Loading…
Insurance is the second-most-common reason a broker tender goes sideways: a policy that was valid at onboarding but lapsed before pickup, a BMC-91 with a cancellation date the dispatcher missed, or a Certificate of Insurance that does not match what is actually on file. This guide walks the FMCSA L&I insurance register field by field — what each form is, what the dates mean, and the three patterns that should stop a tender.
An FMCSA insurance filing is a regulator-held record that a carrier's insurer has bound coverage at the federally required minimum. The two filings every broker reads are BMC-91 (or BMC-91X) for public liability and BMC-34 for cargo. Each filing has an effective date (when coverage starts) and a cancellation date (when the insurer has notified FMCSA the policy will end). Read both — and never trust the 'active' flag without checking the cancellation date.
Every interstate for-hire motor carrier hauling regulated commodities is required to keep certain minimum levels of liability and (sometimes) cargo insurance in force. The carrier's insurer files a form with the FMCSA Licensing and Insurance (L&I) system certifying coverage. That form — not the carrier's COI — is the regulatory record of coverage. The L&I register is public, refreshes daily, and is the single source of truth for whether a carrier is legally insured.
The forms are not the policy itself. They are filing certificates: short summaries the insurer submits saying 'we have bound coverage for carrier X at $Y limit starting on date Z'. Insurers also file cancellation notices when a policy ends, which is why the cancellation date is the field that catches lapses brokers would otherwise miss.
A Certificate of Insurance (COI) is a sales document an insurance agent prints — useful, but easy to forge. The BMC filing exists in the federal L&I database whether the carrier wants it there or not. When the two disagree, the regulator's filing is the one that matters. If the COI shows coverage the L&I register does not, call the insurance agency on the COI directly to confirm.
BMC-91 is the canonical 'public liability' filing. It certifies the carrier has bodily injury and property damage (BIPD) coverage at or above the federal minimum. The federal minimum is $750,000 for general freight, $1,000,000 for oil and certain hazmat, and $5,000,000 for the most hazardous loads. State minimums may exceed these on intrastate freight, but the L&I filing is the interstate floor.
BMC-91X is the fleet variant — mechanically identical to BMC-91, but covers the entire fleet under a single filing rather than a per-vehicle endorsement. For brokers, the practical difference is zero: both forms certify the same thing. Most modern carriers file BMC-91X.
Watch for a $300,000 or $500,000 limit on a BMC-91. The federal minimum for non-hazmat is $750,000; anything below is non-compliant for interstate general freight and should stop a tender. The exception is intrastate-only carriers where the state minimum is lower — but that carrier should not be hauling your interstate load anyway.
Cargo coverage is filed separately from liability. BMC-34 is the standard cargo filing for general freight. BMC-32 is the household-goods variant — required for any carrier authorized to haul household goods, even if they also haul general freight under the same authority.
Cargo minimums are lower than liability and vary by load type. The federal floor is $5,000 per vehicle for household-goods carriers and is not specified for general-freight cargo (the federal regulator does not mandate a cargo minimum for general freight). In practice, shippers and brokers require cargo limits in the $100,000-$250,000 range, and high-value freight requires much more. The L&I cargo filing shows the limit the insurer certified — your shipper's requirement may be higher.
Many carriers have an active BMC-91 (liability) on file with no corresponding BMC-34 (cargo). That is regulatorily compliant for non-household-goods carriers but commercially insufficient for almost every broker workflow. If your shipper's BOL requires cargo coverage and the L&I register shows no BMC-34, request the COI directly — and verify the cargo policy is real before tender.
Two date fields per filing decide whether the policy is in force right now: the effective date and the cancellation date. The pattern brokers look for is simple — effective date in the past, cancellation date blank or in the future, and you are clear. Anything else is a flag.
When an insurer terminates a policy, they file a cancellation notice with the L&I system. The cancellation date is when coverage ends, not when the notice was filed. A common pattern: the insurer files the cancellation notice on the 1st of the month with a cancellation date of the 30th. For 29 days the L&I register shows the policy as still active — with a populated cancellation date sitting in the future. Brokers who only check the 'active' status flag miss this every time.
The lapse window — the period between when the cancellation notice is filed and when coverage actually ends — is the single most common source of insurance failures on tender. Any tender within 30 days of a populated cancellation date deserves a follow-up: is there a replacement policy on file, has the carrier rebooked coverage, or is this load going to be uninsured when the wheels turn?
Most insurance failures are not subtle. They look like one of three patterns the L&I register makes obvious once you know where to look.
An insurance check at onboarding gives you the snapshot for that day. A cancellation notice filed three weeks later will not retroactively change the onboarding record. The only safe insurance check is one run on the day of tender. Knowhaul's insurance card reads the L&I register live on every search, surfaces the cancellation date prominently, and flags any policy lapsing inside the next 30 days.
An experienced broker can read an FMCSA insurance filing in under a minute. The order matters: liability first (most loads require it), cargo second (depends on the load type), dates last (the lapse-window check). If any one of those three steps fails, the tender stops there — there is almost always another carrier on the lane.
Documenting the check matters too. Negligent-selection lawsuits against brokers increasingly hinge on whether the broker verified insurance at the time of tender, not just at onboarding. A timestamped log of the L&I read on the tender day is the strongest defense — and it is what every modern carrier-verification tool produces automatically.
It refreshes daily from the underlying insurer filings, but the insurers themselves are not always real-time. A cancellation notice filed today typically appears in the L&I register within 24-72 hours. For the most current view, read the register on the day of tender — not the day of onboarding.
BMC-91 is filed per-vehicle (or per-policy on a small fleet). BMC-91X is the fleet-wide endorsement variant — one filing covers the carrier's entire fleet under a master policy. Both certify the same thing: liability coverage at or above the federal minimum. For broker verification purposes, they are interchangeable.
Not exactly. The BMC-91 confirms coverage exists at the certified limit. A COI gives you the policy number and insurer contact for additional-insured endorsements, claims, and certificate-of-cancellation notifications. Best practice is to verify the BMC filing for current status and request a COI for documentation. A discrepancy between the two is a hard flag.
Federal regulators do not require cargo coverage for most general-freight carriers — only liability. Many carriers carry cargo coverage on the policy side but never file a BMC-34 because they are not required to. If your load needs cargo coverage and there is no BMC-34, ask the carrier for the cargo COI and call the cargo insurer directly to confirm the policy is in force.
Legally, the carrier is operating in violation of federal regulations the moment the BMC filing lapses. Your shipper's freight is at risk because cargo claims will likely be denied. Brokers who tendered to a carrier whose insurance lapsed inside the tender window face negligent-selection exposure. The mitigation is exactly the same as the prevention: same-day insurance verification at tender, and a re-check within 24 hours of pickup.
Third-party databases pull from the same L&I source, but most refresh on a slower cadence (24-72 hours typical, sometimes longer) and surface only the 'active' flag — not the cancellation date. They are useful for onboarding workflows but not sufficient on the tender day. Always pair them with a direct same-day read against the L&I register or a tool that does it for you.
Paste an MC or DOT — KnowHaul reads the L&I register live, surfaces the cancellation date, and flags any policy lapsing inside 30 days.
Free, no signup. Paste a DOT, MC, or VIN — verify right away.
Step-by-step checklist for vetting any motor carrier before tendering a load — operating authority, insurance, safety scores, inspection history, and identity flags.
Decoder ring for the free public carrier lookups every broker can reach — what each field means, what is missing, and how to read authority and inspection data without misinterpreting it.
How double brokering works in 2026, recent fraud patterns, and a prevention checklist for freight brokers and shippers who want to stop the bleed.
Open one of these profiles in a new tab to see how the checklist applies to a live carrier record.
Liability, cargo, effective date, cancellation date — and a 30-day lapse warning before the policy expires.