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Policy vs filing
Two different papers. One sits in your glove box. The other is what Motus and Licensing & Insurance actually look at.
The policy
You buy coverage
- You pay the premium. You get a declarations page.
- The MCS-90 endorsement goes on the policy. That is proof you keep at the principal place of business (49 CFR 387.7).
- A live policy does not, by itself, put anything on FMCSA's record.
The filing
They send the certificate
- The insurer files BMC-91 or BMC-91X. A surety files BMC-82.
- FMCSA must accept it. 387.301T says no certificate stays in force until that happens.
- That accepted filing is what Motus shows as insurance on file.
This sits next to the post-authority checklist, the August 2026 Motus update, and — once you start hauling — the new-entrant safety audit. Missing required financial responsibility is an automatic fail on that audit. motorcarrier.ai is a private filing and compliance help service. We are not FMCSA.
Which form: 91, 91X, or 82
FMCSA does not mail you these forms. The official FAQ (last updated May 26, 2023; still posted August 2026) says the insurance company keeps them and files them.
BMC-91
One insurer, full limit
387.313T(a)(3): filed for the full security limits. Most one-truck policies land here.
BMC-91X
Full limit or stacked
Same section: used for full coverage or any level of aggregation. More than one insurer sharing the limit? Each files a 91X.
BMC-82
Surety bond instead
Bond, not a policy certificate. FMCSA's chart lists it as the BI&PD alternative to 91 / 91X.
How much has to be on file
Dollars below are from FMCSA's Insurance Filing Requirements chart, checked August 2026. Same floors sit in 49 CFR 387.303T (387.303 itself is suspended).
| Who | Vehicle / cargo | BI&PD on file | Forms |
|---|---|---|---|
| For-hire property (non-HM) | GVWR under 10,001 lb | $300,000 | BMC-91, 91X, or 82 |
| For-hire property (non-HM) | GVWR 10,001 lb or more | $750,000 | BMC-91, 91X, or 82 |
| For-hire certain hazardous materials | See FMCSA chart / 387.303T | $1,000,000 | BMC-91, 91X, or 82 |
| Explosives, poison gas, or radioactive | For-hire and private | $5,000,000 | BMC-91, 91X, or 82 |
| For-hire passengers | 15 or fewer passengers | $1,500,000 | BMC-91, 91X, or 82 |
| For-hire passengers | 16 or more passengers | $5,000,000 | BMC-91, 91X, or 82 |
| Household goods | GVWR 10,001 lb or more | $750,000plus $5,000 cargo | 91 / 91X / 82 and BMC-34 or BMC-83 |
Most one-truck freight
Non-HM for-hire: $300,000 if the truck is under 10,001 lb GVWR; $750,000 at 10,001 and up.
Cargo on file
The official chart lists a cargo filing only for household goods ($5,000; BMC-34 or BMC-83). We are not inventing cargo-bond numbers for general freight.
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Who files, and how you check
After you get a docket number, FMCSA says contact your financial-responsibility provider and have them file. You do not upload a BMC-91 in Motus as the carrier.
You
Buy, then check the record
- Legal name and address must match the authority application. FMCSA says any deviation delays the grant.
- Check status in Motus and the public Motus search.
- The L&I carrier search is still up as of August 2026. Use it as a second look, not as a substitute for Motus.
The insurer
They send the certificate
- Insurance and surety companies register as financial-responsibility filers.
- FMCSA's insurance page still says supporting companies keep filing in Licensing & Insurance until Motus is open for all users. Carriers already check status in Motus. That split is why two screens can disagree.
- Details: Insurance Filing Requirements and Motus FAQs.
Why Motus can look wrong when the policy is fine
Motus may show insurance as not on file, or “no active insurance meeting minimum coverage on file,” while you are holding a current declarations page. That is a record problem, not automatically a lapsed policy.
Insurer has not filed yet
Bound coverage is not a BMC-91. Ask for the filing confirmation, not another copy of the dec page.
L&I and Motus out of step
Filers may still be in L&I while you are reading Motus. Check both. Do not assume one is stale without looking.
Name, USDOT, or MC mismatch
Certificate must be in the full, correct name of the person getting the authority (387.313T(c)). LLC vs DBA, extra commas, wrong docket — the filing misses.
BMC-35 in process
Cancellation is BMC-35. The filing stays up until 30 days after FMCSA receives that notice (387.313T(d)). A new accepted certificate can replace it sooner (387.313T(e)).
What to do this week
One-truck owner-operator. Same steps. The DQ file is a different folder.
Waiting on first authority
BOC-3 plus insurance on file. That is the after-MC checklist. Authority does not go active on a premium receipt.
Already running
Stay on file. A BMC-35 starts a 30-day clock after FMCSA receives it. Operating without required financial responsibility fails the new-entrant audit.
FAQ
Can I file the BMC-91 myself?
No. FMCSA's forms FAQ says the insurance company files BMC-91 and BMC-91X. FMCSA does not give those forms to carriers. You buy the policy. They file.
Why does Motus say insurance is missing when I have a policy?
Policy in force is not “on file.” Usual causes: insurer has not filed; L&I and Motus do not match; name / USDOT / MC is wrong on the certificate; a BMC-35 is running; or you are reading the dec page instead of Motus or L&I.
Is the MCS-90 the same as the BMC-91?
No. MCS-90 is the policy endorsement you keep at the principal place of business (387.7). BMC-91 / BMC-91X is the certificate filed with FMCSA (387.313T). Most for-hire operations need both. One is not the other.
How long after a BMC-35 until the filing is gone?
387.313T(d): the certificate is not cancelled until 30 days after FMCSA actually receives the BMC-35. That is not the 35-day notice between you and the insurer in 387.7(b). A replacement certificate that FMCSA accepts can end the old one on the replacement effective date (387.313T(e)).
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