October 19, 2026

MCS-90 Form: What It Is and Why Your Authority Needs It (2026)

Quick Answer

Form MCS-90 is a federal endorsement attached to your truck liability policy. It guarantees the insurer will pay final judgments for injuries, property damage, or environmental cleanup caused by your trucks, up to the federal minimum ($750,000 for most for-hire general freight), even when the policy itself wouldn't cover the crash. You keep it on file; your insurer files a BMC-91X with FMCSA so your authority goes active.

Key Takeaways

The MCS-90 is required proof of financial responsibility under 49 CFR 387.7(d) and must be kept at your principal place of business.
Minimums come from 49 CFR 387.9: $750,000 for for-hire non-hazardous freight in trucks of 10,001 lbs GVWR or more, $1,000,000 for most hazmat and oil, and $5,000,000 for the most dangerous bulk hazmat.
The MCS-90 protects the public, not you. If the insurer pays a claim it wouldn't otherwise owe, you agree to pay it back.
The BMC-91 or BMC-91X is a different document: a certificate your insurer files with FMCSA to prove coverage for your operating authority.
Your insurer can't drop the filing quietly. It must give you 35 days' written notice, and the FMCSA filing can't be cancelled until 30 days after FMCSA receives the notice.

“The MCS-90 is a federal endorsement attached to a motor carrier's liability policy. It guarantees the insurer will pay final judgments for public injury or damage up to the federal minimum, such as $750,000 for general freight, even if the policy wouldn't otherwise cover the crash. You keep it on file; your insurer files the BMC-91X with FMCSA.”

What is an MCS-90?

The full name is "Endorsement for Motor Carrier Policies of Insurance for Public Liability under Sections 29 and 30 of the Motor Carrier Act of 1980." Everyone just calls it the MCS-90, or the MCS-90 endorsement.

An endorsement changes the terms of an insurance policy. The MCS-90 makes your auto liability policy meet federal financial responsibility rules. 49 CFR 387.15 requires it to be on FMCSA's prescribed form, issued in the exact name of the motor carrier, and to stay in effect continuously until terminated.

FMCSA's MCS-90 form page adds that the endorsement isn't issued per truck. It attaches to the policy and applies to every vehicle you run under that policy that's subject to the federal rules.

What does the MCS-90 endorsement actually do?

It's a guarantee to the public. Under the current FMCSA form (Rev. 7/6/2024), the insurer agrees to pay any final judgment against you for public liability caused by negligent operation of your trucks:

whether or not that truck is listed on the policy
whether or not the crash happened on a route or in a territory you're authorized to serve
regardless of your financial condition, insolvency, or bankruptcy

No policy condition or exclusion can relieve the insurer of that duty, up to the limit shown on the endorsement. "Public liability" means bodily injury, property damage, and environmental restoration.

There are two big limits. The MCS-90 doesn't cover injury to your own employees on the job, and it doesn't cover the cargo you're hauling.

The catch for you is the reimbursement clause. You agree to repay the insurer for any payment it would not have owed under the policy except for the MCS-90. Example: you add an unlisted truck, it causes a $200,000 crash, and the policy excludes unlisted units. The injured driver still gets paid through the MCS-90, then the insurer can come after you for the $200,000.

Who needs an MCS-90?

Part 387, subpart A covers these carriers (49 CFR 387.3 and related rules):

For-hire carriers of property in interstate or foreign commerce, including owner-operators and hot shot carriers under their own authority
Carriers of hazardous materials, substances, or wastes, for-hire or private, interstate or (for some bulk loads) intrastate
Hazmat safety permit holders, who can't get a permit without the minimum coverage required by 387.9 (49 CFR 385.407)
Carriers domiciled in Canada or Mexico, who must also carry a legible English copy of the MCS-90 or MCS-82 in every vehicle (387.7(f))

The rules generally don't apply to vehicles under 10,001 lbs GVWR unless they haul certain high-hazard materials (387.3(c)). A private carrier hauling its own non-hazardous goods isn't covered by this subpart either.

Bus and motorcoach companies use a separate version, the MCS-90B, under 49 CFR 387.39. Their minimums are $5,000,000 for vehicles seating 16 or more, and $1,500,000 for 15 or fewer.

Here are the property limits the endorsement must meet:

Operation (10,001+ lbs GVWR unless noted)	What you haul	Minimum
For-hire, interstate	Non-hazardous property	$750,000
For-hire or private	Oil, and hazmat not listed in the other rows	$1,000,000
For-hire or private	Bulk hazardous substances, bulk Division 1.1 to 1.3 explosives, bulk Division 2.3 Zone A, and other high-hazard bulk loads listed in 387.9	$5,000,000
For-hire or private, under 10,001 lbs GVWR	Bulk Division 1.1 to 1.3, Division 2.3 Zone A, 6.1 PG I Zone A, or highway route controlled Class 7	$5,000,000

These are federal floors; most brokers ask for $1 million as a business requirement. Our new authority trucking insurance post covers how to bring that premium down.

One edge case: a for-hire fleet made up only of vehicles under 10,001 lbs GVWR needs $300,000 for its authority filing (49 CFR 387.303T), and the rules point to a different endorsement, the BMC-90, for that coverage. Ask your insurer which one applies.

MCS-90 vs BMC-91X: what's the difference?

The MCS-90 answers "will the public get paid?" The BMC-91X answers "does FMCSA know you're insured, so your authority can be active?"

Under 49 CFR 387.301T, no for-hire carrier can hold operating authority unless a certificate of insurance, surety bond, or other security has been filed with and accepted by FMCSA. That certificate is the BMC-91 or BMC-91X. Per 49 CFR 387.313T, the BMC-91 certifies the full limit, while the BMC-91X can show full coverage or any layer of coverage stacked across several insurers. When the coverage is also subject to DOT minimums, an MCS endorsement such as the MCS-90 must go with it.

	MCS-90	BMC-91 / BMC-91X	MCS-82
What it is	Endorsement added to your liability policy	Certificate of insurance	Surety bond
Who provides it	Your insurer	Your insurer files it	A surety company
Where it lives	Your files, at your principal place of business	FMCSA's records, filed online by the insurer	Your files, at your principal place of business
What it proves	The public will be paid up to the federal minimum	You have the coverage your operating authority requires	Same guarantee as the MCS-90, backed by a bond instead of a policy
Rule	387.7(d)(1), 387.15	387.301T, 387.313T	387.7(d)(2), 387.15
Needed for	Compliance with 387.7	Getting and keeping MC authority	An alternative to the MCS-90

Other filings you'll hear about: household goods carriers also file cargo coverage on the BMC-34 ($5,000 per vehicle, $10,000 per occurrence), and brokers and freight forwarders file a $75,000 bond or trust fund on the BMC-84 or BMC-85, according to FMCSA's insurance filing requirements page.

How do you get an MCS-90 and get your authority active?

You don't fill out an MCS-90 yourself. Your insurer issues it with the policy.

Apply for your USDOT number and operating authority in Motus (motus.dot.gov). The steps are in our hot shot trucking requirements guide.
Bind a liability policy that meets the 387.9 minimum for what you haul, in the exact legal name on your application.
Ask the insurer to file the BMC-91 or BMC-91X under your MC number. FMCSA says that if the filing isn't made within 20 days of your application's publication in the FMCSA Register, it serves a decision giving you 60 days before the application is dismissed.
Get a copy of the MCS-90 from your agent and file it with your authority paperwork at your place of business.
Confirm your status shows ACTIVE before you haul. Your MC authority letter and first 90 days checklist cover what comes next.

FMCSA warns that your name and address must match exactly across your state registration, application, and insurance filings, or the grant is delayed.

What happens if your MCS-90 coverage lapses?

Coverage must stay in effect continuously until terminated (387.7(b)(1)). Two notice clocks protect you:

Between you and your insurer: either side cancels with 35 days' written notice, counted from when the notice is sent.
With FMCSA: the insurer files a cancellation notice (Form BMC-35). The filing can't be cancelled until 30 days after FMCSA actually receives it (387.313T(d)).

Use those 30 days to get a replacement filed. It ends the old insurer's liability on the new filing's effective date, so there's no gap.

If nothing replaces it, FMCSA's April 29, 2026 Federal Register notice on Motus is direct: a registrant that fails to keep the required insurance on file "will be revoked or suspended involuntarily." Brokers check your status before tendering loads, so a revoked authority stops your revenue right away.

Running without coverage is also a violation of 387.7(a). Under 387.17, each day of a continuing violation counts as a separate offense, with penalties set in part 386, appendix B.

How does the MCS-90 come up in the new entrant safety audit?

Operating without the required minimum financial responsibility under 387.7(a) is one of the 16 automatic-failure violations in 49 CFR 385.321. One instance is enough to fail.

In practice the auditor asks for proof of coverage, which usually means your MCS-90 (or MCS-82), and checks the limit against what you haul. A carrier hauling $1,000,000-tier hazmat on a $750,000 endorsement has a problem even with an active authority. Our new entrant safety audit guide covers the full document list and what happens if you fail.

Before the audit, check that the endorsement names your exact legal entity, the limit fits your highest-risk freight, and the dates cover your whole operating period.

New authority? Get an FMCSA-registered ELD set up before your first load

Educational content, not legal advice. Confirm requirements against current FMCSA regulations and your state's rules.

FAQ

Do I need to keep the MCS-90 in my truck?

Not as a federal rule for U.S.-based carriers. Section 387.7(d) requires the proof at your principal place of business. Carriers domiciled in Canada or Mexico must carry an English copy in each vehicle.

Is the MCS-90 the same as a certificate of insurance?

No. The certificate a broker asks for and the BMC-91X filed with FMCSA prove you have coverage. The MCS-90 changes your policy's terms to guarantee payment to the public.

Does the MCS-90 cover my cargo or my own truck?

No. It covers public liability only: injury, property damage to others, and environmental restoration. Cargo and physical damage need separate coverage.