Who regulates you: TxDMV, FMCSA, or both
People say Texas DOT insurance, but two agencies handle the paperwork. The Texas Department of Motor Vehicles (TxDMV) runs intrastate operating authority through its TxMCCS system. The Federal Motor Carrier Safety Administration (FMCSA) runs interstate registration and authority.
The dividing line is simple. If every load starts and ends in Texas and never crosses a state line, TxDMV sets your insurance minimum.
If you haul for hire across state lines, FMCSA sets it. Some carriers hold both, such as a carrier running I-35 to Oklahoma City on some loads and Texas-only aggregate on others.
TxDMV intrastate minimum limits
These are the auto liability minimums TxDMV lists for carriers that need a TxDMV number. They are combined single limits per occurrence.
| Operation | Minimum liability | Cargo |
|---|---|---|
| Private or for-hire carrier, vehicles over 26,000 lbs | $500,000 | Not required by law |
| Oil, petroleum, and listed hazmat requiring placards | $1,000,000 | Not required by law |
| Division 1.1 to 1.3 explosives, bulk 2.1 or 2.2 gases, other top-class hazmat | $5,000,000 | Not required by law |
| Household goods mover, under 26,000 lbs | $300,000 | $5,000 per vehicle, $10,000 aggregate |
FMCSA minimum limits under 49 CFR 387.9
These apply to for-hire carriers of property in interstate commerce, and to carriers of hazmat that federal rules reach. The limits are public liability: bodily injury, property damage, and environmental restoration.
| Operation | GVWR | Minimum liability |
|---|---|---|
| For-hire, nonhazardous property | 10,001 lbs or more | $750,000 |
| Oil and hazmat listed in 49 CFR 172.101, outside the top class | 10,001 lbs or more | $1,000,000 |
| Certain bulk hazmat, Division 1.1 to 1.3 explosives, bulk 2.1 or 2.2, highway route controlled quantity Class 7 | Any covered vehicle | $5,000,000 |
- FMCSA's insurance requirements page lists a $300,000 filing amount for for-hire nonhazardous carriers under 10,001 lbs GVWR. That matters for small hot shot and cargo van authorities.
- Interstate household goods carriers file $5,000 in cargo coverage on top of liability.
Who needs a TxDMV number
TxDMV requires intrastate registration if you operate on Texas roads and any of these apply:
- A commercial vehicle or combination over 26,000 lbs
- Household goods hauled for hire, at any vehicle size
- A vehicle designed to carry more than 15 passengers, including the driver
- A farm vehicle over 48,000 lbs
- Hazardous materials in quantities that require placards
- A commercial school bus
USDOT number vs MC number
These two numbers get mixed up all the time. A USDOT number identifies your company for safety tracking.
An MC number is operating authority, the federal permission to haul for hire across state lines. Texas requires a USDOT number even for intrastate carriers, and TxDMV says to register with USDOT as intrastate if you never leave Texas.
| Number | Issued by | Who needs it |
|---|---|---|
| USDOT number | FMCSA | Interstate carriers at 10,001 lbs or more, and Texas intrastate carriers before they apply to TxDMV |
| MC number | FMCSA | Interstate for-hire carriers of federally regulated freight. Private carriers and carriers of only exempt commodities do not need one. |
| TxDMV number | TxDMV through TxMCCS | Texas intrastate carriers that meet the list above |
Which filing goes where
You do not file insurance proof yourself. Your insurer does, electronically, with the right agency. Your job is to make sure the filing is active and stays that way.
| Form | Filed with | Filed by | What it proves |
|---|---|---|---|
| Form E | TxDMV in TxMCCS | Your insurer | Intrastate auto liability |
| Form H and Form I | TxDMV in TxMCCS | Your insurer | Household goods cargo coverage |
| Form K | TxDMV in TxMCCS | Your insurer | Cancellation of liability coverage |
| BMC-91 or BMC-91X | FMCSA | Your insurer | Interstate public liability |
| BMC-34 | FMCSA | Your insurer | Household goods cargo coverage |
| BOC-3 | FMCSA | You or a process agent company | Process agents in each state, not insurance |
| MCS-90 | Not filed. Attached to your policy and kept at your principal place of business. | Your insurer issues it | Federal financial responsibility |
Step by step: getting filings in place
The order matters. A filing sent before the agency has a record to attach it to can stall your start date. The table shows the order for each type of carrier.
| Step | Texas intrastate carrier | Interstate for-hire carrier |
|---|---|---|
| 1 | Get a USDOT number, registered as intrastate | Apply for a USDOT number and MC number through FMCSA |
| 2 | Bind auto liability at or above the TxDMV minimum | Bind auto liability at or above the 387.9 minimum |
| 3 | Insurer files Form E in TxMCCS (plus Forms H and I for movers) | Insurer files BMC-91 or BMC-91X (plus BMC-34 for movers) |
| 4 | Apply for the TxDMV certificate in TxMCCS and pay fees | File the BOC-3 through a process agent company |
| 5 | Print cab cards for each truck | Register for UCR and wait for authority to show active on L&I |
Filing mistakes that hold up your authority
Most filing delays come from small mismatches. Check the details before the insurer files, not after.
- The legal name on the policy does not match the name on your USDOT or TxDMV record.
- The insurer files under the wrong number, such as the USDOT number when FMCSA needs the MC docket.
- The filing goes to FMCSA when you need a Texas intrastate Form E, or the other way around.
- The limit on the filing is below the minimum for your cargo, such as $750,000 for a placarded petroleum load.
- A policy renews with a new insurer but the old filing cancels before the new one is on record.
- Your TxMCCS email is out of date, so you miss the 30-day cancellation notice TxDMV sends.
Which limit applies to common Texas operations
Use the numbers above to find your floor. A few common setups:
- A Texas-only dump truck hauling aggregate around Austin on SH-130, over 26,000 lbs: TxDMV minimum of $500,000.
- A hot shot pickup and gooseneck at 10,001 lbs GVWR or more hauling oilfield equipment from Odessa into New Mexico for hire: FMCSA minimum of $750,000.
- A placarded fuel tanker running Corpus Christi to San Antonio on I-37: $1,000,000 under TxDMV rules.
- A Houston-area mover with a 24-foot box truck under 26,000 lbs: $300,000 liability plus household goods cargo coverage.
How this guide differs from the requirements guide
This page sticks to the government minimums and the paperwork. It does not cover the $1,000,000 auto liability and $100,000 cargo most brokers want, or the physical damage your lender requires.
For that full stack, read our Texas truck insurance requirements guide. Once you know your floor, ask your agent which filings the quote needs.
Coverage this guide touches
Questions truckers ask
Do I need a TxDMV number if I already have a USDOT number?
If you run intrastate in Texas and meet a TxDMV trigger, yes. A USDOT number alone does not give you Texas intrastate authority. TxDMV wants the USDOT number first, then you apply for intrastate authority through TxMCCS, and your insurer files Form E. Purely interstate carriers with an MC number generally rely on their federal authority instead.
Is the Texas intrastate minimum lower than the federal minimum?
For general freight, yes. TxDMV requires $500,000 for vehicles over 26,000 lbs, while FMCSA requires $750,000 for for-hire interstate carriers of nonhazardous property at 10,001 lbs GVWR or more. Hazmat minimums line up more closely at $1,000,000 and $5,000,000. Most broker contracts still ask for $1,000,000 regardless of which floor applies to you.
Who files my insurance with TxDMV or FMCSA?
Your insurance company files it electronically. TxDMV says only the insurer can file proof of insurance or a cancellation in TxMCCS. FMCSA also expects the insurer to file the BMC-91 or BMC-91X after you apply for authority. You cannot upload a certificate yourself, so tell your agent exactly which agency and number the filing belongs to.