California sets charter-party carrier liability minimums by vehicle seating capacity in General Order 115-G: $750,000 for a vehicle seating 7 passengers or fewer, $1,500,000 for 8 through 15 passengers inclusive, and $5,000,000 for 16 passengers or more. Vehicles operating under a Class C certificate are the exception at $750,000. The coverage must be on file with the Commission — buying a policy is not the same as satisfying the requirement.
This is the page where we were most determined not to paraphrase. Insurance minimums are the single most frequently misquoted numbers in California passenger transportation, and the misquotes are not random — they cluster around a specific wrong band that we will name, because we nearly repeated it ourselves.
What follows is the schedule as General Order 115-G states it. We went to the order rather than to any summary of it.
The schedule, by seating capacity
| Vehicle seating capacity | Required amount of coverage |
|---|---|
| 16 passengers or more | $5,000,000 |
| 8 passengers through 15 passengers, inclusive | $1,500,000 |
| 7 passengers or fewer | $750,000 |
| Any vehicle operated under a Class C certificate (Public Utilities Code § 5383) | $750,000 |
Three observations that the table alone does not make obvious.
The bands are wide and the steps are large. The jump from the middle band to the top is more than three times the coverage. For an operator, the decision to put a sixteen-seat vehicle into service is not a fleet decision with an insurance footnote; the insurance consequence is arguably the larger half of it.
The middle band starts at 8, not at 11. This is the misquote. A widely repeated version of this schedule gives the $1,500,000 band as covering 11 to 15 passengers, which would leave 8, 9 and 10-passenger vehicles in the $750,000 band. General Order 115-G does not say that. It says 8 through 15, inclusive.
The bands are about seating capacity, not about what you actually carry. The schedule speaks to the vehicle's seating capacity. An operator running a twelve-seat van with four passengers in it has not thereby moved into a lower band.
"On file" is the requirement, not "purchased"
Among the basic requirements the CPUC sets out for passenger carriers is maintaining insurance on file with the Commission. That preposition is the whole point of this section.
There are two failure modes here and they look identical from inside the business:
- The policy exists and was never filed. The operator is insured and non-compliant at the same time. Everything feels fine because the coverage is genuinely there.
- The policy was filed and has since lapsed, been cancelled or been replaced. The filing reflects something that is no longer true. Again, nothing in the daily operation surfaces this.
Neither shows up in dispatch, in a booking flow, or on an invoice. Both show up on the Commission's record, which is precisely why that record is worth checking — by the operator on itself, at least as often as by anybody else.
When we build operational software, the insurance date is one of the fields we push clients to treat as a first-class operational value rather than a filing-cabinet fact — because a renewal date sitting in an email thread is a renewal date nobody owns. A system that knows when coverage expires can surface it; a system that was never told cannot. We are not claiming software makes an operator compliant. We are saying that the specific failure of nobody noticing a date is a solvable one, and it is a common cause of an otherwise well-run operation going non-compliant without a single bad decision.
The Class C exception
General Order 115-G carves out vehicles operated under a Class C certificate — the authority the CPUC describes as covering transportation services incidental to commercial balloon operations, commercial river rafting or skiing — and sets those at $750,000, citing Public Utilities Code § 5383.
The exception makes sense once you see what Class C is for: transportation that exists in service of another activity rather than as the product being sold. It is also a reminder that the seating-capacity schedule is the general rule and not the only rule, which is a good reason to read the order rather than a table derived from it — including ours.
If you are unsure which authority an operation holds, the classes are set out in California TCP permit classes explained.
Why you will find different numbers for TNCs
Searching for California passenger-carrier insurance minimums surfaces a second, entirely different set of figures — $1,000,000 amounts, and a $50,000 / $100,000 / $30,000 structure. Those are real, and they are not the charter-party schedule.
General Order 115-G addresses transportation network companies separately, under Public Utilities Code § 5431(a), referring to the requirements in § 5433. That framework includes $1,000,000 for bodily injury and property damage liability under § 5433(b)(1), $1,000,000 of uninsured and underinsured motorist coverage under § 5433(b)(2), and a lower tier under § 5433(c) of $50,000 for bodily injury per person, $100,000 per incident, $30,000 for property damage, with $200,000 in excess coverage.
The reason to spell this out is not that most readers need the TNC numbers. It is that these two schedules get blended together in secondary sources, and a blended version is worse than either. If you encounter a figure for California passenger transportation insurance, the first question is which regime it belongs to. A $1,000,000 figure quoted at a charter-party operator is a category error, and a charter-party operator who adopts it as their target is aiming below the schedule that applies to them across most of the range.
Workers' compensation
Liability coverage is not the only insurance obligation in the picture. California's workers' compensation regime attaches to employment generally, and a carrier with employees is inside it — which for a chauffeur operation is a significant exposure, because the work involves employees operating vehicles for long hours.
We are deliberately not stating a rule about which engagement models attract which obligations. Worker classification in transportation is contested, consequential and genuinely not something to take from an article. What we will say plainly is that the model an operation chooses for its chauffeurs changes its insurance position, that "contractor" is a conclusion rather than a setting you select, and that this is a question for an employment lawyer and an insurance broker who both know this industry.
The operationally useful version: whatever the model, a carrier should be able to answer what coverage exists for a chauffeur injured on the job, and should be able to answer it without a meeting.
What a lapse actually does
Insurance on file is a condition of operating authority, not a parallel obligation sitting beside it. That is the part worth understanding, because it changes what a lapse means.
A lapse is not a fine with the business continuing underneath. It goes to whether the carrier is entitled to be carrying passengers at all — which in turn reaches everything downstream: the trips already on the books, the corporate account with a procurement team that asked for evidence of coverage, the airport work where authority is checked, and the affiliate relationships where another carrier's compliance is riding on yours.
We are not going to enumerate specific enforcement consequences, because those depend on the circumstances and on the Commission's Transportation Enforcement Branch rather than on anything we can responsibly generalise. The point stands without the enumeration: this is a condition that has to remain continuously true, and the cost of it quietly ceasing to be true is not proportionate to the effort of checking.
If you are the one asking for the certificate
For a passenger, a procurement team, or an event planner placing a group, the useful version of this page is short.
- Ask for the certificate of insurance. A licensed operator produces one without friction. Reluctance is itself information.
- Check the amount against the vehicle you are actually booking. A $750,000 certificate is the published minimum for a vehicle seating 7 or fewer. If the vehicle arriving seats twelve, that certificate is not matched to the vehicle.
- Confirm the named insured matches who is taking your money. A certificate in the name of an unrelated entity is a different document than it first appears to be.
- Check the CPUC record alongside it. Status and authority on the Commission's record, plus the certificate, is a genuinely strong check — and the record part is free and takes a minute.
That fourth step is the one almost nobody runs, and it is the one the operator cannot influence. We walk through reading the record properly in how to verify a chauffeur company, including the specific things the record does not tell you.
Sources
Questions we actually get asked
Is the requirement per vehicle or per company?
The schedule in General Order 115-G is expressed by vehicle seating capacity — it sets the amount of coverage required for a vehicle of a given size. A carrier operating a mixed fleet is therefore looking at the requirement that attaches to its largest relevant vehicles, not an average.
This is why adding a single larger vehicle to an otherwise small fleet is a bigger decision than it looks. The vehicle does not just need a seat map and a driver; it can move the coverage the operation has to carry into a different band entirely.
Does a certificate of insurance prove compliance?
It proves coverage exists. It does not by itself prove the coverage is on file with the Commission, and filing is part of the requirement rather than an administrative afterthought.
For a passenger checking an operator, the certificate plus an active status on the CPUC record is a reasonable check — the two together are much stronger than either alone. For an operator, the thing to confirm is that what the broker filed is what the Commission actually holds.
Why do I see $1,500,000 quoted for 11 to 15 passengers?
Because that figure is in wide circulation and the band is wrong. General Order 115-G sets $1,500,000 for a vehicle with a seating capacity of 8 passengers through 15 passengers, inclusive — the band starts at 8, not at 11.
We checked because we had seen the 11-to-15 version too. It matters: an operator running a nine or ten-passenger vehicle on the assumption that it falls in the $750,000 band is under-insured against the published schedule, and the first time anyone discovers that will be the worst possible time.
Do these figures change?
They are set by a General Order, which is an instrument the Commission can revise — the "G" in 115-G is a revision marker. A page that presents these amounts as permanent is making a promise it cannot keep.
So: treat the table below as what the current General Order says, verify against the order itself before relying on it for anything consequential, and be suspicious of any source that quotes these numbers without naming the instrument they come from.