Updated 2026-11-01
Carriers sometimes assume that one insurance filing covers everything. In practice, federal and state filings serve different regulators and different kinds of trips.
The federal side
FMCSA regulates interstate commerce. For-hire carriers with federal operating authority need their insurer to file proof of liability coverage with FMCSA, and household goods carriers need cargo coverage on file as well. Those filings support the federal authority and appear on FMCSA's public records.
The state side
States regulate intrastate commerce, meaning trips that begin and end in the same state without crossing state lines as part of a larger interstate movement. Many states require intrastate for-hire carriers to hold a state permit or authority, and to have their insurer file proof of coverage with the state agency. Commonly used forms are Form E for liability and Form H for cargo.
Why some carriers need both
A carrier with federal authority that also hauls local loads inside a state with intrastate requirements may need a state filing for those trips. Local movers, dump truck operators and tow companies sometimes operate only intrastate and never need a federal filing at all.
Deciding what applies
- Does any trip cross a state line, or continue a shipment that came from another state?
- Is the freight regulated or exempt?
- Does the state require intrastate authority for your type of operation?
- Does the state accept the uniform forms or use its own system?
Answering these questions, with the help of the state agency's guidance, tells you which filings you need.
One policy, several filings
A single commercial auto policy can often support several filings: one with FMCSA and one with each state that requires it. The insurer must be willing and authorized to file in each place. Tell your agent every state where you operate so nothing is missed.