Understanding FMCSA Filings: BMC-91X, MCS-90, and More Explained
When starting or managing a trucking company, compliance with FMCSA (Federal Motor Carrier Safety Administration) regulations is non-negotiable. One of the most confusing areas for carriers—especially new authorities—is understanding the various insurance-related filings required to operate legally in interstate commerce.
In this guide, we'll break down key FMCSA filings like BMC-91X, MCS-90, and others, helping you stay informed and compliant.
🚛 What Are FMCSA Insurance Filings?
FMCSA insurance filings are documents submitted by your insurance company directly to the FMCSA to prove you have the minimum required coverage in place. These filings are linked to your USDOT and MC Number and are required before your operating authority becomes active.
Important: You cannot submit these forms yourself — your insurance provider must file them on your behalf.
🧾 Key Filings Explained
🔐 BMC-91 / BMC-91X — Proof of Auto Liability Coverage
What it is: Confirms that your business carries the minimum auto liability insurance required for interstate operations.
BMC-91X is the most common form for fleets with multiple insurers or policies — it combines several filings into one.
Required for: Carriers hauling freight or passengers in interstate commerce.
🧾 MCS-90 — Endorsement of Liability Insurance
What it is: An endorsement added to your insurance policy stating that your insurer will meet certain federal financial responsibility requirements, even if the policy wouldn’t normally cover a specific claim.
Why it matters: It protects the public, not the carrier. Even if a policy exclusion would deny a claim, the insurer must pay — and can seek reimbursement from the insured.
Required for: All for-hire carriers required to maintain minimum liability under FMCSA rules.
📄 BMC-34 — Cargo Liability Filing
What it is: Proof that your company carries the required cargo insurance, often $5,000 per vehicle and $10,000 per occurrence (unless otherwise exempt).
Who needs it: Most common for freight forwarders and household goods movers.
📃 BMC-84 / BMC-85 — Freight Broker Bonds or Trusts
BMC-84: Surety bond
BMC-85: Trust fund agreement
What it is: Proof that freight brokers or freight forwarders have the $75,000 financial security required by FMCSA.
Filed by: Bonding or financial institution, not the broker themselves.
✅ When Are These Filings Required?
You’ll need to have the proper filings before your authority becomes active. FMCSA gives a 20–30 day window from the time you apply to have all filings submitted. If you fail to meet the deadline, your application will be dismissed.
Also note:
If your insurance lapses, your authority will be revoked.
If you change insurance providers, the new carrier must refile these forms.
⚠️ Common Mistakes to Avoid
Assuming your COI is enough: A Certificate of Insurance is not a substitute for an FMCSA filing.
Not knowing your filing requirements: Passenger carriers, hazmat haulers, freight brokers, and forwarders all have different obligations.
Switching carriers without a filing gap plan: Always confirm that your new insurer will file immediately to avoid revocation.
🔍 Let Trucking IQ Help
At Trucking IQ, we specialize in helping carriers navigate insurance and FMCSA compliance with ease. Our licensed agents handle filings like BMC-91X and MCS-90 for you, ensuring you stay compliant and on the road.
Need help getting started or managing your filings?
👉 Reach out to Trucking IQ — we help drivers make smarter, safer, and more profitable decisions on the road.