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What is a BMC-91X filing?

Updated . Sources for every claim are listed at the end.

Short answer

A BMC-91X is a certificate of insurance that your insurance company files electronically with FMCSA to prove you carry the federal minimum public liability coverage. You cannot file it yourself, and FMCSA will not grant or keep for-hire operating authority without it.

  • The "X" version can show either full coverage from one insurer or one layer of coverage when several insurers combine to reach the required limit.
  • The filing stays in force until someone cancels it with a notice to FMCSA. Cancelling a policy does not end the filing by itself.
  • The filing has to be issued in the exact legal name on your authority. Name mismatches are a common reason authority sits pending.
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What the BMC-91X actually proves

For-hire motor carriers in interstate commerce have to show FMCSA that they carry public liability insurance at the levels in 49 CFR 387.303: $750,000 for non-hazardous freight in vehicles of 10,001 pounds or more, $300,000 for a fleet made up only of lighter vehicles, and $1,000,000 or $5,000,000 for certain hazardous materials. The BMC-91X is the form the insurer uses to certify that coverage to FMCSA.

Under 49 CFR 387.313, the BMC-91 certifies full coverage from one insurer, while the BMC-91X can represent full coverage or "any level of aggregation," meaning a layer stacked with other insurers to reach the required limit. In practice many trucking insurers use the 91X for every filing. For the dollar amounts by commodity, see FMCSA truck insurance minimums.

Which filing goes where

Trucking insurance filings and where each one goesThe insurer files BMC-91X or BMC-91 with FMCSA as proof of liability for interstate authority, and BMC-35 to cancel it, effective 30 days after FMCSA receives it. The carrier or a process agent service files the BOC-3 with FMCSA. The insurer files Form E with TxDMV for Texas intrastate registration, and Form K to cancel it. The MCS-90 endorsement is not a filing; it is attached to the policy.Who filesFormWhere it goesInsurerfiles itBMC-91X or BMC-91proof of liabilityFMCSAneeded for interstate authorityInsurerfiles itBMC-35notice of cancellationFMCSAeffective 30 days after receiptCarrieror a process agent serviceBOC-3designates process agentsFMCSAan agent in every stateInsurerfiles itForm Eproof of liabilityTxDMVTexas intrastate registrationInsurerfiles itForm Kliability cancellationTxDMVcancels the proof on fileInsurerattaches itMCS-90 endorsementguarantee to the publicYour policynot a filing; part of the policy
Forms named in 49 CFR 387.313 (BMC-91, BMC-91X, BMC-35) and 49 CFR part 366 (BOC-3). Under 387.313, federal filings cannot be cancelled until 30 days after FMCSA receives the BMC-35. TxDMV states that only the insurance company can file proof of insurance (Form E) or its cancellation (Form K), and that the carrier is still responsible for keeping its insurance record active.

Who files it, and when

FMCSA's own guidance is direct: once you apply for operating authority, "a financial responsibility provider must file the appropriate insurance form(s) on behalf of the applicant." That means the insurer (or its authorized filer), not you, not your agent's office staff typing into a portal under your login.

Timing matters for new carriers. FMCSA says that if the required filings are not made within 20 days after your application is published in the FMCSA Register, FMCSA will serve a decision saying the application will be dismissed unless you comply within 60 days. The BOC-3 process agent designation has to be on file too. The full sequence is in how long until new authority is active, and the broader picture of which filing goes where is on our FMCSA and TxDMV insurance filings page.

Federal filings a for-hire property carrier usually deals with
FormWho files itWhat it does
BMC-91 or BMC-91XYour insurer, with FMCSACertifies public liability (bodily injury and property damage) coverage
MCS-90 endorsementAttached to your policy by the insurer; not filedGuarantees payment of final judgments to the public up to the federal minimum
BMC-34Insurer, with FMCSACargo filing, required only for household goods carriers
BMC-35Insurer (or carrier), with FMCSANotice of cancellation of a BMC-91 or 91X filing
BOC-3A process agent or blanket companyDesignates agents for service of legal papers

Why the name on the filing has to match exactly

Section 387.313(c) requires certificates of insurance to be issued in "the full and correct name" of the carrier, and FMCSA warns that the name and address on your application must match your other registration records exactly or the grant is delayed. A filing for "Smith Trucking" will not attach cleanly to an authority issued to "Smith Trucking LLC." If you changed your entity type, added a DBA, or moved, check that the policy, the filing, and your FMCSA record all agree before a broker looks you up.

The filing outlives the policy until someone cancels it

Section 387.313(a)(6) says certificates must remain in effect continuously until terminated. Under 387.313(d), a filing cannot be cancelled until 30 days after a cancellation notice (Form BMC-35) is filed with FMCSA. A replacement filing from a new insurer ends the old insurer's liability as of the replacement's effective date under 387.313(e).

So when you switch insurers, the clean sequence is: new policy bound, new insurer files its 91X effective the same day, then the old filing is replaced. If you are thinking about a mid-term switch or worried about a lapse, read what happens if truck insurance cancels.

How to check your own filing

FMCSA’s Licensing and Insurance records (linked from each SAFER Company Snapshot) show active filings and any pending cancellation. Look yourself up before a broker does, and confirm the insurer, effective date and limit are what you expect.

Common questions

Can I file my own BMC-91X?

No. FMCSA requires the financial responsibility provider (your insurer) to file it on your behalf.

Does an intrastate-only Texas carrier need a BMC-91X?

Not for Texas intrastate operations. Texas intrastate carriers prove insurance to TxDMV through a Form E filed by the insurer. Carriers who also run interstate for hire need both.

Does the BMC-91X show my cargo coverage?

No. It covers public liability only. FMCSA requires a cargo filing (BMC-34) only for household goods carriers.

My policy renewed. Does the insurer need to refile?

Usually not when the same insurer renews, because the filing is continuous until cancelled. A new insurer always files its own.

Sources

  1. 49 CFR 387.313, Forms and procedures (eCFR). BMC-91 vs BMC-91X use, exact-name rule, continuous coverage, 30-day BMC-35 cancellation notice, termination by replacement.
  2. 49 CFR 387.303, Security for the protection of the public: minimum limits (eCFR). Minimum limits the filing certifies.
  3. FMCSA, Insurance Filing Requirements. Insurer files on applicant’s behalf; 20-day and 60-day timing; name and address matching; filing chart.

This page explains insurance, not law. Have your attorney review indemnity and contract language; our job is making the insurance match it.

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