If you run an executive sedan or SUV on prearranged trips — Uber Black, corporate accounts, hotel work, airport runs — your personal auto policy will not cover you, and the state minimum will not let you work. Here is what will.
Last reviewed: September 2026.
Who this is for
You drive a black Suburban, Escalade, or S-Class. Your work is prearranged — booked ahead, not flagged down. Maybe you came in through Uber Black, maybe through a hotel or a corporate account, maybe you farm in work from a larger operator.
You are not a rideshare driver. That distinction is not marketing — in Ohio it is written into the statute, and it changes which rulebook applies to you and how much insurance you are required to carry.
This guide covers Ohio and Kentucky, because in the Cincinnati market you probably need both.
Does Ohio law consider a black car a limousine?
Most operators assume “limousine” means a stretch. Ohio does not. Under ORC 4501.01, a chauffeured limousine is:
a motor vehicle that is designed to carry nine or fewer passengers and is operated for hire pursuant to a prearranged contract for the transportation of passengers on public roads and highways along a route under the control of the person hiring the vehicle and not over a defined and regular route.
Nine or fewer seats, for hire, prearranged, route controlled by the customer. That is a black car sedan. That is an Escalade. Ohio defines the class by how you work, not what the vehicle looks like. Everything downstream follows from that classification.
Is a black car service the same as rideshare in Ohio?
Ohio transportation network company law — ORC Chapter 4925, with definitions in ORC 3942.01 — is built around the “personal vehicle.” A TNC driver is defined as someone who uses a personal vehicle to provide TNC services. And a personal vehicle, by the statute own terms, cannot be a chauffeured limousine.
- A TNC driver uses a personal vehicle
- A personal vehicle is not a chauffeured limousine
- A chauffeured limousine is any prearranged for-hire vehicle seating nine or fewer
- Therefore prearranged black car work sits outside Ohio TNC framework and inside its for-hire motor carrier framework
This matters financially. Ohio TNC statute (ORC 3942.02) sets a driver on-trip floor at $1 million — and Uber own policy satisfies it. Ohio for-hire carrier framework sets your floor at $1.5 million, and nothing but your own policy satisfies that. That is the whole reason a rideshare driver can work on a personal policy and you cannot.
What insurance does Ohio require for a black car service?
A PUCO certificate
ORC 4921.03 is direct: “No for-hire motor carrier may operate in intrastate commerce unless the carrier has a current and valid certificate of public convenience and necessity.”
ORC 4921.01 lists the exemptions. Taxicabs in usual taxicab service are exempt. Cost-sharing ridesharing is exempt. There is no limousine, livery, or black car exemption. And the requirement is not tied to vehicle size.
$1.5 million, filed on Form E
Ohio minimum for an intrastate for-hire passenger carrier with 15 seats or fewer is $1,500,000, and it requires a properly completed Form E submitted by your insurance company. That last part matters. It is not enough to buy the policy — your carrier has to make the filing, and not every carrier will. This is one of the practical reasons the market for this class is narrow.
Under ORC 4921.09, if the coverage lapses, “all operations under the certificate of public convenience and necessity shall cease immediately.”
Livery registration
Ohio provides a livery registration class for chauffeured limousines under ORC 4503.24, conditioned on ORC 4509.80 financial responsibility of $100,000 per person, $300,000 per accident, $50,000 property damage.
Do not mistake this for your operating requirement. That figure is what gets you plates. It is a fraction of what PUCO requires to carry passengers, and a fraction of what any corporate account will accept. An operator who buys to this number has a policy that registers a car and does nothing else.
What insurance does Kentucky require for a black car service?
If you work CVG at all — and in this market almost everyone does — Kentucky is not optional. The airport is in Boone County, Kentucky.
KRS 281.630: “A person shall not act as a motor carrier without first obtaining a certificate from the department.” Under KRS 281.010, a limousine is a vehicle operating under a limousine certificate “designed or constructed with not more than fifteen (15) regular seats.” Kentucky defines the class by the certificate you hold; Ohio defines it by seats and prearrangement.
You apply to the Kentucky Transportation Cabinet, Department of Vehicle Regulation, on Form TC 95-633. Insurance is filed by your carrier on Form E or ACORD. Allow roughly two weeks.
The Kentucky minimums — and why they are a trap
| Seats | Per person | Per incident | Property damage |
|---|---|---|---|
| 7 or fewer | $100,000 | $300,000 | $50,000 |
| 8 or more | $100,000 | $600,000 | $50,000 |
A $300,000 statutory minimum in a business where a single serious injury claim routinely exceeds seven figures. Kentucky floor will satisfy the Cabinet and nothing else — not a corporate account, not Uber Black.
Do you need federal operating authority for a black car service?
Here is where the Cincinnati market is genuinely different from Columbus or Dayton. CVG is in Kentucky. If you pick up in Cincinnati and drop at the airport, you crossed a state line. That is interstate commerce, and it puts you under federal jurisdiction on a large share of your trips.
Safety regulations: probably not
Under 49 CFR 390.5, a commercial motor vehicle includes one “designed or used to transport more than 8 passengers (including the driver) for compensation,” or one with a GVWR of 10,001 pounds or more. Appendix A to Part 390 confirms FMCSA safety jurisdiction excludes passenger vehicles designed and used for 8 or fewer passengers, at 10,000 pounds or less, not carrying hazmat. A typical sedan or SUV clears that.
Operating authority and $1.5 million: yes
49 CFR 387.33 sets financial responsibility for interstate for-hire passenger carriers at $1,500,000 for 15 or fewer passengers including the driver, and $5,000,000 for 16 or more.
The exceptions in section 387.27 are narrow — school transportation, commuter round trips under 16 people, and taxicab service “having a seating capacity of less than 7 passengers and not operated on a regular route or between specified points.” Prearranged black car service is not taxicab service. There is no limousine exception and no small-vehicle exception.
On registration, FMCSA published position, stated in a 2022 Federal Register notice, is that the commercial regulations apply to for-hire interstate transportation of passengers “in any vehicle, no matter the GVW, GVWR, or passenger capacity,” and that for-hire carriers must obtain operating authority registration under 49 U.S.C. 13902 before engaging in interstate transportation.
So the same vehicle that falls outside federal safety regulation falls inside federal registration and financial responsibility. Two different tests — and conflating them is where most of the confusion in this market comes from.
We are describing FMCSA published position, not predicting enforcement. If you are structuring an operation around this, talk to us and to FMCSA directly.
What insurance does Uber Black require from its drivers?
Uber Black is a different product from UberX in the way that matters most here. From Uber own published requirements:
- Drivers “must be professional drivers with commercial auto insurance (personal auto insurance does not qualify)“
- You must have all permits your city requires to operate a commercial livery vehicle
- Black exterior, black leather or vegan leather interior
- Only specific makes and models qualify
- A 4.85 or higher rating across your most recent 500 rated trips
On vehicle age, be careful: Uber national Uber Black page says no older than 5 years, while Uber Cincinnati and Columbus driver pages both say 6 years or newer. Check your city page rather than the national one, and confirm before you buy a vehicle.
Uber insurance is not your insurance
While you are online and available, Uber policy provides $50,000 per person and $100,000 per accident for injuries, and $25,000 property damage. On an accepted trip, at least $1,000,000 for third-party injury and property damage. Three things it does not do:
- It does not satisfy Ohio $1.5M Form E filing or the federal $1.5M
- It does not cover you on any trip that is not an Uber trip — corporate accounts, hotel work, direct bookings and farm-in work are all outside it
- It does not substitute for the commercial policy Uber itself requires you to carry
For most black car operators, non-Uber work is the majority of revenue. That work is uninsured under Uber policy entirely.
What limits will corporate and hotel contracts require?
The statutory minimums are the floor. Your customers set the real number, and it is consistently higher. Across published institutional vendor insurance requirements the pattern is consistent:
- $1,000,000 combined single limit commercial auto — the baseline for corporate and institutional accounts, frequently specified as including owned, hired and non-owned vehicles
- $5,000,000 where charter buses are involved
- Additional insured status and certificate holder endorsements, essentially universally
Add the airports, and there is a requirement most operators do not see coming: CVG and Columbus both require a separate $1,000,000 commercial general liability policy, with the airport authority named as additional insured. Commercial auto does not provide that. It is a second policy.
Why is general liability so hard for a black car operator to get?
This is the most practical thing on this page. You need commercial general liability — CVG requires $1,000,000 per occurrence to issue a permit, and Columbus requires the same. It is separate from your commercial auto policy and there is no way around it if you want airport work.
Now look at what the CVG application asks:
“Will you operate at CVG under any Ride Share Companies?” Yes / No
If Uber Black is part of your business, that is a yes. And a number of general liability markets will decline your application the moment you disclose it. Their own applications ask whether the applicant drives for Uber or Lyft, and a yes ends the submission. Explaining that black car work is not UberX will not change the underwriting answer once the box is checked.
So the operator ends up in a bind: the airport demands a policy the accessible markets will not sell him.
The one thing you must not do
Do not answer an insurance application incorrectly to get around this. Your application becomes part of your policy. A material misrepresentation on it can give the carrier grounds to rescind the policy or deny a claim. The result would be a certificate on file at the airport, a permit issued on the strength of it, premium paid — and no coverage at the moment it matters. That is materially worse than not having the permit, and it surfaces at the worst possible time.
What actually works
The answer is usually a different kind of market — specialty and surplus lines carriers that underwrite for-hire transportation deliberately, rather than standard small-business carriers that screen the exposure out at the application. Those are not markets you reach through a quoting portal. They are reached through an agency with the right wholesale relationships.
This is the part of the job that is genuinely hard, and it is why we wrote this. Lighthouse places significant general liability volume, we know which markets screen rideshare exposure out at application and which will look at it properly, and a declination on your record makes the next submission harder. Have the conversation before you fill anything out.
What does a Cincinnati black car operator actually carry?
| Coverage | Why |
|---|---|
| Commercial auto, $1.5M CSL | Ohio Form E, federal 387.33, and it clears the $1M contracts want |
| Commercial general liability, $1M | CVG and CMH permits; premises and operations exposure |
| Uninsured / underinsured motorist | Uber does not maintain UM/UIM in every state |
| Physical damage — comp and collision | Your vehicle is your business. Uber contingent coverage carries a $2,500 deductible and only applies if you carry your own |
| Hired and non-owned auto | If you ever farm work out or use a substitute vehicle |
| Workers compensation (Ohio BWC) | If you have any employee drivers |
Coverage needs are specific to your operation. This is a general guide, not advice about your situation.
Does three years in business change what you can buy?
This is the single most useful thing to know about pricing in this class, and almost nobody tells operators about it.
When you start out, your options are narrow. Years in business and years of driving experience are real rating factors in commercial auto, and a brand-new venture with no loss history is a harder risk to price. Fewer carriers will look at you, and the ones that will charge accordingly. That is not unfair — it is what an underwriter does with an unknown.
Around the three-year mark, that changes. You have a track record. You have loss runs. Markets that would not quote a startup will quote you, and markets that already would tend to price you differently. The carrier that made sense in year one is frequently not the carrier that makes sense in year three.
Here is the problem: most operators never find out. The renewal shows up, the number is close enough to last year, and it gets paid. Nobody re-shops, because re-shopping means finding an agency with more than one market — and the agency that placed you as a startup may only have the one that said yes.
If you have been running three years or more
And you are still on the program you started with, it is worth an hour of somebody actually testing the market for you. Not a quote portal — a submission to more than one carrier that underwrites for-hire livery on purpose, with your loss runs and your real operating profile in front of them.
Sometimes the answer is that you are priced correctly and you should stay put. That is a fine answer, and you will know it rather than assume it. Often enough it is not, and the difference on a commercial auto policy in this class is not small.
Where each of our markets fits
This is worth saying plainly, because it is the practical reason having more than one market matters.
Progressive is often the right answer for a newer operation. Broad appetite, well established in for-hire livery, and willing to look at a venture that does not have years of documented history behind it yet. If you are getting started, that is a real advantage — plenty of carriers will not engage at all.
Forge is where an established driving record starts to pay off. In our experience their program responds best to two things: roughly three years or more of documented driving history, and a strong rating history behind it. Forge has been a commercial auto specialist since 1938 and is built around light vehicles and local operations, which is the black car profile almost exactly.
Note what that is actually measuring: time on the platform, not the age of your LLC. You could have formed the company last month and still have five years of documented driving behind you, and that history is the part that counts. It also means the 4.85 rating Uber Black already requires of you is not just a condition of keeping the work — it is an asset when your risk goes in front of an underwriter. Most operators have never thought of it that way, because nobody ever told them their rating was worth anything outside the app.
That distinction is not a knock on either carrier. It is how underwriting appetite works: different companies are built for different stages of a business, and the one that was right for you at the start is not automatically the one that is right for you now.
What it means for you practically: if you have three or more years on the platform and a clean rating record, and nobody has looked at your program since you started, there is a market in play for you now that may not have been in play then. That is worth a submission, not a guess.
And if you are just starting out
We write new ventures too. Expect a narrower field and a higher number in year one — that is the market, not the agency — but getting placed properly from the start matters more than most new operators realize. Your filings have to be right, your limits have to match what your contracts and airport permits demand, and the loss history you build over the next three years is what determines whether year four is cheap or expensive.
The operators who end up with the best pricing at year three are usually the ones who were set up correctly at year one. Come back and see us at three years. We will tell you honestly whether the market has moved for you.
Why do most insurance companies decline black car operators?
For-hire livery is a class most insurance companies decline outright. Passenger exposure, high annual mileage, night and weather driving, and severity well above ordinary commercial auto. Which means the answer you get depends almost entirely on whose desk your submission lands on.
Lighthouse writes this class through Progressive and Forge. Progressive is the name most operators already know in for-hire livery. Forge is a commercial auto specialist writing this business since 1938, positioned around light vehicles and local operations — precisely the black car profile.
Very few agencies in this market have both. Having two real markets for the same risk is the difference between a quote and a decline, and between a competitive rate and whatever the single available carrier decides to charge.
Growing past a couple of vehicles? We also write larger fleets through Philadelphia Insurance — fleet rating, driver screening programs, and the higher limits larger corporate contracts demand.
All three write in Kentucky as well as Ohio, which matters in this market more than it does anywhere else in the state.
We handle the filings
The filings are where operators get stuck. Your Ohio CPCN needs a Form E from your carrier. Federal authority needs a BMC-91 or 91X. CVG wants the Kenton County Airport Board named as additional insured on both policies. Columbus wants its own certificate on its own schedule. None of that is something you should be figuring out from a web portal at 11pm.
Tell us where you pick up, where you drop off, and what you are driving. We will tell you which requirements apply to you and what it costs to satisfy them.
Request a Quote or call (513) 860-2552.
About this guide
Last reviewed: September 2026.
Operating and insurance requirements for for-hire passenger transportation change, and they vary considerably based on the jurisdiction you operate in, your vehicle seating capacity, the type of operating authority you hold, and the kind of service you provide. Airport permit terms, state financial responsibility minimums, federal registration requirements and platform requirements such as Uber Black’s are all revised from time to time.
This page is general information, not legal advice or a coverage determination. Confirm current requirements with the regulator that applies to you — the Public Utilities Commission of Ohio, the Kentucky Transportation Cabinet, the Federal Motor Carrier Safety Administration, or the airport authority involved — and confirm any coverage question against your own policy forms and endorsements.
If you would like help working out which of these requirements actually apply to your operation, that is what we are here for. Request a quote, contact us, or call (513) 860-2552.