motorcarrier.ai
Compliance·7 min read

How Insurance Gets on File With FMCSA

You buy the policy. The insurer files BMC-91 or BMC-91X. Motus can still show insurance missing when the policy is fine. One truck still counts.

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⏱️7 min read
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Key Takeaway
Buying a policy is not the filing. The insurance company (or surety) files BMC-91 or BMC-91X. FMCSA will not grant for-hire authority until the required financial responsibility is on file.

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.
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MCS-90 is not the FMCSA filing
Do not hand a broker the MCS-90 and call it done. That endorsement is on the policy. The BMC-91 / BMC-91X is the certificate sent to FMCSA. Different jobs. 387.313T lists both.

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.

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Pro Tip
You do not pick the form number. The insurer does. Your job is to make sure something acceptable shows as on file under the right legal name, USDOT, and MC.

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).

FMCSA minimum public-liability amounts on file, from the official insurance-filing-requirements chart, August 2026
WhoVehicle / cargoBI&PD on fileForms
For-hire property (non-HM)GVWR under 10,001 lb$300,000BMC-91, 91X, or 82
For-hire property (non-HM)GVWR 10,001 lb or more$750,000BMC-91, 91X, or 82
For-hire certain hazardous materialsSee FMCSA chart / 387.303T$1,000,000BMC-91, 91X, or 82
Explosives, poison gas, or radioactiveFor-hire and private$5,000,000BMC-91, 91X, or 82
For-hire passengers15 or fewer passengers$1,500,000BMC-91, 91X, or 82
For-hire passengers16 or more passengers$5,000,000BMC-91, 91X, or 82
Household goodsGVWR 10,001 lb or more$750,000plus $5,000 cargo91 / 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.

Two clocks that are not the same
387.7 is about having coverage in effect before you operate. 387.301T is about the certificate being filed and accepted before authority is issued or stays in force. You can have a live policy and still be waiting on the filing.

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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.
Application clock — from FMCSA, August 2026
If the required filing is not in within 20 days of publication in the FMCSA Register, FMCSA serves a decision: comply within 60 days or the application can be dismissed. That is on the same insurance-filing page. Call the insurer the day the MC number lands.
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Pro Tip
SAFER is still online. It is a safety snapshot. For “is the certificate on file,” use Motus first, then L&I. See the August Motus post if the dashboard itself looks wrong.

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)).

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Look at FMCSA’s record, not the dec page
Brokers and the Agency read Motus / L&I. Your policy packet is for the truck and the audit box. If the public record is empty, the policy is not finished work.

What to do this week

One-truck owner-operator. Same steps. The DQ file is a different folder.

1
Confirm the legal name on the policy
Match Motus, the authority application, and the secretary-of-state record. FMCSA says a mismatch delays the grant.
2
Call the insurer and ask for the FMCSA filing
Say BMC-91, BMC-91X, or BMC-82. Ask them to confirm they sent it, under which docket, and for which dollar limit. You cannot file that form yourself.
3
Check Motus, then L&I
Public Motus search, then L&I. Look for an accepted BI&PD certificate at the required amount — not a “policy active” email.
4
If it is missing, fix the record — do not buy a second policy
Wrong name or number? Have them refile. Already filed in L&I but Motus is empty? Give it a beat, then open one ticket at ask.fmcsa.dot.gov with screenshots. The Motus post covers the “do not panic-file twice” rule.
5
Keep the MCS-90 with the truck file
That endorsement stays with the policy proof at the principal place of business (387.7). It does not replace the certificate on file. Put a copy in the same box as the safety-audit records.

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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