Pennsylvania Truck Insurance Requirements (2026)

Federal vs state — who requires what

Two regulators set truck insurance requirements for Pennsylvania operators. The Federal Motor Carrier Safety Administration (FMCSA) sets minimums for any motor carrier running interstate freight. The Pennsylvania Public Utility Commission (PUC) sets minimums for intrastate operators — those running freight only inside Pennsylvania.

If the truck crosses a state line — even occasionally — federal rules apply. Most owner-operators with their own interstate authority fall under federal jurisdiction even if most of their work stays inside Pennsylvania. Knowing which regulator applies determines which filing the insurer makes and which minimums apply.

Interstate liability minimums

Federal minimums are set in 49 CFR 387.9 for property carriers and in 49 CFR 387.33T for passenger carriers. Most of the property schedule applies to vehicles with a gross vehicle weight rating (GVWR) of 10,001 pounds or more:

• For-hire, interstate, non-hazardous property (10,001 lb GVWR or more) — $750,000. Household-goods movers fall in this tier.
• Oil and hazardous materials not listed in the $5,000,000 tier (10,001 lb GVWR or more) — $1,000,000.
• Hazardous substances in bulk in cargo tanks, portable tanks, or hopper-type vehicles; bulk Division 1.1, 1.2, or 1.3 explosives; bulk Division 2.1 or 2.2 gases; bulk Division 2.3 (Hazard Zone A) and Division 6.1 (Packing Group I, Hazard Zone A) materials; and highway-route-controlled quantities of Class 7 radioactive material — $5,000,000.
• Under 10,001 lb GVWR: a for-hire carrier whose fleet is only these smaller vehicles hauling non-hazardous freight needs $300,000 (49 CFR 387.303T). Bulk explosives, Zone A materials, and highway-route-controlled Class 7 loads still require $5,000,000 at any weight.
• Passenger carriers — $1,500,000 for vehicles seating 15 or fewer including the driver, $5,000,000 for 16 or more (49 CFR 387.33T).

Pennsylvania intrastate minimums

For-hire carriers hauling property inside Pennsylvania under PUC authority must keep a certificate of insurance on file with the PUC. Under 52 Pa. Code § 32.12(a), the minimum is $300,000 per accident for a vehicle with a manufacturer's gross vehicle weight rating of 10,000 pounds or less, and $750,000 per accident for a vehicle rated over 10,000 pounds. For a tractor-trailer combination, the gross combination weight rating is what counts. These limits do not include cargo coverage: common carriers of property or household goods must also file cargo insurance of at least $5,000 under 52 Pa. Code § 32.13 (dump trucks and a few other operations are exempt). Passenger carriers have their own section of the rules.

Intrastate operations are rarer than they look on paper. A truck running between Allentown and Philadelphia is intrastate. A truck that picks up in Allentown, drops in Philadelphia, then takes a backhaul into Newark, NJ, is interstate even though most of the work was inside Pennsylvania. Federal jurisdiction is based on the nature of the haul, not the percentage.

Cargo and physical damage

Cargo and physical-damage coverage are not federally required for general freight, but they’re required by lenders, by leases, and by most shippers. The standard motor truck cargo limit on a typical dry van or flatbed runs $100,000. Specialty cargo (auto haulers, refrigerated, high-value freight) runs higher.

Cargo policies have exclusions worth reading carefully. Unattended trailer theft, contamination, and refrigerated breakdown are common carve-outs that get filled with endorsements when they apply. Reefer breakdown coverage in particular is its own line — a standard cargo policy often excludes spoilage from a refrigeration unit failure.

What brokers actually require

The FMCSA floor is rarely the operating standard. Most freight brokers and shippers require a $1,000,000 minimum primary liability on the COI. Some require $2,000,000. Cargo limits of $100,000 are typical for general freight. High-value and auto-hauler loads need a limit sized to the worst-case load: seven cars at $40,000 each is already $280,000 on one trailer.

If the COI shows the federal floor — $750,000 — many brokers screen the carrier out before a dispatcher ever sees the truck. Because most brokers require $1,000,000, most operators running broker freight carry it by default.

Of everything truckers ask us for, a current COI is the most time-sensitive, because a new broker or shipper wants one before the first load. Check that yours shows the right limits, the exact legal name on your authority, and the right certificate holder before you book the run.

Filings — BMC-91, MCS-90, BMC-34

Several FMCSA filings need to live with the policy. The BMC-91 (or BMC-91X) is the proof of financial responsibility the insurance carrier files with FMCSA. The MCS-90 endorsement is attached to the policy and confirms the carrier will pay public liability claims even if a coverage exclusion would normally apply. Household-goods carriers also need cargo coverage on file: the insurer files a BMC-34 certificate, backed by a BMC-32 endorsement on the policy (49 CFR 387.313T).

The insurer handles the filings, but late or missing filings put the operating authority in jeopardy. An insurer can't pull a filing overnight: a filing can't be cancelled until 30 days after the insurer submits written notice to FMCSA on Form BMC-35. Confirm the filings are in place after every new policy, renewal, or change of insurer.

Common compliance mistakes

• Letting the BMC-91 filing lapse. An insurer's cancellation only takes effect 30 days after its BMC-35 notice reaches FMCSA. If no replacement filing is on record by then, FMCSA can suspend or revoke the operating authority after giving notice (49 U.S.C. 13905(f)), and in practice it revokes it. Getting it back takes a new filing and a reinstatement request. That is true even if you bought a new policy but the new insurer never filed, so have the new insurer file before the old one cancels.
• Adding a power unit but forgetting to add it to the policy. Most carriers don’t auto-add new equipment — the operator has to call.
• Carrying $750,000 because that's the federal floor, then finding that brokers want $1,000,000.
• Underbuying cargo for the actual mix being hauled. The per-load limit needs to match real-world worst-case freight value.
• Letting a driver run hours of service that disqualify the carrier in an audit — insurance follows the safety rating, and a poor safety rating raises premiums or non-renews coverage.