BMC-91X Insurance Filing: What FMCSA Requires and What the Data Shows
A BMC-91X is the certificate your insurer files with FMCSA to prove your federal liability minimum, $750,000 for non-hazardous for-hire freight in vehicles of 10,001 lb GVWR or more. FMCSA will not grant authority until it is on file, and your filing must stay on record to avoid revocation proceedings.
By TruckerStack Editorial, AK Digital Marketing LLC · Published 2026-11-09 · Updated 2026-11-09 · checked against the official sources cited · Editorial policy · Not insurance, legal or financial advice.
What FMCSA requires on file, by entity type
FMCSA publishes one filing chart under 49 CFR 387.303 and 49 CFR 387.307. The rows that matter to most small carriers are the first two; the BMC-91X is one of the three forms that can satisfy them.
| Entity | Vehicle | BIPD liability | Cargo | Bond / trust | Forms |
|---|---|---|---|---|---|
| For-hire property carrier (non-hazardous) | GVWR under 10,001 lb | $300,000 | $0 | $0 | BMC-91, BMC-91X or BMC-82 |
| For-hire property carrier (non-hazardous) | GVWR 10,001 lb or more | $750,000 | $0 | $0 | BMC-91, BMC-91X or BMC-82 |
| For-hire carrier of certain hazardous materials | n/a | $1,000,000 | $0 | $0 | BMC-91, BMC-91X or BMC-82 |
| For-hire and private carriers of explosives, poison gas, radioactive | n/a | $5,000,000 | $0 | $0 | BMC-91, BMC-91X or BMC-82 |
| For-hire household goods carrier | GVWR 10,001 lb or more | $750,000 | $5,000 | $0 | BMC-91/91X/82 plus BMC-34 or BMC-83 |
| Property broker or freight forwarder | n/a | $0 | $0 ($5,000 for household goods forwarders) | $75,000 | BMC-84 or BMC-85 |
Updated 2026-11-09. Source: FMCSA Insurance Filing Requirements (last updated 2026-03-26).
Filing deadlines for new authority
| Step | What FMCSA says |
|---|---|
| Before authority is granted | FMCSA will not grant operating authority until the registrant has the minimum financial responsibility on file. |
| Who files | A financial responsibility provider (your insurer or surety) files the form for you after you obtain your docket number. |
| Day 20 after FMCSA Register publication | If the filing is missing, FMCSA serves a decision that the application will be dismissed unless the entity complies. |
| 60 days after that decision | Deadline to comply before the application is dismissed. |
| After authority is granted | You must maintain proof of insurance and agent designation (BOC-3) on file with FMCSA to avoid revocation proceedings. |
Updated 2026-11-09. Source: FMCSA Insurance Filing Requirements (last updated 2026-03-26). Name and address on the filing must match your application exactly; any deviation delays the grant.
Cancellation and termination records in FMCSA data, January-April 2026
FMCSA's insurance history file lists every filing with its cancellation method and date. We counted records with form type BIPD/Primary whose cancellation date falls in each month. These are filing records, not unique carriers: a carrier that changes insurer produces a termination record on the old filing and a new filing record.
| Cancellation date in | CANCEL | TERM/CANCL | TERM/REPL | Other methods | Total records |
|---|---|---|---|---|---|
| January 2026 | 14,244 | 6,408 | 12,904 | 102 | 33,658 |
| February 2026 | 13,377 | 6,515 | 12,029 | 64 | 31,985 |
| March 2026 | 14,843 | 7,240 | 13,639 | 129 | 35,851 |
| April 2026 | 15,103 | 7,650 | 12,352 | 96 | 35,201 |
| Jan-Apr 2026 | 136,695 | ||||
Updated 2026-11-09. Source: FMCSA InsHist - All With History, file refreshed 2026-11-08, queried 2026-11-09 (filter: mod_col_3 = BIPD/Primary, cancl_effective_date in month). Method labels are FMCSA's own: CANCEL, TERM/CANCL and TERM/REPL appear as published, and we do not infer more from them than the label states (TERM/REPL is the label FMCSA uses for a termination by replacement). Records dated after April 2026 are excluded because the file's last full month of records is April; May is partial and later dates are scheduled or incomplete entries.
Cancellation notice: what the rule text says
The text of 49 CFR 387.313(d) says a certificate of insurance shall not be cancelled until 30 days after the insurer or another party files a BMC-35 notice with FMCSA, and (e) says a certificate can instead be terminated by a replacement certificate that FMCSA accepts. The eCFR page also carries a note that this section has been suspended since the 2019 amendments, so ask your insurer how FMCSA is processing cancellation notices today rather than relying on a fixed number of days.
How to check your own filing
Run your USDOT or MC number through the authority & insurance checker or the DOT lookup. If the insurance shown is older than your current policy, ask your agent to confirm the BMC-91X was refiled. For how limits vary by cargo, see insurance minimums.
Premiums are set by each insurer and we do not publish price estimates. What moves a quote: authority age (new MCs are rated higher), driver MVR and CDL experience, radius and lanes, commodity, vehicle value and GVWR, garaging ZIP, CSA/inspection history (check yours in our DOT lookup), deductibles and limits above the minimum that brokers often require.
Related
- Commercial truck insurance hub
- Insurance minimums table
- Authority & insurance checker
- Check any carrier's insurance on file
- Hot shot truck insurance
- Owner-operator truck insurance
FAQ
What is a BMC-91X?
It is the certificate of insurance form an insurer files with FMCSA to show a for-hire carrier has the required liability coverage. FMCSA lists BMC-91, BMC-91X or BMC-82 as the forms for non-hazardous property carriers.
How much liability does a for-hire trucker need on file?
$750,000 for non-hazardous freight in vehicles with a GVWR of 10,001 lb or more and $300,000 for vehicles under 10,001 lb, per FMCSA's insurance filing chart for 49 CFR 387.303.
Who files the BMC-91X, me or my insurer?
Your insurer or surety, as a financial responsibility provider registered with FMCSA, files it after you obtain your docket number.
What happens if my filing is missing when I apply for authority?
If it is not on file within 20 days of publication in the FMCSA Register, FMCSA serves a decision that the application will be dismissed unless you comply, and you then have 60 days.
Does cargo insurance have to be filed with FMCSA?
Not for non-hazardous property carriers: the FMCSA chart shows $0 cargo filing. Household goods carriers must file $5,000 cargo, and brokers need a $75,000 bond or trust fund.