FMCSA insurance filings explained — BMC-91X, BMC-84, BMC-34 and the rest
A carrier's FMCSA record lists insurance by form code, not by plain description. The codes are not self-explanatory, and two of them look almost identical while meaning very different things.
The table below is derived from 95,806 live filings, checked against the coverage amounts each form actually carries rather than from a glossary.
The form codes
| Code | What it is | Typical coverage | Satisfies BIPD? |
|---|---|---|---|
BMC-91X | Liability insurance certificate | $750,000 / $1,000,000 | Yes |
BMC-91 | Liability certificate, older form | $750,000 | Yes |
BMC-82 | Liability surety bond | $750,000 / $1,000,000 | Yes |
BMC-35 | Liability certificate, alternate form | $750,000 / $1,000,000 | Yes |
BMC-34 | Cargo insurance certificate | $5,000 | No |
BMC-83 | Cargo surety bond | $5,000 | No |
BMC-84 | Broker surety bond | $75,000 | N/A — broker filing |
BMC-85 | Broker trust fund agreement | $75,000 | N/A — broker filing |
Two things fall out of this that catch people:
A surety bond counts. BMC-82 is a bond rather than a policy, but it satisfies the same federal financial-responsibility requirement as a BMC-91X certificate. A carrier showing only a BMC-82 is not uninsured.
Cargo is not liability. BMC-34 sits at $5,000 in essentially every filing. It is cargo coverage and does nothing for bodily injury or property damage. A carrier with a BMC-34 and nothing else has no BIPD filing on record.
Primary versus excess
Liability filings carry a class code. P is primary, E is excess.
An excess layer sits *above* a primary policy. On its own it does not meet the requirement, because there is nothing underneath it. Across live BIPD-capable filings the split is roughly 84,000 primary to 1,500 excess, and about 920 carriers hold both.
That matters when a primary is cancelled and an excess filing remains: the record still shows a large dollar figure — sometimes $10,000,000 — while no primary coverage is on file. The number looks reassuring and describes coverage that has nothing to sit on.
The broker filings
BMC-84 and BMC-85 are not carrier insurance at all. They are the $75,000 financial responsibility a property broker must maintain — a surety bond or a trust fund respectively.
The uniformity is useful: every BMC-84 filing in the data sits at exactly $75,000. If you are checking whether an entity is a licensed broker rather than a carrier, the presence of one of these is the cleanest signal on the record.
Coverage amounts you will actually see
Across live liability filings:
| Limit | Share | What it usually means |
|---|---|---|
| $750,000 | Most common | Federal minimum for general freight |
| $1,000,000 | Second | What most shipper contracts require |
| $5,000,000 | Uncommon | Hazmat or high-value |
| $75,000 | — | Broker bond, not carrier liability |
| $5,000 | — | Cargo, not liability |
The $750,000 federal minimum applies to general freight. Higher minimums apply to certain hazardous materials. Your own contract may require more than either — and that is a requirement FMCSA has no view on, so nothing on the public record will flag it for you.
Reading a filing correctly
- Check the form code, not just the dollar amount. $5,000 on a BMC-34 is normal; $5,000
of liability would not be.
- Check the class. An excess-only record is a gap, however large the number.
- Check whether the policy is still in force. The active/pending table can list a policy
that has been cancelled — the cancellation is recorded separately, keyed by policy number.
- Check the effective date. A filing dated in the future is not coverage today.
A caveat on the source
These figures come from FMCSA's own published files. Filings can be delayed, duplicated, or contain errors — we measure roughly 7% duplicate rows in the raw feeds before deduplication. The record tells you what has been filed, which is not the same as what is true on the road. Confirm with the carrier and the certificate holder before you dispatch.