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On Sept. 24 I pulled the Federal Motor Carrier Safety Administration's public Motus-system registration files from data.transportation.gov, and counted every operating authority application sitting in Pending status. There were more than 22,000. In 21,400 of them, or 95.4%, no required liability insurance filing was recorded.
The unfiled count went from 16,606 back on Aug. 23 to 22,000-plus on Sept. 24, up 28.7% in a single month.
In 9,354 of those, or 43.7%, no BOC-3 was matched to the docket either. Median age of a pending application without a filing: 41 days.
Measured against the roughly 90-day window FMCSA describes in its own FAQ about how long it typically gives new entrant carriers before dismissing the authority application entirely, 3,648 of the pending applications were already past that, and another 1,798 had 14 days or less left.
Two things to know about those numbers.
- FMCSA's public files record the insurance filing, not the policy itself, so a filing on record can still have been canceled.
- Records touched by the May move to Motus can carry statuses that have gone stale. Formal dismissals, for one, ran about 100 a month through February and stopped entirely in June, July and August post-Motus, so an application already past its window can still show as Pending. Read a single snapshot as a picture of the line rather than a verdict on any one company.
The number in the rule is 20 days, not 90
The FMCSA FAQ referenced above says an application is dismissed if insurance and BOC-3 are missing "approximately 90 days from the date of filing." The regulation is written from the other end, basically giving any New Entrant carrier 20 days from the date that notice of your application is published in the FMCSA Register to get proof of financial responsibility (insurance) on file, and 20 days for the BOC-3 process agent filing.
Nothing gets closed on day 21. FMCSA serves a decision telling you the application will be dismissed unless you comply within another 60 days. That is where the FAQ's "approximately 90 days" comes from, though the two are not the same clock: the FAQ counts from the date you filed, the regulation counts from the date your notice published. Either way, the 60 days is a rescue and not your deadline.
The clock starts at publication in the FMCSA Register, not the day you hit submit. If you plan against 90 days, you will get a decision notice in the mail and find out what your real deadline was.
[Related: What's wrong with this picture? Motus insurance mess costing small fleets thousands]
Line up insurance before you file
You cannot file your own proof of insurance.
FMCSA is blunt about it: Form BMC-91 or BMC-91X "must be submitted electronically by a registered electronic filer (a representative of an insurance company, surety company, or financial institution)."
A surety can file a BMC-82 instead of an insurer's BMC-91, and a large carrier can qualify as a self-insurer, but in every version somebody else's registered account, not yours, does the transmitting.
FMCSA lists the forms, and will not take one from you.
BMC-91 is the single insurer certificate. BMC-91X is the form used when the required limit is built from more than one insurer or layer, with each carrier of a layer filing its own. FMCSA lists them as alternatives and leaves the choice to the insurer.
Minimum requirements, well-known to many of you: $750,000 for for-hire, non-hazardous property in interstate commerce at 10,001 lbs. GVWR or more. Running under 10,001 lbs. GVWR for hire, the figure is $300,000. Hazmat requires $1 million or $5 million, depending on commodity.
[Related: Trucking insurance: What's necessary, and what owner-ops can expect to pay]
The dollar figures have not moved since Jan. 1, 1985, which is literally the column heading in the table shown with 49 CFR 387.9, the regulation that outlines most minimums. (FMCSA touched the surrounding text as recently as July, so anyone telling you the minimums went up this year is describing a wording change, not a number.)
The practical part: have a quote you can bind the day your docket number exists with publication in the FMCSA Register.
Ask your agent two direct questions before you buy.
- Who does your FMCSA filing? And:
- How many business days after I bind until it hits the system?
Every day of that lag comes out of your 20.
BOC-3 is one form, and FMCSA does not charge for it
Part 366 of the regulations requires a designation of process agents, filed on Form BOC-3, and only one current form can be on file at a time.
A process agent has to live or keep an office in the state it is designated for. The effective rule for carriers, 366.4T(a), requires an agent for every state you are authorized to operate in and every state you traverse; in practice everyone satisfies that with a blanket designation covering the 48 contiguous states and DC.
Brokers have a narrower job under 366.4T(b): only the states where their offices are or where contracts will be written.
Watch the single-form rule if you change agents. A new BOC-3 replaces the old one entirely, so a partial filing wipes out coverage you already had.
FMCSA charges nothing for the BOC-3 itself. The $35 you see quoted is the blanket agent's price, and calling it a government fee is simply wrong.
What the money actually is, and what it’s for
The filing fee is $300 per type of authority. Applying for motor carrier and broker authority together is $600. The money isn’t refunded whether the application is granted, denied, rejected before docketing, dismissed or withdrawn.
As of Sept. 30, 2025, FMCSA does not process paper payments of any kind, no checks and no money orders, on any transaction. Registration fees are paid by debit or credit card through FMCSA's own registration pages.
Other numbers worth knowing:
- $80 to reinstate a revoked authority
- $14 for a name change
- $100: Temporary authority issued in an emergency situation; FMCSA limits this to true disasters/national emergencies.
- $10: FMCSA’s service fee per accepted insurance certificate, billed to your insurer's filing account rather than to you, though it usually reaches you inside what your agent quotes.
Getting into Motus without losing a week, if you haven’t already
The old registration process was paused beginning May 14 at 8 p.m. ET, and Motus opened to everyone May 19. Access runs through Login.gov plus identity verification, which FMCSA runs through Idemia.
If you already have a USDOT number, use the same Login.gov email address that was listed for the company official in the old FMCSA Portal. Use a different one and the claim on your own record will not go through. FMCSA's own claim instructions lead with it, and it is the failure mode that shows up first in the agency's registration alerts.
One known snag: if your email gets registered by mistake in a “Transportation Service Provider” role when you first log into Motus to link a USDOT number to your account, the "Link a USDOT Number" option will be grayed out. Sign in, open the TSP account page, use the gear icon and select “Close Account,” then try the claim again.
Still grayed out? Open a ticket at ask.fmcsa.dot.gov with your USDOT, the company official's name and Login.gov email, and proof of ownership such as an Internal Revenue Service letter or articles of incorporation.
What did not change in this Motus transition phase: MC numbers still exist, the MCS-150 form is still accepted, and the BOC-3 process is the same. What did change:
- New USDOT and docket numbers are now randomized.
- New USDOT numbers carry a letter suffix showing entity type and the registrations granted.
- Each newly granted authority gets its own docket number, even if you asked for several (carrier and broker together, for instance) in one application.
[Related: Motus: 6 known issues ID'd by Fusable's CAB, some stranding carriers OOS after inspection]
The 10-day protest window
Once your notice publishes in the FMCSA Register, interested parties have 10 days to protest. For a property carrier or a broker this is a fitness question only. Grounds for protest: Someone can argue you do not meet financial responsibility and/or safety fitness requirements, not that the market does not need you.
There is nothing to do about the protest window except to be compliant when it opens.
If, despite all your best efforts, your roughly 90 days has run out and your authority application dismissed by the agency, know that’s equivalent to a rejection. You refile under the same USDOT and MC number and pay the $300 again, now through Motus. (For what it’s worth, FMCSA's dismissal FAQ still points to the retired Licensing and Insurance screens and has not been updated since 2023.) Before you refile, get the insurance filing and the BOC-3 in place. Refiling with the same two holes open buys you the same clock, at the same price.
Separately, FMCSA has temporarily suspended inactivating USDOT numbers over missed biennial updates while it works through Motus access problems, so an existing number is not likely to disappear underneath you while you clean this up.
[Related: FMCSA suspends USDOT deactivations as Motus issues mount for carriers]
The order of operations
Finally, you can use this timeline like a cheat sheet for any new authority filing:
- A month before you file: Business entity and Employer Identification Number (you’ll need it for use tax, if nothing else) done, insurance quoted and bindable, blanket process agent (BOC3) picked.
- Filing day: Login.gov account and identity verification finished, application submitted in Motus, $300 per authority type paid by card.
- Next business day: Send your agent the USDOT and docket (MC) number and tell them to file. Order the BOC-3.
- Publication date in the FMCSA Register: Watch for it. That is day zero, and 20 days later is your real deadline.
- Ten days after publication: Check your own record in Motus public search at motus.dot.gov/public/search. If either the insurance or BOC3 filing is missing, pick up the phone and dial 800-832-5660 direct to FMCSA’s help line. Do not send another email.
With all the Motus-related snags businesses have run into, I'd say clear your afternoon to get through.
Those two filings -- insurance, BOC3 -- are responsible for killing the largest number of applications, and they’re the two you do not control. Your insurer transmits one, your process agent transmits the other, and both are working on their own schedule.
Line them up before you submit and the clock stops being your problem.
*Disclosure: The author's company files carrier and broker authority applications for a fee, and he holds a New Jersey property and casualty producer license. The data described above is public and the query is reproducible.
