BMC-91, MCS-90 and the Certificate of Insurance: What Each One Actually Proves
Three pieces of paper get treated as interchangeable proof that a carrier is insured. They are not remotely the same thing, and the differences matter on the day something goes wrong.
Here is what each one is, what it proves, and which one you should actually be looking at.
The three documents
Certificate of insurance (COI)
The one a broker emails you, or you email a shipper. It is produced by an insurance agent and summarises a policy: who is covered, what limits, what dates.
What it proves: remarkably little.
A COI is a snapshot of what an agent says was true on the day they typed it. It is not a contract. It creates no obligation on the insurer. Most COIs carry language explicitly saying they confer no rights on the holder.
Most importantly, a COI does not tell you the policy is still in force today. A policy cancelled last Tuesday leaves last month's certificate looking perfect. Certificates float around in email for months after the coverage behind them has lapsed.
BMC-91 / BMC-91X
This is a filing, not a certificate. The insurer files it directly with FMCSA to certify that a carrier carries the public liability coverage required for its operating authority.
What it proves: coverage is registered with the federal government, today.
The difference is the direction of travel. A COI goes from an agent to you. A BMC-91 goes from the insurer to FMCSA and becomes part of the public record. And when coverage is cancelled, the insurer must notify FMCSA — so the filing goes away, publicly, on a timeline you can observe.
BMC-91X is the same instrument used where multiple insurers share the required limits.
This is the document that governs whether the carrier legally holds authority. No active filing, no active authority.
MCS-90
The MCS-90 is not a filing and not a certificate. It is an endorsement attached to the policy itself.
What it proves: the injured public gets paid, even if the policy would not otherwise respond.
It exists to protect members of the public, not the carrier. If a carrier has an accident and the insurer would ordinarily deny the claim — undisclosed operation, excluded cargo, a policy breach — the MCS-90 obliges the insurer to pay the injured party up to the required minimum anyway.
The critical part carriers rarely understand: the insurer can then come after the carrier to recover what it paid. The MCS-90 is not coverage for you. It is a federally mandated backstop for everyone else, and you are on the hook for the reimbursement.
A carrier relying on an MCS-90 as their safety net has misread it completely.
The minimum limits, from §387.9
These are set in the schedule at 49 CFR §387.9:
| Operation | Commodity | Minimum |
|---|---|---|
| For-hire, interstate/foreign, GVWR 10,001 lbs or more | Property (non-hazardous) | $750,000 |
| For-hire and private, GVWR 10,001 lbs or more | Oil, and hazardous materials/waste/substances not in the higher tier | $1,000,000 |
| For-hire and private, GVWR 10,001 lbs or more | Bulk hazardous substances in cargo tanks, bulk Division 1.1/1.2/1.3, certain bulk Division 2.3 and 6.1 materials, bulk Division 2.1/2.2, highway route controlled Class 7 | $5,000,000 |
| For-hire and private, GVWR under 10,001 lbs | Certain bulk hazmat and highway route controlled Class 7 | $5,000,000 |
Two things to note.
First, $750,000 is a floor, not a market rate. Very few brokers will work with a carrier at the federal minimum. $1,000,000 in auto liability plus $100,000 in cargo is the practical expectation for general freight, and plenty of shippers ask for more. Meeting §387.9 keeps your authority. It does not get you loads.
Second, the schedule has said "January 1, 1985" at the top for decades. There have been repeated proposals to raise the minimums and none have been adopted. The $750,000 figure is genuinely still current.
What goes wrong in practice
The certificate is stale. By far the most common problem. Someone checks a COI from four months ago and treats it as live coverage.
Cancellation is quiet. When a policy lapses, the carrier does not announce it. The insurer notifies FMCSA, the filing comes off the record, and the authority becomes vulnerable. Anyone still holding the old certificate has no idea.
Limits do not match the commodity. A carrier with $750,000 filed is fine for general freight and nowhere near compliant the moment they take a hazmat load requiring $1,000,000 or $5,000,000. The commodity determines the requirement, not what the carrier usually hauls.
The MCS-90 is mistaken for coverage. Carriers assume it protects them. It protects the public and leaves the carrier owing the money.
Cargo insurance is assumed to be federal. For most general freight carriers, cargo coverage is a contractual requirement from brokers and shippers, not a federal filing requirement. Do not assume an active authority implies cargo coverage.
How to actually verify coverage
Stop relying on the emailed certificate. Check the federal record, where cancellations show up.
- Confirm there is an active filing — not a certificate, an actual BMC-91 on file with FMCSA.
- Check the limit against the commodity they will be hauling for you.
- Look at the filing history, not just current status. This is the signal almost nobody checks. A carrier whose insurance has been filed and cancelled repeatedly is telling you something a current certificate cannot. Repeated lapses usually mean they are paying month to month and struggling.
- Re-check before each load for carriers you use occasionally. Coverage status is a live fact, not a file you keep.
- Get named as a certificate holder if you want notice of cancellation — but treat that as a supplement to checking the record, not a replacement.
Our free DOT number lookup shows insurance on file, the filed limits, authority status and the filing history for any US carrier, with no signup. If you are vetting someone, that history is the most useful thing on the page. Our guide to reading a carrier's DOT record goes through the other signals worth checking at the same time.
If you are the carrier
Your insurance filing is the single point of failure for your operating authority. There is no grace period worth relying on.
- Know your renewal date and treat it as a hard deadline, not a reminder.
- Never let a payment lapse in the belief you can reinstate quietly. The cancellation reaches FMCSA and becomes public record. Brokers running automated monitoring will see it, and some will drop you before you have reinstated.
- Keep your filing limits ahead of what you haul, not level with what you usually haul.
- Check your own record periodically. Filing errors happen. A broker discovering your insurance shows as inactive is a far worse way to learn about it than checking yourself.
Your insurance renewal belongs on the same calendar as your MCS-150 biennial update and your annual vehicle inspections — the small set of dates that, if missed, stop the business rather than merely inconveniencing it.
Insurance renewal is one of the few compliance dates where missing it by a day can cost you your authority. MyCarrierVault tracks it alongside your driver and vehicle document expiries, and tells you 30, 14 and 7 days out. Start a free trial — no credit card, 30 days free.