A long-haul carrier needs more than one policy. The federal floor is the auto liability your insurer files with FMCSA: $750,000 for general freight in trucks rated 10,001 pounds or more, and higher for oil and hazardous materials. Around that sit motor truck cargo, physical damage on your tractors and trailers, trailer interchange if you pull other carriers’ trailers, non-trucking liability for leased owner-operators, general liability, and workers comp or occupational accident for drivers depending on your state. Broker and shipper contracts can ask for more than the federal minimum. For a fleet, underwriters look closely at drivers, safety scores, lanes, commodities and loss history.
The federal liability filing
Under 49 CFR 387.9, a for-hire carrier running interstate in vehicles rated 10,001 pounds or more needs at least $750,000 of public liability for nonhazardous property. Oil and hazardous materials not in the top tier call for $1,000,000, and certain hazardous materials hauled in bulk, including bulk explosives, call for $5,000,000. These are floors, not recommendations.
When the coverage is insurance, proof is the MCS-90 endorsement on your auto liability policy, kept at your principal place of business. Your insurer then files a certificate with FMCSA: a BMC-91 for the full limit, or a BMC-91X, which can show full coverage or an aggregated level, such as a limit built from primary and excess layers. An insurer has to give FMCSA 30 days’ notice before cancelling that filing. More on what the MCS-90 endorsement does.
Motor truck cargo
Motor truck cargo is an inland marine form covering loss of property in transit. FMCSA only requires a cargo filing from household goods carriers, at $5,000 per vehicle and $10,000 per occurrence. For general freight there is no federal cargo filing, so the limit you carry is driven by your broker-carrier agreements and shipper contracts. Send those with your submission, and make sure the commodities listed on the cargo policy match what you actually haul. More on cargo insurance.
Tractors, trailers and trailer interchange
Physical damage is the coverage for your own tractors and trailers. It is a separate decision from liability: the federal filing protects the public, not your equipment.
If you pull other carriers’ trailers under an interchange agreement, ask about trailer interchange coverage. It is designed for your legal liability for damage to trailers of others. Trailer interchange (CA 23 98) is available under a truckers or motor carrier policy, or by endorsement on a business auto policy.
Leased owner-operators
Under 49 CFR 376.12, a lease must give your company exclusive possession, control and use of the equipment for the lease term. It must name your company as the party legally obligated to carry the public liability insurance, state who provides other coverage such as bobtail, and spell out any insurance you charge back to the owner-operator.
- Non-trucking (bobtail) liability is auto liability for the owner-operator after a load has been delivered and while the truck isn’t being used for trucking purposes. It is written on a business auto policy with the non-trucking use endorsement, CA 23 09.
- Charge-backs. If the owner-operator buys coverage through you, the lease must say you will provide a copy of each policy on request and a certificate showing the insurer, policy number, dates, coverages, cost and deductible.
General liability and driver injury
General liability is a separate policy from auto liability. I quote it alongside the trucking program, and check your contracts for any GL limit they name.
Coverage for injured drivers varies by state. California requires workers comp even with one employee. Texas lets private employers choose whether to carry it. Occupational accident is designed to pay benefits similar to workers comp, but it isn’t a workers comp policy, so whether it fits depends on your state and on how your drivers are classified.
What underwriters review for a fleet
- Drivers. A list with license details, years of experience and MVRs. Federal rules already require you to pull and review each driver’s record at least once every 12 months.
- CSA/SMS data. FMCSA’s Safety Measurement System groups carrier data into seven BASICs, including Unsafe Driving, Hours-of-Service Compliance and Vehicle Maintenance, using roadside inspections and crash reports from the last two years plus investigation data.
- Radius, lanes and commodities. Where you run and what you haul.
- Loss runs from your current and prior insurers.
- Safety program and ELDs. How you hire, train and monitor drivers. Carriers generally must have drivers record duty status on an ELD, with limited exceptions such as trucks built before model year 2000.
How this differs from a new authority
A new carrier is in FMCSA’s new entrant program for 18 months, with a safety audit generally after at least 3 months of operation. It has no loss runs of its own and little inspection history, so underwriters lean on the owner’s and drivers’ experience. An established fleet is rated on its own record. The coverage list is much the same; the evidence behind it is different. See how to get MC authority if you are earlier in the process.
Common questions
Does FMCSA require cargo insurance?
Only household goods carriers have to file cargo insurance with FMCSA. For general freight, the cargo limit you carry is set by your broker and shipper contracts rather than a federal filing.
What is the difference between a BMC-91 and a BMC-91X?
Both are certificates your insurer files with FMCSA to show public liability coverage. A BMC-91 is filed for the full limit; a BMC-91X can show full coverage or an aggregated level, such as a limit built from primary and excess layers.
Does my liability cover a leased owner-operator driving home after a load?
Not necessarily. The lease has to name your company as responsible for public liability and state who provides other coverage, such as bobtail. Non-trucking liability is written for the owner-operator after a load is delivered, while the truck isn’t being used for trucking purposes.
Is occupational accident the same as workers comp?
No. It is designed to pay benefits similar to workers comp, but it isn’t a comp policy and doesn’t take the place of one where state law requires comp.
What should I have ready for a fleet quote?
Your USDOT number, driver list with MVRs, tractor and trailer schedule, radius and lanes, commodities, loss runs and any broker or shipper insurance requirements.
Sources
- 49 CFR 387.9 (eCFR): financial responsibility, minimum levels
- 49 CFR 387.7 (eCFR): financial responsibility required; MCS-90 proof
- 49 CFR Part 387 Subpart C (eCFR): surety bonds and policies of insurance for motor carriers (BMC-91, BMC-91X, BMC-34, cancellation notice)
- 49 CFR 376.12 (eCFR): written lease requirements
- 49 CFR 391.25 (eCFR): annual inquiry and review of driving record
- 49 CFR 395.8 (eCFR): driver’s record of duty status (ELD)
- 49 CFR 385.307 (eCFR): new entrant safety assurance program
- FMCSA CSA: the Safety Measurement System and BASICs
- IRMI glossary: motor truck cargo
- IRMI glossary: trailer interchange insurance
- IRMI glossary: bobtail liability
- IRMI glossary: occupational accident insurance
- California DIR: workers’ compensation information for employers
- Texas Department of Insurance: workers’ compensation non-subscribers
General information about insurance for interstate for-hire motor carriers as of October 2026, not legal or tax advice; 49 CFR Parts 376, 385, 387, 391 and 395, state workers’ compensation laws and each policy’s wording control. Coverage depends on underwriting and the terms, conditions and exclusions of the policy actually issued.