Key Takeaways
Every California truck operator faces the same compliance challenge: satisfying two separate insurance jurisdictions that overlap but don't align. Miss one filing, confuse a certificate with regulatory proof, or operate under the wrong policy tier, and you're looking at suspended authority, impounded equipment, and loads cancelled mid-route. The stakes are existential, yet most carriers learn these distinctions only after enforcement action.
This guide clarifies exactly what insurance you need, which agencies require which filings, and how to verify compliance before your first dispatch. Whether you're launching an owner-operator business, managing a growing fleet, or expanding from intrastate to interstate operations, understanding FMCSA versus California requirements isn't optional; it's the foundation of legal operation.
Federal and state regulations run parallel tracks. Interstate commerce triggers FMCSA jurisdiction under federal law. California's Department of Motor Vehicles regulates all commercial trucks operating in-state with a GVWR of 10,000+ lbs. Federal preemption means FMCSA insurance requirements supersede state law for interstate operations, but don't exempt you from California's Motor Carrier Permit requirements.
Understanding federal vs state trucking compliance is essential: one insurance policy can satisfy both $750,000 minimums, but your insurer must file proof separately: BMC-91/91X to FMCSA and MC 65 M to CA DMV. No filing means no compliance, regardless of coverage.
| Your Operation | FMCSA Filing? | CA MCP? | Minimum Liability | Key Forms |
| Interstate for-hire, 10,001+ lbs | ✓ Yes | ✓ Yes | $750,000 | BMC-91 + MC 65 M |
| Intrastate only, 10,000+ lbs | No | ✓ Yes | $750,000 | MC 65 M |
| Hazmat (placarded), any operation | Varies | ✓ Yes | $1M-$5M | Per operation |
| Household goods mover (CA) | Varies | ✓ Yes | $750k + $20k cargo | MC 65 M + CPUC |
| Under 10,000 lbs | Varies | ✓ Yes | $300,000 | Per operation |
| Operation Type | GVWR/Trigger | FMCSA Minimum | CA Minimum | Notes |
| General freight property | 10,001+ lbs | $750,000 | $750,000 | Harmonized |
| General freight property | <10,001 lbs | $300,000 | $300,000 | Harmonized |
| Hazmat (placarded) | Any | $1,000,000 | $1,000,000 | By reference |
| Hazmat (CERCLA/Superfund) | Any | $5,000,000 | $5,000,000 | Highest tier |
| Household goods (CA mover) | Any | N/A | $750k + $20k cargo | CPUC regulated |
| Passengers (9-15) | Any | $5,000,000 | $5,000,000 | Passenger tier |
| Factor | FMCSA (Interstate) | California MCP |
| Who it regulates | For-hire interstate carriers | All carriers, GVWR 10,000+ lbs |
| Proof mechanism | BMC-91/91X (with MCS-90) | MC 65 M certificate |
| Filing authority | FMCSA (federal) | CA DMV Motor Carrier Services |
| If it lapses | Operating authority suspended (30-day notice) | MCP suspended; registration risk |
| Workers' comp | Not federally required | Mandatory for CA employers |
Key insight: Interstate carriers operating in California need BOTH filings. Federal preemption means FMCSA rules govern interstate commerce, but doesn't exempt you from state Motor Carrier Permit requirements. One commercial truck insurance California policy satisfies both minimums, but your insurer must file separately with FMCSA (BMC-91) and CA DMV (MC 65 M). No exceptions.
Geography and cargo type determine jurisdiction. Interstate commerce, goods crossing state lines, triggers federal FMCSA authority. California intrastate trucking insurance applies to all commercial trucks 10,000+ lbs GVWR operating in-state, regardless of interstate status. Most carriers hauling out of California need both. Private carriers and intrastate-only operations need California compliance alone.
| Your Situation | FMCSA? | CA MCP? | Minimum | What to File |
| For-hire interstate (CA→NV) | ✓ | ✓ | $750k | BMC-91 + MC 65 M |
| Intrastate for-hire (CA only) | No | ✓ | $750k | MC 65 M only |
| Private carrier (own goods, CA only) | No | ✓ | $750k | MC 65 M only |
| Leased owner-operator | Depends | ✓ | $750k | Carrier may file BMC-91; you file MC 65 M |
| Broker/freight forwarder | ✓ Bond | No | $75k bond | BMC-84/85 (not liability) |
Compliance starts before you buy insurance. Name mismatches between USDOT registration, insurance certificate, and MCP applications trigger automatic rejections. Filing confirmation takes 3-5 business days minimum; don't operate until agency systems show active status. One policy satisfies both requirements, but requires separate filings to FMCSA and CA DMV.
Filing lapses trigger cascading penalties across multiple agencies. FMCSA issues 30-day suspension notices; California DMV acts faster. Brokers monitor SAFER databases daily, suspended carriers lose loads immediately. Roadside enforcement impounds vehicles on-spot. One lapse creates months of operational chaos.
The existential risk: Operating while suspended transforms a paperwork problem into a business-ending crisis. One roadside inspection equals vehicle impounded, load abandoned, driver stranded. You're personally liable for any accident damages, no policy protection. Brokers blacklist carriers with filing gaps. Insurance markets tighten: carriers with suspensions face 50%+ premium increases or non-renewals.
The cost of one week suspended (lost revenue, impound fees, emergency insurance, expedited filings) exceeds years of proper compliance costs. Reinstatement requires paying all back premiums, filing fees, and waiting for agency processing, minimum two weeks with zero revenue.
Personal auto minimum: $15k/$30k/$5k. Motor carrier minimum: $750,000 for GVWR 10,000+ lbs. Operating with a personal policy on a commercial truck equals operating uninsured, zero coverage for commercial liability. Personal policies exclude business use.
Fix: Always purchase commercial motor carrier policy. Verify agents can file MC 65 M with CA DMV.
COI satisfies brokers and shippers before tendering loads. Regulatory filings (BMC-91, MC 65 M) satisfy government agencies. Having a COI doesn't mean you've filed proof with FMCSA or DMV. Brokers can't verify regulatory compliance, only agency databases show true status.
Fix: Independently verify filing status with agencies before operating. Never rely on agent promises alone.
If leased to a carrier operating under their MC number, they file BMC-91 for interstate authority. But you still need your own CA MCP and MC 65 M filing. The carrier's insurance doesn't satisfy your state permit requirement; DMV requires proof in your name.
Fix: Review the lease agreement with your insurance agent. Confirm who files what. Get both carriers' and your own filing confirmations in writing.
Yes, one $750,000 policy meets both minimums. But your insurer must file separately with FMCSA (BMC-91) and CA DMV (MC 65 M). One policy, two filings.
Most common: name mismatch between policy and USDOT/MCP registration, wrong limit tier, missing identifiers (USDOT/CA#), effective date gaps, form errors, agency processing backlogs (7-14 days).
Interstate for-hire carriers need FMCSA filing (BMC-91 with MCS-90) plus CA MCP filing (MC 65 M). Intrastate CA-only operations need CA MCP filing only (MC 65 M). One policy works for both, but insurers must file separately with each agency. Verify independently using FMCSA Safer Web and CA DMV before operating; never trust an agent's word alone. Common minimums: $750k for GVWR 10,000+ lbs; $1M-$5M for hazmat; $300k under 10,000 lbs.
Certificate of Insurance isn't the same as a regulatory filing: COI is for brokers; BMC-91/MC 65 M is for government agencies. Operating while suspended equals vehicle impounded, personal liability, and business-ending consequences.
Need California truck insurance that's filed the first time correctly? Contact SoCal Truck Insurance for expert guidance on FMCSA and CA DMV compliance. We handle the filings so you can focus on hauling.
