement. ### How much BIPD insurance does a new trucking company need? For nonhazardous freight in trucks rated 10,001 pounds or more, the federal minimum is $750,000. Vehicles under 10,001 pounds need $300,000. Oil and most hazardous materials need $1,000,000, and certain bulk hazardous substances need $5,000,000. ### Does a BMC-91 filing expire? No. The filing stays in effect until it's cancelled. An insurer has to give FMCSA 30 days' written notice, on Form BMC-35, before cancelling, so a cancellation notice is the sign coverage is ending, not a date on the original filing. ## Sources - [FMCSA FAQ: insurance forms required](https://www.fmcsa.dot.gov/faq/what-forms-are-required-insurance-and-where-can-i-find-them) - [Federal Register (2016): BMC-34 cargo liability certificate, 49 CFR 387.303(c)](https://www.govinfo.gov/content/pkg/FR-2016-12-30/pdf/2016-31651.pdf) - [FMCSA: insurance requirements](https://www.fmcsa.dot.gov/registration/insurance-requirements) - [49 CFR 387.303, security for the protection of the public: minimum limits](https://www.law.cornell.edu/cfr/text/49/387.303) - [49 CFR 387.9, schedule of limits](https://www.law.cornell.edu/cfr/text/49/387.9) - [49 CFR 387.313, forms and procedures](https://www.law.cornell.edu/cfr/text/49/387.313) - [FMCSA: Motus changes to FMCSA registrations (fact sheet)](https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/2026-05/Motus%20Changes%20to%20FMCSA%20Registrations.pdf) - [Agent on r/HotShotTrucking: filings lagging after Motus](https://www.reddit.com/r/HotShotTrucking/comments/1wjv4t9/motus_insurance_renewal_psa/)