TL;DR: Under 49 CFR 387.9, for-hire carriers hauling non-hazardous freight in vehicles rated 10,001 pounds or more must carry at least $750,000 of liability coverage. Oil and most listed hazardous materials require $1,000,000, and bulk high-hazard commodities require $5,000,000. Most shippers demand $1,000,000 regardless of the legal floor.
What limits does federal law actually require?
The floors live in 49 CFR 387.9, and they have been at the same dollar levels since January 1, 1985. The limit that applies to you depends on what you haul, how big your vehicles are, and whether you run for-hire or private. The money covers public liability, which means bodily injury, property damage, and environmental restoration together, not three separate limits.
| Tier | Who it covers | Commodity | Minimum |
|---|---|---|---|
| 1 | For-hire, interstate, vehicles 10,001 lbs GVWR or more | Non-hazardous property | $750,000 |
| 2 | For-hire and private, 10,001 lbs or more | Bulk hazardous substances in cargo tanks or hoppers, bulk explosives Division 1.1 to 1.3, bulk poison gas Zone A, bulk Division 2.1 and 2.2 gases, highway route controlled radioactive material | $5,000,000 |
| 3 | For-hire and private, 10,001 lbs or more | Oil listed in 49 CFR 172.101, and other listed hazardous materials not in tier 2 | $1,000,000 |
| 4 | For-hire and private, vehicles UNDER 10,001 lbs | The same worst-class bulk commodities as tier 2 | $5,000,000 |
Does the $750,000 floor apply to private carriers?
No, not for ordinary freight. The $750,000 tier reaches for-hire carriers of non-hazardous property. A private carrier hauling its own non-hazardous goods has no minimum under 49 CFR 387.9. The hazmat tiers are different: they apply to private and for-hire carriers alike, and the $5,000,000 bulk tier even reaches vehicles under 10,001 pounds.
Is $750,000 actually enough to run on?
Legally, yes, for general freight. Commercially, almost never. Most brokers and shippers require $1,000,000 of auto liability on their carrier agreements before they will tender a load, so the market floor sits above the legal floor. A serious injury crash can also blow through $750,000 quickly, leaving your business assets exposed. That is why many fleets add excess or umbrella liability on top of the primary limit.
What about smaller trucks and passenger vehicles?
On the filing side, 49 CFR 387.303 sets $300,000 as the requirement for for-hire fleets that run only vehicles under 10,001 pounds hauling non-hazardous property, such as hotshot and cargo van operations below that weight. Passenger carriers have their own schedule under 49 CFR 387.33: $1,500,000 for vehicles seating 15 or fewer including the driver, and $5,000,000 for vehicles seating 16 or more.
Have the minimums changed recently?
No. The dollar amounts in 49 CFR 387.9 have not increased since January 1, 1985, although the table's wording was last amended in a housekeeping rule in November 2023. Proposals to raise the $750,000 floor have appeared in Congress and at FMCSA over the years, but none has become law as of July 2026. If someone tells you a higher federal minimum already applies, ask them for the regulation number, because 387.9 still says $750,000.
How do the minimums connect to my filings and endorsement?
Three pieces move together. Your policy must carry at least the 387.9 limit for your tier. Your insurer files a BMC-91 or BMC-91X certificate with FMCSA showing that limit. And the MCS-90 endorsement on the policy proves financial responsibility at your place of business. If you change commodities, for example adding tanker hazmat work, your limit, your filing, and your endorsement all need to move up together before you haul the first load.
Real questions owner-operators and new authorities ask
Is the federal minimum $750,000 or $1,000,000?
The legal floor for for-hire non-hazardous freight in vehicles 10,001 pounds or more is $750,000 under 49 CFR 387.9. The $1,000,000 figure is the market standard most shippers and brokers require by contract, and the legal floor for oil and most listed hazmat.
What limit do I need to haul fuel?
Oil listed in 49 CFR 172.101 takes a $1,000,000 minimum. Many bulk fuel and gas operations fall into the $5,000,000 tier when the commodity is a bulk hazardous substance or a Division 2.1 or 2.2 gas in bulk. Match the tier to the exact commodity before binding.
Do hotshot trucks under 10,001 pounds have a federal minimum?
For non-hazardous freight, the coverage schedule in 49 CFR 387.9 starts at 10,001 pounds, but FMCSA's filing rules in 49 CFR 387.303 require $300,000 for for-hire fleets running only lighter vehicles. Hazmat in bulk requires $5,000,000 even under 10,001 pounds.
Are the minimums per crash or per year?
The limits are the minimum level of financial responsibility for each accident. They cover bodily injury, property damage, and environmental restoration combined, not separately. Your policy's limit structure should meet or exceed the tier for every vehicle you operate.
Will the federal minimums increase soon?
As of July 2026, no increase has become law. The amounts in 49 CFR 387.9 have been unchanged since January 1, 1985. Watch FMCSA rulemaking for changes, and remember shippers can and do require more than the federal floor by contract.
Why truckers work with Morrow
- We know the filings. Morrow matches your liability limit to your commodity tier under 49 CFR 387.9 and to what your shippers actually require.
- New authority is our normal. First-year carriers pay the most and get declined the most. We work with markets that actually want new ventures and we tell you what the first renewal takes.
- Certificates and filings, fast. Certificates of insurance the same business day for most carriers, and federal or state filings submitted electronically so your authority is not sitting in a queue.
- We quote the whole picture. Liability, cargo, physical damage, and the endorsements shippers and brokers actually check for, priced together so nothing is missing when a load is on the line.
- Real people when something goes wrong. A claim, a lapse notice, or a lost certificate gets a person, not a portal.
Related trucking guides
Short answers to the surrounding questions truckers ask next.
- Trucking insurance at Morrow (start here)
- What is an MCS-90 endorsement?
- BMC-91 and BMC-91X filings, explained
- Primary auto liability for truckers
- Excess and umbrella liability for truckers
- Insurance you need to get an MC number
- Commercial auto for trucking fleets
- Commercial umbrella for trucking
This guide is general information, not legal, tax, or insurance advice. Limits, forms, and deadlines change, so verify current requirements with FMCSA before you rely on them. Morrow is a brand name of Afthonea Inc. Last updated: July 2026.