Short answer: California charter-party carriers, including limousine operators with a TCP permit, must keep liability insurance on file with the CPUC under Public Utilities Code §5391 and General Order 115. The minimums are $750,000 for vehicles seating 8 or fewer, $1,500,000 for 9 through 15, and $5,000,000 for 16 or more, counting the driver.
Minimum liability by seating capacity
| Vehicle seating capacity (including the driver) | Minimum combined BI/PD liability |
|---|---|
| 8 or fewer | $750,000 |
| 9 through 15 | $1,500,000 |
| 16 or more | $5,000,000 |
Sources: Public Utilities Code §5391, which requires the CPUC to make every charter-party carrier keep liability protection for its whole permit term, and the CPUC's PL 912 insurance endorsement, which lists the schedule above. The insurer files the policy electronically with the CPUC.
Things operators get caught on
- Seat count includes the driver. Under the CPUC's 2024 update (Resolution TL-19147), tiers count the driver: a vehicle with 8 seats including the driver is in the $750,000 tier, and 9 seats including the driver moves it to $1,500,000.
- Lapses suspend operations. Keep coverage continuous; the CPUC filing must stay in force for the life of the permit.
- Employees need workers' comp under Labor Code §3700.
- Airports and venues may require higher limits or additional insured status by contract.
Checklist
- List every vehicle with its seat count, including the driver, and confirm the tier.
- Ask your insurer to file the CPUC endorsement and confirm it posted.
- Calendar the renewal to avoid a gap in your filing.
Related: limousine insurance.
Frequently asked questions
How much insurance does a limo company need in California?
CPUC minimums by seating capacity, including the driver: $750,000 for 8 or fewer, $1,500,000 for 9 through 15 and $5,000,000 for 16 or more.
Who regulates limousine insurance in California?
The California Public Utilities Commission, under Public Utilities Code §5391 and General Order 115, for charter-party carriers (TCP permit holders).
Does the seat count include the driver?
Yes. The CPUC schedule counts vehicle seating capacity including the driver.
How is limo insurance proven to the CPUC?
The insurer files the policy electronically with the CPUC, using the required endorsement.
Alishahi Insurance · 439 N Canon Dr, Penthouse, Beverly Hills, CA 90210 · (877) 711-4545 · CA License #4348151. General information only. Not legal, tax or financial advice, and not a coverage determination. Coverage depends on policy language and underwriting, and rules vary by state.