Oklahoma Commercial Insurance Requirements: A Comprehensive Guide for Businesses

Oil and Gas Drilling Insurance Requirements

Oklahoma Corporation Commission (OCC) Regulations

The Oklahoma Corporation Commission, through its Oil and Gas Conservation Division, has exclusive jurisdiction to regulate oil and gas drilling within the State of Oklahoma. Key insurance and financial requirements include:

Financial Security Options: The Division allows for several options to meet financial security requirements:

• Surety Bond: Must be issued by a company licensed to do business in Oklahoma, typically in amounts for estimated plugging and abandoning of each well (minimum $25,000 for wells with plugging costs less than $25,000)
• Letter of Credit: Requires an FDIC insured Oklahoma bank or savings and loan association
• Financial Minimum Net Worth: Proof of minimum $50,000 net worth

Specialized Requirements:

• Operators must complete the Affidavit of Well Plugging Cost for Oil and Gas Well Operators (Form 1006D) signed by a licensed pipe and pulling and well plugging company
• Financial security must remain in place from commencement of oil and gas operations through abandoning of the well
• Six-month notice required for bond cancellation, with replacement bond or alternative security required

Oil and Gas Transportation Requirements

Commercial Transportation Insurance

Oklahoma’s transportation sector is vital to the state’s economy, with over 82,000 employees in trucking-related jobs. Key transportation insurance requirements include:

State Insurance Requirements:

• Minimum Liability Coverage: $100,000 injury per person, $300,000 injury total, and $50,000 property damage for commercial vehicles
• Workers’ Compensation: Required for all employers with five or more employees (with limited exemptions)
• Hazmat Transportation: $5 million liability insurance requirement for hazardous materials transport
• Oil Transportation: $1 million liability insurance requirement for oil transport

Federal Requirements (Interstate Commerce):

• Primary liability coverage of $750,000 minimum (many insurers require at least $1,000,000)
• Motor Carrier (MC) number from the FMCSA for interstate operations
• Commercial Driver’s License (CDL) for vehicles over 26,000 pounds

Additional Coverage Considerations:

• Motor truck cargo insurance for companies transporting cargo for others
• Non-trucking liability insurance for personal use of commercial vehicles
• Physical damage insurance for vehicle protection
• Occupational accident coverage as alternative to workers’ compensation for certain operations

Underground and Aboveground Storage Tank Insurance Requirements

Petroleum Storage Tank Division (PSTD) Regulations

Key Regulatory Updates:

• Effective October 1, 2024, any individual who tests a UST and/or AST system must be an OCC Licensed Tester
• Oklahoma has EPA-approved state program authority, corresponding to the EPA final rule published on July 15, 2015

Financial Responsibility Requirements:

• UST Financial Responsibility: Owners and operators must demonstrate financial responsibility to cover costs associated with potential releases
• Insurance Options: State UST funds or Environmental Liability Insurance
• Coverage Areas: Cleanup costs, third-party liability damages, and regulatory compliance
• Testing and Compliance: Licensed testing requirements and scheduled removal procedures with PSTD oversight

State Fund vs. Private Insurance:

• Oklahoma’s state fund provides compensation for cleanup costs and third-party liability damages
• Environmental Liability Insurance offers broader coverage including legal defense costs
• Private insurance may provide more comprehensive protection than state fund limitations

Mining Operations Insurance Requirements

Oklahoma Department of Mines Regulations

The Oklahoma Department of Mines regulates non-fuel mineral production and ensures reclamation of land disturbed by mining operations.

Coal Mining Oversight:

• Federal Jurisdiction: Coal mining in Oklahoma is regulated by the Federal Office of Surface Mining and Reclamation Enforcement (OSMRE)
• Performance Bonds: Required under 30 CFR Part 800 for surface coal mining operations
• Liability Insurance: Federal regulations require public liability insurance for surface coal mining operations

Non-Coal Mining Requirements:

• Permit and Bonding: Mining operators must obtain permits and post adequate bonds to cover site reclamation
• Current Bond Amounts: As of June 2025, $120,842,709.25 in reclamation bonds posted with the Department for non-coal permits
• Inspection Requirements: Active operations must be inspected 4-6 times per year per Title 45, Chapter 11, Section 907
• Accident Reporting: Operators must notify the Department of all serious injuries or fatal accidents in a timely manner

Insurance Coverage Areas:

• General liability for mining operations
• Environmental liability for site restoration
• Equipment and property coverage
• Workers’ compensation (required for employees)
• Professional liability for mining consultants and engineers

Cell Tower and Telecommunications Regulations

Federal and State Oversight

While Oklahoma doesn’t operate a comprehensive state-level telecommunications regulatory program, businesses must comply with federal requirements and limited state oversight:

Federal Requirements:

• FCC Compliance: Building new towers or collocating antennas requires compliance with FCC environmental review rules
• FAA Coordination: Towers may require Federal Aviation Administration notification and approval
• NEPA and NHPA Compliance: Environmental and historic preservation requirements
• Antenna Structure Registration (ASR): Required registration with the FCC for certain structures

Oklahoma Corporation Commission Role:

• Limited Oversight: The Public Utility Division has limited regulatory oversight of telephone companies
• Universal Service Fund: Oversees Oklahoma Universal Service Fund for special services to schools and medical facilities
• New Carrier Applications: Reviews applications for new carriers offering services within the state

Insurance Considerations:

• General liability insurance for construction and maintenance activities
• Professional liability for telecommunications services
• Property insurance for tower equipment and infrastructure
• Environmental liability coverage for potential environmental impacts
• Workers’ compensation for tower construction and maintenance crews

Municipal Regulations:

• Local jurisdictions may have specific zoning and setback requirements (e.g., Sallisaw, OK requires 1,500 feet setback from homes for commercial wireless towers)
• Building permits and local approval requirements
• Design standards and aesthetic requirements

Workers’ Compensation Regulations

Oklahoma Workers’ Compensation System

Oklahoma operates a comprehensive workers’ compensation system administered by the Oklahoma Workers’ Compensation Commission.

Mandatory Coverage Requirements:

• Coverage Threshold: Required for employers with five or more employees
• Universal Coverage: All employees (full-time and part-time) must be covered
• Immediate Coverage: Required from the first day of employment
• Cost Responsibility: All costs paid by employer; cannot deduct premiums from employee wages

Exemptions from Coverage:

• Agricultural or horticultural workers employed by companies with less than $100,000 in payroll during the previous calendar year
• Real estate agents or brokers who are licensed and paid on commission
• Federal employees and certain Department of Human Services trainees
• Family businesses with five or fewer employees all related by blood or marriage
• Independent contractors (subject to specific criteria)

Compliance Options:

• Private Insurance: Purchase from licensed insurance companies
• Self-Insurance: Obtain approval from Workers’ Compensation Commission
• Group Self-Insurance: Join commission-approved group associations
• Qualified Employer Plans: Obtain approval from Oklahoma Insurance Department

Penalties for Non-Compliance:

• Fines up to $1,000 per day without coverage
• Misdemeanor charges for failing to obtain required coverage
• Business cessation orders after two violations
• Civil litigation exposure from injured employees
• Liability for all workplace injury costs

OSHA Regulations Specific to Oklahoma Operations

Federal OSHA Jurisdiction

Oklahoma operates under federal OSHA jurisdiction for private sector workers, with a separate state program for public employees.

Private Sector Coverage:

• Federal OSHA Authority: Covers most private sector workers in Oklahoma
• Area Office: Located at 5104 N. Francis Ave., Suite 200, Oklahoma City, OK 73118
• Standard Compliance: Must follow 29 CFR regulations including general industry (Part 1910), construction (Part 1926), maritime (Parts 1915, 1917, 1918), and agriculture (Part 1928)

Public Employees Occupational Safety & Health (PEOSH):

• State Authority: Covers state agencies, cities, counties, public schools, and universities
• Separate Standards: Public employees fall under state-managed safety regulations
• Oklahoma Department of Labor: Administers PEOSH program independently from federal OSHA

Training and Consultation:

• OSHA Outreach Training: 10-Hour and 30-Hour courses recommended for general safety orientation
• Free Consultation Services: Available through Oklahoma Department of Labor for small and medium-sized businesses
• Tax Incentive: $1,000 state tax exemption available for completing full-service consultations
• Industry-Specific Training: Required for telecommunications work (29 CFR 1910.268), construction activities, and other specialized operations

Enforcement and Compliance:

• Private sector inspections conducted by federal OSHA
• Public sector oversight by Oklahoma Department of Labor
• Consultation services separate from enforcement (no citations or penalties)
• Priority given to high-hazard worksites for consultation services

Business Registration and General Insurance Requirements

State Registration and Licensing

All businesses operating in Oklahoma must comply with basic registration requirements:

• Registration with Oklahoma Secretary of State
• Appropriate business licenses based on industry type
• Sales tax permits from Oklahoma Tax Commission (where applicable)

Recommended Coverage

While not always legally mandated, businesses should consider:

• Commercial General Liability: Protection against third-party claims
• Professional Liability: Essential for service providers and consultants
• Cyber Liability: Increasingly important for data protection
• Business Interruption: Coverage for operational disruptions
• Directors & Officers Liability: For corporations and LLCs
• Employment Practices Liability: Protection against workplace discrimination claims

Conclusion

Oklahoma’s diverse economy requires businesses to navigate complex insurance requirements across multiple regulatory agencies. From the Oklahoma Corporation Commission’s oversight of oil and gas operations to federal OSHA requirements for workplace safety, understanding these regulations is crucial for business success.

Key regulatory bodies include the Oklahoma Corporation Commission, which oversees oil and gas, as well as petroleum storage tanks. The Oklahoma Department of Mines regulates non-coal mining. The Oklahoma Workers’ Compensation Commission handles workplace injuries. Federal agencies like OSHA and the FCC manage specialized operations.

Experienced commercial insurance professionals are familiar with Oklahoma’s regulatory landscape. By working with them, your business maintains appropriate coverage. This also ensures it meets all state and federal requirements. Regular reviews of insurance portfolios help maintain compliance as regulations evolve and businesses grow.

This guide provides general information about Oklahoma commercial insurance requirements and should not be considered legal or insurance advice. Specific requirements vary by location, business type, and operational scope. Consult with qualified insurance professionals and legal counsel for guidance on your specific situation.