Is Cargo Insurance Required by FMCSA?
Someone said cargo is optional, and you are about to run a broker load with none. Optional to FMCSA is not the same as optional to the broker, and it is not optional at all if you are a household-goods carrier.
General freight
No federal cargo filing
HHG
Cargo filing required
$100,000
A common contract, not a statute
COI
Not the L&I liability row
Ahmad Qazi
Founder & CEO, O Trucking LLC
Fact-Checked by O Trucking Owner-Operator Desk
Walks new authorities through Motus filings, insurance, and the first legal load after ACTIVE
Written by Ahmad Qazi, founder of O Trucking LLC, drawing on 9+ years dispatching for owner-operators. Learn more about us.
Is Cargo Insurance Required by FMCSA?
Key Takeaways
- Ordinary for-hire property carriers have no federal cargo-insurance filing.
- The required federal filing is auto liability, not cargo.
- Household-goods carriers must file cargo security. Do not tell them cargo is optional.
- A common broker demand of $100,000 cargo is a contract.
- Exclusions, not the limit, are where cargo claims die.
- A cargo line on a COI does not show up as the BMC liability filing. Do not use L&I as proof of cargo.
What Part 387 requires for general freight
FMCSA does not require motor-truck cargo insurance for ordinary for-hire property carriers. The federal filing that gates authority is public liability: bodily injury and property damage, evidenced by BMC-91 or BMC-91X, or a permitted surety. Cargo you are hauling for a shipper is your commercial problem and often your contract problem. It is not, for a dry van or a flatbed of non-HHG freight, a filing that has to post before the authority goes ACTIVE.
That sentence gets abused. Optional to the agency means the agency will not revoke you for lacking a cargo policy. It does not mean the freight is uninsured by magic, and it does not mean a broker's contract is void. It means you can hold ACTIVE authority and still be personally exposed to a $40,000 shortage.
Do not look for a cargo row on L&I for a general-freight MC and treat the absence as a system error. The absence is the rule. The liability row is the filing.
What it requires for household goods
Household-goods carriers do have a federal cargo filing. Do not tell an HHG applicant cargo is optional. 49 CFR 387.303(c) requires security of $5,000 for household goods on any one vehicle and $10,000 for loss at any one time and place. The insurer files BMC-34. The endorsement is BMC-32. A surety alternative is BMC-83. FMCSA's forms FAQ says this cargo certificate is for household-goods carriers and that only those carriers must file evidence of cargo insurance.
The HHG amounts are small next to a broker's $100,000 cargo schedule, and they are still mandatory. A mover who buys a large motor-truck cargo policy and never has BMC-34 transmitted has the contract coverage and not the filing. A mover who files BMC-34 and declines a broader policy has the filing and a thin limit. Read both.
If you are not an HHG carrier, do not file HHG cargo forms to look complete. File what your authority type requires.
Why every broker still asks for $100,000
Broker and shipper contracts commonly require $100,000 of motor-truck cargo. That is a contract, and it is how you get the load. The broker is buying a recovery path that does not depend on your balance sheet. The number is customary. It is not a line in 49 CFR 387.9. Some shippers want $150,000 or $250,000, or a reefer-breakdown endorsement on top. Those are negotiations.
Link out for price and for the difference between $100,000 and $250,000. Cargo insurance already covers limits and cost. This page will not run a second survey or invent a national premium.
If you sign the packet and you do not buy the coverage, the broker's later denial of freight is the smallest consequence. The cargo claim is the larger one. The federal authority staying ACTIVE does not pay the claim.
Reefer breakdown, debris removal, and unattended-truck exclusions
Exclusions matter more than the limit. An unattended-truck exclusion, a theft warranty that requires a locked padlock and a parked location you did not use, a target-commodity exclusion for electronics or alcohol, and a reefer-breakdown exclusion are where claims die. Name them when you read a specimen form. Do not assume a $100,000 limit means $100,000 for the loss you are about to have.
This page will not invent a percentage of cargo claims that are denied, and it will not invent a dollar cost for debris removal or for a reefer breakdown buy-back. Those numbers live on specimen forms and on quotes. Ask the agent to show the form. If the form excludes the commodity you haul, the limit is advertising.
Debris removal, earned freight, and debris-or-pollution sublimits show up as small numbers inside a large cargo policy. Read them if you haul bulk or anything that spills. They are not the federal filing either.
Pro Tip
A COI that lists cargo when L&I does not
A cargo line on a COI does not appear as a BMC liability filing. Teach yourself to stop using L&I as proof of cargo. L&I proves the liability filing the insurer transmitted. The COI proves whatever the agent typed, which should match a policy but is not independently the policy. Brokers mix the two screens and then accuse you of a lapse when cargo never had a federal row to lapse from.
When a setup desk says your insurance fell off, ask which row. If the BMC-91 is intact and they are looking for cargo on L&I, send the cargo certificate and explain that FMCSA does not display it for general freight. If the BMC-91 actually cancelled, you have an authority problem, not a cargo-display problem.
Keep the cargo policy number, the limit, and the exclusion summary in the same folder as the COI. The day of a theft is a bad day to learn the unattended-truck wording.
The claim you still owe if you declined the policy
Declining cargo insurance does not decline the loss. The bill of lading and the broker-carrier agreement still make you responsible for the freight you lose, damage, or fail to protect from a reefer failure, subject to whatever legal limits actually apply to that shipment. Carmack and contract terms are a claims discussion this page will not try to win. The practical point is smaller: if you declined the policy, the check comes from you.
A factor will not pay the claim for you. A dispatch service will not pay the claim for you. FMCSA will not pay the claim for you, because FMCSA never required the policy on a general-freight MC. The only person who thought cargo was optional in a way that erased the loss was you.
Buy the contract limit if you want the freight, read the exclusions if you want the claim paid, and do not call L&I looking for a cargo row that the rule does not put there. That is the whole answer to whether the government requires it.
What to verify before you act
Say the answer in the words the question used. For ordinary for-hire property, FMCSA does not require a cargo filing. For household goods, it does, at $5,000 per vehicle and $10,000 aggregate, on BMC-34 or BMC-83. For a broker packet, cargo is usually required by contract at $100,000 or whatever number they typed. Three different yes-or-no answers. Pick the one that matches the operation before you tell a driver that cargo is optional.
Then read the specimen for unattended truck, theft warranty, target commodity, and reefer breakdown. Write down which of those you actually need. A limit without those coverages is a certificate that will disappoint you on the exact loss you haul. Do not invent a denial statistic. Do invent the habit of reading the form before the first load that depends on it.
When a setup desk says your cargo fell off L&I, ask them to point at the row. General freight never had a cargo row there. Send the certificate. If what fell off is the BMC-91, stop and treat it as an authority problem. The two screens are not interchangeable, which is the mistake this question keeps producing.
Put the answer on the rate confirmation before you accept it. If you are general freight, you are buying cargo because the contract requires it, not because L&I will show it. If you are household goods, you are filing BMC-34 because the regulation requires it, and the contract may require more. Write which one you are in the dispatch notes so a night driver does not hear optional and skip a reefer endorsement you actually needed.
Frequently Asked Questions
Does FMCSA require cargo insurance on a dry van?
No. For ordinary for-hire property carriers, the federal filing is liability on BMC-91 or BMC-91X. Motor-truck cargo is not a Part 387 filing for that operation.
Does that mean I can run with no cargo policy?
You can be legal with FMCSA and still be in breach of every broker agreement you want to sign. Most broker packets require cargo coverage, commonly $100,000. You will also owe the shipper for cargo you lost, out of pocket, if you declined the policy.
Are household goods different?
Yes. HHG carriers must file cargo security. 49 CFR 387.303(c) sets $5,000 per vehicle and $10,000 aggregate. Do not tell an HHG applicant that cargo is optional.
Why does my COI show cargo if L&I does not?
Because the COI is a commercial snapshot and L&I shows the federal liability filing. Cargo on the certificate is not a BMC-91. Stop using L&I as proof of cargo, and stop using a cargo line as proof of authority.
What exclusions should I ask about?
Unattended truck, theft warranties, target commodities, and reefer breakdown are where claims die. Read the specimen form. This page will not invent a percentage of claims denied.
Where do I compare $100,000 and $250,000 cargo prices?
On the cargo insurance guide. This page only answers whether the government requires it.
Know which cargo rule applies before you roll.
O Trucking does not sell cargo policies. Dispatch after ACTIVE authority is flat weekly.