MCS-90, BMC-91X and Form E: which trucking filing does what
They do different jobs. The MCS-90 is an endorsement on your liability policy that requires the insurer to pay the public up to the federal minimum. The BMC-91 or BMC-91X is the certificate your insurer files with FMCSA to prove you carry that coverage. Form E is the certificate your insurer files with the Michigan State Police for intrastate authority.
- Side by side
- MCS-90: the endorsement
- BMC-91 and BMC-91X: the federal filing
- Form E, H and K: Michigan filings
- Which ones you need
- FAQ
Three forms come up in almost every trucking insurance conversation, and they are easy to mix up. One is part of your policy, one is a federal record, and one is a Michigan record.
Side by side
| MCS-90 | BMC-91 / 91X | Form E (Michigan) | |
|---|---|---|---|
| What it is | Endorsement on your liability policy | Certificate filed with FMCSA | Certificate filed with the Michigan State Police (CVED) |
| What it proves | Payment to the public up to the federal minimum | You carry the required federal liability | You carry the required state liability |
| Who handles it | Insurer attaches it | Insurer files it | Insurer or its authorized agent files it |
| Who needs it | For-hire and interstate motor carriers | Carriers with FMCSA operating authority | For-hire carriers running only inside Michigan |
| Rule | 49 CFR 387.15 | 49 CFR 387.313 | Michigan Motor Carrier Act, CVED |
MCS-90: the endorsement
- Required by 49 CFR 387.15 for all for-hire and interstate motor carriers, per FMCSA's filing chart.
- Attached to the policy, not to a truck. It applies to every vehicle under the policy that is subject to federal financial responsibility rules, whether or not the truck is listed.
- The insurer agrees to pay a final judgment for public liability up to the required limit, even where the policy itself would not respond.
- It does not cover your employees or the cargo you haul.
- You agree to pay the insurer back for anything it pays only because of the endorsement. It protects the public, not you.
BMC-91 and BMC-91X: the federal filing
Your insurer files this certificate with FMCSA to show you carry at least the federal minimum, $750,000 for most for-hire freight in trucks of 10,001 pounds or more. A BMC-91 certifies full limits from one insurer. A BMC-91X can certify full limits or one layer from several insurers. FMCSA will not grant operating authority until the filing is on record, and you must keep it on file after. More in our BMC-91X guide.
Form E, H and K: Michigan filings
- Form E. Proof of liability insurance for CVED Authority. The Michigan State Police application asks for a certificate of liability and a Form E from your insurer.
- Form H. Proof of cargo insurance. The Michigan State Police list it for household goods carriers.
- Form K. The insurer's cancellation notice. A filing stays in force until a Form K is received (Tyler Insurance Filings guide).
J. J. Keller's summary lists Michigan's intrastate liability minimum as a $750,000 combined single limit for vehicles over 10,000 pounds. Confirm the current amount with the Michigan State Police before you rely on it. The CVED application can take up to 30 days to process, and it also needs business registration and proof of workers' compensation or an approved exclusion.
Which ones you need
- Interstate for-hire: a liability policy with the MCS-90, and a BMC-91 or BMC-91X on file with FMCSA.
- Michigan intrastate for-hire only: CVED Authority with a Form E on file, renewed each year. Household goods carriers add a Form H.
- Both: the federal filing, plus a check of the Michigan State Police rules for interstate carriers. Interstate carriers of general freight do not renew CVED Authority each year if their UCR is current.
Official steps: Michigan State Police CVED Authority and FMCSA insurance filing requirements. You can also check your public FMCSA record with DOTView below.
FAQ
Is the MCS-90 an insurance policy?
No. It is an endorsement attached to your auto liability policy. FMCSA says it is not issued for individual vehicles; it applies to all vehicles under the policy that are subject to federal financial responsibility rules.
Does the MCS-90 cover my own losses?
No. It requires the insurer to pay a final judgment to the public for bodily injury, property damage and environmental restoration. It does not cover your employees or the cargo, and you must pay the insurer back for anything it pays only because of the endorsement.
Who files the BMC-91X?
Your insurance company, through its FMCSA filer account. Neither you nor your agent files it directly. A BMC-91X can certify full limits or one layer when several insurers combine.
What is a Form E in Michigan?
The certificate of liability insurance your insurer or its authorized agent files with the Michigan State Police, Commercial Vehicle Enforcement Division, for CVED Authority. It stays in force until the insurer files a Form K cancellation.
Do I need both a BMC-91X and a Form E?
Interstate for-hire carriers need the federal filing. Carriers that haul for hire only inside Michigan need CVED Authority with a Form E. If you do both, check the Michigan State Police requirements for interstate carriers.
This guide is general information, not legal advice or an offer of insurance. Rules and programs change; check the sources below. Helm Partners' Michigan license is pending, and we do not quote until licensed.
Sources
- FMCSA: Insurance Filing Requirements
- FMCSA: Form MCS-90
- 49 CFR 387.15: Forms (MCS-90)
- 49 CFR 387.313: Forms and procedures (BMC-91, BMC-91X)
- Michigan State Police: CVED Regulatory and Credentialing (CVED Authority, Form E)
- Tyler Insurance Filings: Michigan filing guide (Forms E, H, K)
- J. J. Keller: Intrastate operating authority, Michigan