Cargo insurance is not federally required. Here's the actual rule.

Search “is cargo insurance required” and you will be told, confidently and repeatedly, that FMCSA requires it and that the number is $100,000. Both halves of that are wrong, and the second half is wrong in a way that costs money.

Here is what the regulation actually says, and why the distinction is worth ten minutes of your attention rather than being a pedantic footnote.

What the federal rules actually cover

The cargo insurance requirements live in 49 CFR 387, and the operative sections today are the “T” versions — the un-suffixed ones carry an eCFR note reading “again suspended indefinitely” following the 2017 URS suspension.

Three pieces of the text converge on the same conclusion:

§387.301T(b) is headed “Household goods motor carriers-cargo insurance”, and its prohibition reaches only “household goods motor carrier[s]”. There is no parallel paragraph for general freight.

§387.303T(c) is headed “Household goods motor carriers: Cargo liability”. It sets the figures at $5,000 for loss or damage on any one vehicle, and $10,000 for losses occurring at any one time and place.

§365.109T(a)(5)(iii) lists the cargo filing forms — BMC-34 and BMC-83 — as applying to “(household goods motor carriers and household goods freight forwarders)”.

So: if you move household goods, there is a federal cargo requirement, a federal figure and a federal filing. If you move general freight, there is none of the three.

And there is no $100,000 anywhere in Part 387.

So where does $100,000 come from?

Your customers. Broker carrier packets require a certificate showing cargo coverage before they will tender you a load, and $100,000 is the conventional number for dry van freight. It is a contract term, not a regulation.

That sounds like a distinction without a difference, because either way you are buying the insurance. It isn’t, for two reasons.

Why it matters, practically

First: contract terms are negotiable and regulations are not. If you believe a federal regulator set your limit at $100,000, that number is simply a fact of life. Once you understand it was set by the person giving you freight, the question changes to what do the brokers I actually work with require, and what am I actually hauling. High-value electronics or pharmaceuticals need $250,000 or more and the broker will tell you so. Building materials may not need six figures at all.

Second — and this is the expensive one: a box you tick gets bought cheaply. Treating cargo insurance as a compliance formality is how carriers end up with a certificate that satisfies a packet and a policy that does not cover the loss. Unattended vehicle theft is frequently excluded or heavily limited, which is precisely the scenario most cargo theft occurs in. Refrigeration breakdown is usually a separate endorsement rather than part of the base form. Your policy lists excluded commodities, and taking one means you are uninsured for that load and will find out at claim time.

Nobody reads the exclusions on a box they are ticking. People do read them on a commercial decision.

The part you must not misread

No insurance mandate does not mean no liability.

Your responsibility for loss or damage to freight comes from the Carmack Amendment, 49 U.S.C. 14706, and it applies whether or not you bought a policy. Federal law not requiring you to insure the risk does not mean federal law has removed the risk. It means that without cover, you carry it personally.

That is the honest version of this: the requirement is softer than you were told, and the exposure is exactly as hard.

What to do with this

1. Ask your brokers what limit they actually require, in writing, rather than assuming $100,000.
2. Match the limit to the most valuable load you will ever be under, not to the cheapest certificate that gets you onboarded.
3. Read the exclusions — specifically unattended theft, refrigeration breakdown, and the excluded commodity list.
4. If you haul household goods, note that you are in the one category where a genuine federal filing applies.

Every figure above links to the primary text on the cargo insurance page, so you can check it rather than take our word for it. That is the standard this whole site is built to — and it is the reason this post exists, because the claim it corrects is repeated on almost every trucking website you will find.