Texas bus insurance, from the TxDMV registration up

In Texas, a passenger vehicle designed or used for more than 15 passengers including the driver is a commercial motor vehicle, and Transportation Code Chapter 643 requires its operator to register with the Texas Department of Motor Vehicles and keep proof of liability insurance on file before it runs. The statute hands the amount to TxDMV, the agency's rule puts it in a table by seat count, and the operator's insurer files it electronically. This page reads each of those layers and says which document the number comes from.

Tow truck insurance

The registration trigger, and who is exempt from it

Chapter 643 does not carry its own seat count. Section 643.051(a) says a motor carrier "may not operate a commercial motor vehicle, as defined by Section 548.001, on a road or highway of this state unless the motor carrier registers with the department", and Section 548.001 supplies the definition: a vehicle with a gross weight, registered weight, or gross weight rating of more than 26,000 pounds, or one that "is designed or used to transport more than 15 passengers, including the driver", or one carrying placardable hazardous materials, with a school activity bus included by name (Texas Transportation Code Chapter 643; Section 548.001). TxDMV's registration page lists the same triggers in its own words, including "Operate a commercial school bus" as a trigger of its own (TxDMV, TxDMV Number). A "motor carrier" for this purpose is any entity that "controls, operates, or directs the operation of one or more vehicles that transport persons or cargo over a road or highway in this state" (Section 643.001), which is broader than a company that sells tickets.

The exemptions in Section 643.002 decide the church and shuttle questions. The chapter does not apply to "a motor vehicle used to transport passengers operated by an entity whose primary function is not the transportation of passengers, such as a vehicle operated by a hotel, day-care center, public or private school, nursing home, or similar organization", nor to a vehicle operated by a governmental entity, nor to a tow truck, nor to an operation exempt under the federal Unified Carrier Registration Act "when operating exclusively in interstate or international commerce". TxDMV's guidance for bus operators restates the first of those with hotel, day-care, and nursing home shuttles as its examples. A congregation's van is not named in the list; it reads like a "similar organization" case, and the way to settle it is to ask TxDMV rather than to assume.

What the statute says about insurance

Section 643.101(a): "A motor carrier required to register under Subchapter B shall maintain liability insurance in an amount set by the department for each vehicle requiring registration the carrier operates." Subsection (b) lets TxDMV set amounts that do not exceed the federal requirement under 49 U.S.C. Section 13906(a)(1), taking into account the class and size of the vehicle and the persons or cargo carried, and subsection (e) requires the insurer to be authorized in Texas or to be an eligible surplus lines insurer. Section 643.103 then requires the carrier to file "evidence of insurance in the amounts required by Section 643.101 or 643.1015, or evidence of financial responsibility" at initial registration, on re-registration after a lapse, on a change of insurer, and on a change of ownership; to keep "evidence of insurance in a form approved by the department in the cab of each vehicle requiring registration"; and it lets the department charge "a fee of $100 for a filing". The application itself, under Section 643.052, lists each vehicle by VIN, make, and unit number, certifies compliance with the drug testing rules in 49 CFR Part 382, and requires a USDOT number, which is why TxDMV tells applicants to obtain the federal number first. Section 643.053 attaches "an application fee of $100 plus a $10 fee for each vehicle requiring registration".

The pattern is the opposite of the tow truck statute, where the legislature wrote the amounts into the Occupations Code. Here the legislature wrote the ceiling and the mechanics, and delegated the number.

The TxDMV rule, 43 TAC 218.16, and the table it points at

The delegated number lives in 43 Texas Administrative Code Section 218.16, amended most recently effective January 2, 2025. Subsection (a) requires proof of "automobile liability insurance" on file "for each vehicle required to be registered", as "combined single limit liability for bodily injury to or death of an individual per occurrence, and loss or damage to property (excluding cargo) per occurrence", and says "Minimum insurance levels are indicated in the following table." The table is an attached graphic, and the public mirrors of the rule do not render it. The rule also adopts 49 CFR Part 387 by reference for a registered carrier operating a foreign commercial motor vehicle. Subsection (f) bars cancellation "until 30 days after notice has been given to the department by the insurer", and subsection (e) puts the filing duty on the insurer, with a $100 nonrefundable filing fee at original application.

TxDMV publishes the same table in its own materials. The Motor Carrier Handbook (May 2025) prints three passenger rows. "Commercial School Bus Operators: For-hire school buses operating within the boundaries of a municipality and transporting preprimary, primary or secondary school students on a route between the students' residence and a public, private or parochial school or day-care facility", $500,000. "Bus Operators: Vehicles designed or used to transport > 15 passengers (including driver) but < 26 passengers (not including driver)", $500,000. "Vehicles designed or used to transport 26+ passengers (not including driver)", $5,000,000. A fourth row places any carrier over 26,000 pounds at $500,000 (TxDMV, Motor Carrier Handbook, p. 10). TxDMV's 2019 bus operator flyer prints the same three passenger rows with the same amounts (TxDMV, Smart Bus Operators). We quote the counting convention exactly as the agency prints it, "including driver" on the lower bound and "not including driver" on the upper, rather than restating it as one seat count, because the two rows are written differently and the handbook is the agency's gloss on a graphic we could not see. The handbook adds that the policy "must include a provision requiring the insurance provider to submit electronic notice to TxDMV at least 30 days prior to the policy's cancellation or expiration", and that a lapse "may result in administrative penalties, sanctions, or the revocation of your operating authority."

Set that beside the federal schedule and the shape is clear. Interstate, the FMCSA's rows are $1,500,000 at 15 or fewer including the driver and $5,000,000 at 16 or more (49 CFR 387.33, as of 2026). Intrastate in Texas, the top row starts at 26 and the middle row sits at $500,000. A 20-seat shuttle that never leaves Texas and one that runs to Shreveport are two different regulatory cases with the same vehicle, which is the first thing an agent writing Texas buses will ask about.

The clause bus operators do not expect: 218.16(c)

Subsection (c) is an employee-benefit condition inside an auto insurance rule. A registered carrier "whose primary business is transportation for compensation or hire between two or more municipalities shall provide workers' compensation for all its employees or accidental insurance coverage" of at least $300,000 for medical expenses for at least 104 weeks, $100,000 for accidental death and dismemberment, 70 percent of pre-injury income for not less than 104 weeks, and a $500 maximum weekly benefit. Texas makes workers compensation elective for most private employers; for an intercity bus or charter company, this rule takes the election away or names the substitute. A carrier whose work stays inside one city is outside the subsection. Ask the agent which side of that line your route map puts you on.

Two more Texas layers sit next to the TxDMV one. Limousines seating 15 or fewer never reach Chapter 643 and are regulated, where they are regulated at all, by a city under Local Government Code Section 215.004; our limo insurance page reads Houston's ordinance as the example, and that same ordinance requires a permitted charter or sightseeing vehicle to carry auto liability "meeting all requirements of Chapter 643 of the Texas Transportation Code", a city pointing back at the state for the number. School bus contractors answer to the district's contract and to DPS safety standards under Education Code Chapter 34 on top of the TxDMV row above; the national bus insurance page covers that segment and the federal schedule. For the other Texas agencies that permit specialty transport, start at the Texas hub, or compare the class where the statute names the amount itself on the Texas tow truck insurance page.

Frequently Asked Questions

When does a Texas bus operator have to register with TxDMV?
When the vehicle is a commercial motor vehicle under Transportation Code Section 548.001, which for a passenger vehicle means one “designed or used to transport more than 15 passengers, including the driver,” and Section 643.051 then requires registration before it operates on a Texas road. Operating a commercial school bus is a separate trigger on TxDMV’s own list. A vehicle run by an entity whose primary function is not passenger transport, such as a hotel, school, day-care center, or nursing home shuttle, is exempt under Section 643.002, and so is a vehicle operated by a governmental entity.
What liability minimum does TxDMV require for a bus?
The statute leaves the amount to TxDMV, capped at the federal level, and the rule puts the amounts in a table it publishes as an attached graphic. TxDMV’s Motor Carrier Handbook prints that table: $500,000 for vehicles “designed or used to transport > 15 passengers (including driver) but < 26 passengers (not including driver),” $5,000,000 for vehicles designed or used to transport 26 or more passengers not including the driver, and $500,000 for a for-hire commercial school bus on a residence-to-school route inside a municipality, all as combined single limits and as of the May 2025 handbook. Confirm the current figure with TxDMV before relying on it.
Does the Texas rule require workers compensation for a bus company?
For one kind of carrier, yes, or an alternative. 43 TAC 218.16(c) requires a registered motor carrier “whose primary business is transportation for compensation or hire between two or more municipalities” to provide workers compensation for all its employees or accidental insurance coverage of at least $300,000 for medical expenses for 104 weeks, $100,000 for accidental death and dismemberment, 70 percent of pre-injury income for not less than 104 weeks, and a $500 maximum weekly benefit. A carrier that works inside a single city is outside that subsection and back in the state’s general elective workers compensation system.