Who needs it
Interstate for-hire motor carriers of property and passengers generally need liability coverage on file before their operating authority can become active. The BMC-91 is the common way insurers show that coverage.
Private carriers that haul only their own goods have federal minimum insurance requirements in some cases, but do not need operating authority. Ask an agent which rules apply to your operation.
Timing
After a policy binds, the insurer files electronically and the filing usually appears in FMCSA records within a few business days. Plan quotes during the protest period after you apply for authority so coverage is ready when you need it.
What the certificate actually says
Under 49 CFR 387.311, each Form BMC-91 on file represents the full federal minimum liability limit that applies to that carrier for as long as it stays in force. The form does not list your actual policy limit; it certifies that the policy meets the minimum. The underlying policy must carry the endorsement FMCSA requires, and the certificate has to match that endorsement.
The certificate is issued in the full legal name of the carrier that holds, or is applying for, the authority. If your business name on the policy does not match your FMCSA registration exactly, the filing can be rejected, so check the spelling, the entity type and any trade name before the insurer files.
Before you ask for quotes
- Your USDOT and MC numbers, or the application you just submitted
- The commodities you plan to haul, including any hazardous materials
- Each power unit's year, make, VIN and gross vehicle weight rating
- Driver names, license details and years of commercial experience
- Where the trucks are based and the states or lanes you expect to run
Keeping the filing active
A filing stays on record until it is cancelled or replaced. If you move to a new insurer, have the new filing accepted before the old policy ends; under FMCSA's rules a replacement filing ends the old insurer's certificate on the replacement's effective date. Look up your record on FMCSA's licensing and insurance system after any change.
Frequently asked questions
Does the BMC-91 show my cargo coverage?
No. It covers liability. Household goods carriers need a separate cargo filing.
Can I file the BMC-91 myself?
No. The insurer that wrote the policy submits the certificate to FMCSA. A carrier cannot file its own proof of liability coverage.