Which States Require a Form E Filing? Intrastate Trucking Insurance 2026
Form E is a state filing, not a federal one. The BMC-91X your insurer filed with FMCSA proves nothing to Texas, Pennsylvania, Illinois, Georgia or New York: each runs its own certificate of insurance, each demands that the insurance company file it directly, and the intrastate registration is not active until that certificate lands.
What is a Form E filing, and what is Form H?
These are uniform certificates drafted by the National Association of Regulatory Utility Commissioners and adopted state by state. Georgia names three of them in one rule, Rule 570-38-2-.05(6):
- Form E: Uniform Motor Carrier Bodily Injury and Property Damage Liability Certificate of Insurance.
- Form H: Uniform Motor Carrier Cargo Certificate of Insurance.
- Form K: Uniform Notice of Cancellation, the form that ends an authority. Your insurer files it, not you.
- G, J and L are the surety bond twins under 92 Ill. Adm. Code 1457.110; Form I is the cargo endorsement on the policy.
Two rules travel with them. Only the insurer files: Pennsylvania states flatly that certificates handed over by a motor carrier are not binding and not acceptable, and Georgia's own instructions say to have your insurance company, not your agent, file the evidence. And the insurer must be admitted in that state: New York accepts filings only from a company authorized to write that coverage in New York, and 92 Ill. Adm. Code 1425.20(f) requires an admitted insurer for Illinois licensed intrastate carriers regardless of domicile. Surplus lines paper that works federally can be unfilable next door.
"I have federal authority, I can haul anywhere": five sentences that end in a citation
Every one of these is said in good faith, usually by an owner whose interstate paperwork is genuinely spotless. The federal file and the state file are separate objects, kept by separate agencies, on separate forms, with separate consequences when one of them is empty.
| The sentence | What the state actually does | Source |
|---|---|---|
| "My MC number covers me in every state" | An MC number authorises interstate movement. Hauling point to point inside one state is intrastate authority, registered and insured separately | TxDMV, PA PUC, Illinois ICC and Georgia DPS each run their own programme |
| "My agent will email them the certificate" | Pennsylvania states that certificates of insurance provided by a motor carrier are not binding and are not acceptable. Only the insurance company can file | PA PUC |
| "Any A-rated carrier will do" | The insurer must be admitted in that state. Surplus lines paper that passes federally can be unfilable next door | NY filing rules; 92 Ill. Adm. Code 1425.20(f) |
| "FMCSA does not require cargo, so nobody does" | Federal general freight shows $0 for cargo. Illinois and Pennsylvania want a Form H anyway, and Georgia's certificate classes add one on top of Form E | FMCSA chart; PA PUC; Illinois ICC |
| "My truck is light, so none of this applies" | Weight does two different jobs. In Texas it decides whether you register at all. In Illinois and Pennsylvania it only sets the limit, and the certificate is required at any weight | TxDMV; Illinois ICC; PA PUC |
The federal endorsement does not close the gap either: the MCS-90 is proof of federal financial responsibility held at your place of business, and courts have divided over whether it even answers for a purely intrastate trip.
Which states require a Form E, and which do not?
| State and agency | Forms | Liability floor |
|---|---|---|
| Texas: TxDMV, number in TxMCCS | E; H and I for movers; K | $500,000 above 26,000 lbs |
| Pennsylvania: PUC certificate | E and H via Tyler Filings | $750,000 over 10,000 lbs, $300,000 at 10,000 or less |
| Illinois: ICC Public Carrier Certificate | E at any weight, plus H unless waived | $750,000 from 10,000 lbs GVWR, $300,000 below |
| Georgia: DPS, GIMC registration | E, for-hire carriers only | Form E data must concur with the application |
| Georgia: DPS certificate for household goods, passengers, limousines, non-consensual towing | E, H and K | $100K / $300K / $50K default; cargo $25K per vehicle, $50K aggregate |
| New York: NYSDOT property authority | E; H for household goods | Plus workers comp proof |
| California: DMV Motor Carrier Permit | No Form E: MC 65 M | $300,000 to $5,000,000 |
| Florida: no state insurance filing found | None located for general freight | $50,000 at 26,000 to 34,999 lbs, $100,000 to 43,999 lbs, $300,000 at 44,000 lbs and up |
| New Jersey: public movers licensed | No general freight certificate program found | Federal and policy terms |
Those rows come from the agencies themselves: PA PUC, Illinois ICC, Georgia DPS GIMC, NYSDOT. Read the Georgia split carefully: general freight goes through GIMC registration, which requires a Form E from for-hire carriers, while the DPS certificate program with Forms E, H and K covers only movers, passenger carriers, limousines and non-consensual towing. Florida sets weight minimums in F.S. 627.7415 and asks for no filing, but subsection (4) sends every commercial motor vehicle subject to 49 CFR Part 387 subparts A and B back to the federal limits. A 26,000 lb truck under federal jurisdiction is not finished at $50,000.
Does my federal BMC-91X count for intrastate work?
No, and the mismatch runs both ways. The FMCSA filing chart wants BMC-91, BMC-91X or BMC-82 for public liability and nothing for cargo: general freight shows $0 in the cargo column, and only household goods movers add BMC-34 or BMC-83. Illinois and Pennsylvania want a cargo certificate anyway, so a carrier with spotless interstate authority can have no cargo filing in existence and be inadmissible in two states at once. Georgia adds Form H on top of Form E, but only inside its certificate classes. Federal mechanics: the BMC-91 guide.
The clocks differ too. Federal coverage runs until terminated, and cancellation takes 35 days written notice from the date it is transmitted, per 49 CFR 387.7(b)(1). No state copies that number: Georgia asks its certificate holders for 30 days of notice where possible, Texas sends its own electronic warning 30 days out.
Texas: what does TxDMV actually require?
Texas is where out-of-state owners usually start: a second entity hauling inside Texas needs no MC number, only a TxDMV Number. The sequence is fixed: apply in TxMCCS, wait 24 to 48 business hours, then your insurer files, then you pay.
| Texas category | Minimum liability |
|---|---|
| Private or for-hire property over 26,000 lbs | $500,000 |
| Household goods movers under 26,000 lbs | $300,000 |
| Oil and hazmat listed in 49 CFR 172.101, outside the $5M classes | $1,000,000 |
| Placarded bulk hazmat, Division 1.1 to 1.3, controlled Class 7 | $5,000,000 |
| Buses for 16 to 26 people, commercial school buses | $500,000 |
| Household goods cargo | $5,000 per vehicle, $10,000 aggregate |
The seven-day and ninety-day options nobody mentions
TxDMV publishes four registration terms, not one, and the short ones exist for exactly the case a Russian-speaking owner hits first: one seasonal job inside Texas, no intention of basing there. Two cautions from the same page: 7-day and 90-day certificates cannot be renewed, and a short intrastate radius is also a pricing fact the underwriter will ask about, as in radius of operation and pricing.
| Term | Application | Per vehicle | Form E filing |
|---|---|---|---|
| 7 days | $5 | $10 | $100 |
| 90 days | $25 | $10 | $100 |
| Annual | $100 | $10 | $100 |
| Biennial | $100 | $20 | $100 |
Read the last column twice. The $100 insurance filing fee does not shrink with the term, so a seven-day registration costs $115 for one truck and $100 of it is the Form E. That is the arithmetic that decides whether a single Texas load is worth taking.
Budget the paperwork apart from the premium: $100 application, $10 per vehicle for a year or $20 for two, and $100 for the Form E filing itself. Then watch what the weight line does, because it does two different jobs. In Texas it decides whether the TxDMV number is required at all, above 26,000 lbs, and Georgia's GIMC registration opens at 10,001 lbs GVWR. In Illinois and Pennsylvania weight only sets the limit: the certificate is required of any for-hire intrastate property carrier whatever the truck weighs, and a light unit simply files at $300,000 instead of $750,000. So a truck too light for a TxDMV number still needs an Illinois Public Carrier Certificate, the usual trap for dump and aggregate operations.
Pennsylvania and Illinois: the two states that also want cargo
These are the states where a carrier with immaculate federal filings discovers a form that does not exist in its federal life. Both take Form E and Form H from the underwriter, and both publish their numbers.
| Item | Pennsylvania PUC | Illinois ICC |
|---|---|---|
| Property liability | $300,000 at GVWR or GCWR of 10,000 lbs or less; $750,000 over 10,000 lbs, per 52 Pa. Code 32.11 | $300,000 below 10,000 lbs GVWR; $750,000 from 10,000 lbs up |
| Cargo | $5,000 per vehicle under 52 Pa. Code 32.13(a) | $5,000 per vehicle, plus $10,000 aggregate for commodities other than unprocessed agricultural goods, bulk milk, dump-type loads and ordinary livestock |
| Escape from cargo | Exemption from PUC Cargo Insurance Regulations, filed by the carrier instead of a Form H | Cargo Insurance Waiver Affidavit, available only if you never carry cargo worth more than $5,000 |
| Passenger tiers | 15 or fewer: $35,000 split, being $15,000 per person, $30,000 per accident, $5,000 property, plus first party benefits. 16 to 28: $1,000,000. 29 or more: $5,000,000 | Separate ICC passenger programme |
| How it is filed | Electronically through Tyler Insurance Filings, by the insurance company | By the insurance underwriter, admitted in Illinois |
| The deadline that kills applications | 60 days from application for binding proof, or dismissal and a new fee | Coverage remains in effect until a cancellation form reaches the Commission |
One line on the PUC page saves a phone call: Pennsylvania does not participate in the Single State Registration System, so there is no reciprocity to lean on. The Commission runs an insurance hotline at 717-787-1227 and publishes a sample Form E, which is worth sending your agent before renewal rather than after.
What breaks the certificate in each state?
| State | The clock that ends the authority |
|---|---|
| Texas | Electronic notice 30 days before cancellation if your email is current; keeping the record Active is your job |
| Pennsylvania | 60 days from application for binding forms, or the application is dismissed and you refile with a new fee |
| Illinois | Coverage stays in effect until a cancellation form reaches the Commission, per 1425.20(c) |
| Georgia, certificate holders | Void immediately when coverage lapses under Rule 570-38-2-.05(2); suspended six months or more, DPS may revoke without further action under (11) |
| New York | The application is published in the NYSDOT Weekly Bulletin for protest, and the authority is not issued until Form E and the workers compensation proof are on file |
On the federal side the same event runs on three separate clocks, mapped in how cancellation and reinstatement work.
Georgia: the boundary between a registration and a certificate
Georgia deserves a second read, and a boundary. Rule 570-38-2-.05 governs certificate holders: movers, passenger carriers, limousines, non-consensual towing. For them a certificate voided by a lapse revalidates automatically once coverage returns, unless the Department has already entered an order. That is not forgiveness: every load hauled in the gap moved without a certificate, and those carriers must refile certificates at least every two years. A general freight carrier sits outside that subchapter entirely, in GIMC registration, where the insurer still files the Form E. Compare what a lapse does to MC authority.
Two typical scenarios
Illustrative composites, not specific clients. Radomir, a Russian-speaking owner in the New York metro, buys a small Georgia moving company and applies for a DPS household goods certificate; his agent binds through a surplus lines carrier that the federal system accepts without a murmur. Georgia rejects the form under Rule 570-38-2-.05(5): not provided by a company legally authorized to transact business in the state. A month later his partner Vikentiy switches insurers in Pennsylvania on renewal day, the new Form E lands a week late, Form H is forgotten entirely, and two brokers pull an empty PUC record. The certificate a broker reads and the filing a state reads are different objects, as the certificate of insurance guide explains.
The checklist before you register in a second state
- Name match. The exact legal name on the authority, punctuation included. Georgia and New York both say so in writing.
- Admitted paper. Ask before binding whether the insurer is admitted in that state and will file there.
- Cargo, separately. Federal authority needs no cargo filing for general freight. Illinois and Pennsylvania do, and so do Georgia's certificate classes.
- Weight thresholds. Know which job the number is doing, then read your declarations against it with the covered autos symbols guide.
- Workers compensation. New York issues no property authority without C-105.2, U-26.3 or a CE-200 exemption. Rules vary widely: see workers compensation state by state.
TruckSafe is not a licensed insurance agency. We are an independent platform connecting carriers with licensed insurance professionals, and the above is market and regulatory analysis, not legal advice or advice on your policy. Before you register an entity in a new state, get one sentence in writing from your agent: which forms will be filed, with which agency, in which name. If you are adding a state now, request a truck insurance quote and list the state filings on the form, so the insurer confirms it is admitted there before you bind. Questions in Russian and English: (315) 871-0833.
FAQ
What is a Form E filing in trucking insurance?+
Form E is the Uniform Motor Carrier Bodily Injury and Property Damage Liability Certificate of Insurance, a NARUC form a state requires from your insurer as proof of intrastate liability coverage.
What is the difference between Form E and Form H?+
Form E certifies bodily injury and property damage liability. Form H is the uniform cargo certificate, Form K cancels them, and Form I is the cargo endorsement attached to the policy itself.
Does my BMC-91X satisfy a state Form E requirement?+
No. BMC-91 and BMC-91X are federal filings with FMCSA for interstate authority. Texas, Pennsylvania, Illinois, Georgia and New York each need their own state certificate filed separately.
Can I file Form E myself?+
No. Only the insurance company can file. Pennsylvania states that certificates of insurance provided by a motor carrier are not binding and are not acceptable to the Commission.
How much does the Texas Form E filing cost?+
TxDMV charges $100 for the Form E insurance filing, plus a $100 application fee and $10 per vehicle annually or $20 biennially. Movers pay another $100 for Forms H and I.
What happens in Georgia if my intrastate insurance lapses?+
For DPS certificate holders (movers, passenger, limousine, towing) the certificate is void the moment coverage lapses under Rule 570-38-2-.05(2); DPS may revoke one suspended six months or more.
Does Illinois require cargo insurance for a Public Carrier Certificate?+
Yes, Form H filed by the underwriter, unless you file a cargo waiver affidavit stating you will not carry cargo worth more than $5,000 in any vehicle.
Why did a state reject a filing from my surplus lines carrier?+
New York accepts filings only from insurers authorized to write that coverage in New York, and Illinois requires an admitted insurer for intrastate carriers regardless of where they are domiciled.