Ohio Rev. Code » Chapter 4509
Ohio Revised Code

Ohio Rev. Code § 4509.45 (2026)

Filing of proof of financial responsibility

✓ current as of May 2026
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Effective:
April 9, 2025
Latest Legislation:
House Bill 29 - 135th General Assembly
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(A) As used in this section, "electronic wireless communications device" has the same meaning as in section 4509.103 of the Revised Code.

(B) Proof of financial responsibility when required under section 4509.101, 4509.33, 4509.34, 4509.38, 4509.40, 4509.42, 4509.44, or 4510.038 of the Revised Code may be given by filing and maintaining any of the following:

(1) A financial responsibility identification card as provided in section 4509.104 of the Revised Code;

(2) A certificate of insurance as provided in section 4509.46 or 4509.47 of the Revised Code;

(3) A bond as provided in section 4509.59 of the Revised Code;

(4) A certificate of deposit of money or securities as provided in section 4509.62 of the Revised Code;

(5) A certificate of self-insurance, as provided in section 4509.72 of the Revised Code, supplemented by an agreement by the self-insurer that, with respect to accidents occurring while the certificate is in force, the self-insurer will pay the same amounts that an insurer would have been obligated to pay under an owner's motor vehicle liability policy if it had issued such a policy to the self-insurer.

(C) When proof of financial responsibility is required to be given under section 4509.101 of the Revised Code, such proof also may be given through use of an electronic wireless communications device as provided in that section.

(D) Proof under division (B) of this section shall be filed and maintained for one year from the date of the registrar's imposition of a suspension of operating privileges. Proof of financial responsibility that is required to be filed and maintained with the registrar during a period of suspension of operating privileges described in this division shall not be given through the use of an electronic wireless communications device.

Last updated January 28, 2025 at 1:10 PM

Notes of Decisions
Cited in 43 cases (2 in the last 5 years), 1960–2023 · leading case: Grange Mut. Cas. Co. v. Refiners Transp. & Terminal Corp., 487 N.E.2d 310 (Ohio 1986).
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Grange Mut. Cas. Co. v. Refiners Transp. & Terminal Corp., 487 N.E.2d 310 (Ohio 1986). · cites it 5× “As in the above cases, the instant appellant alleged in its complaint that Refiners was a self-insurer under R.C. 4509.45, which provides in relevant part: “Proof of financial responsibility * * * may be given by filing any of the following: “(A) A certificate of insurance * *…”
Archer v. ACE, USA, 788 N.E.2d 662 (Ohio Ct. App. 2003). · cites it 9× “45 provides: {¶ 11} “Proof of financial responsibility * * * may be given by filing any of the following: {¶ 12} “(A) A financial responsibility identification card * * *; {¶ 13} “(B) A certificate of insurance * * *; {¶ 14} “(C) A ¡financial surety] bond * * *; {¶ 15} “(D) A…”
Gilchrist v. Gonsor, 2004 Ohio 7103 (Ohio 2004). · cites it 16× “101(A)(1); R.C. 4509.45. As the majority states, R.C.”
Hellman v. Motorists Mut. Ins., 794 N.E.2d 688 (Ohio Ct. App. 2003). · cites it 5× “” The *413 Straubhaar court reasoned that a policy with a matching liability limit and deductible obviated the need for obtaining a certificate of self-insurance under R.C. 4509.45 and 4509.72. Id. at ¶ 3. Like the Straubhaar court, we see no difference between maintaining a…”
Snyder v. Roadway Express, Inc., 455 N.E.2d 11 (Ohio Ct. App. 1982). · cites it 4× “” Once a person obtains a certificate of self-insurance he may use the certificate to prove financial responsibility by filing it with the registrar along with an agreement to pay whatever amounts an insurer would have been obligated to pay under an owner’s motor vehicle…”
Bob-Boyd Lincoln Mercury v. Hyatt, 513 N.E.2d 331 (Ohio 1987). · cites it 3× “) R.C. 4509.45 provides that one way of showing proof of financial responsibility, when required, is by filing a certificate of insurance as provided in R.”
Lafferty v. Reliance Ins., 109 F. Supp. 2d 837 (S.D. Ohio 2000). · cites it 2× “In effect, the policy was a “fronting agreement” in which the deductible amount is the same as the policy limits and Conrail relied on Reliance to file proof of insurance as required by various Ohio governmental agencies.”
Dolly v. Old Repub. Ins. Co., 200 F. Supp. 2d 823 (N.D. Ohio 2002). · cites it 2× “The Refiners Transport court explained that, although the employer’s purchase of a surety bond and two excess insurance policies to meet its financial responsibility requirements did not make it a self-insurer “in the legal sense contemplated by R.C. 4509.45(D) and 4509.72,” id.…”
Matter of Cerny, 17 B.R. 221 (Bankr. N.D. Ohio 1982). · cites it 4× “Debtor contends that the requirement of prospective financial responsibility insurance in a form prescribed by Section 4509.45 of the Ohio Revised Code violates the anti-discrimination provisions of 11 U.”
Duffey v. Dollison (In Re Duffey), 13 B.R. 785 (Bankr. S.D. Ohio 1981). · cites it 3× “-42 of the Revised Code, and upon such person’s filing with the registrar or motor vehicles evidence of financial responsibility in accordance with section 4509.45 of the Revised Code.” Further, Ohio law creates the duty of the defendant to maintain a suspension of the…”
Cincinnati Ins. v. Kramer, 632 N.E.2d 1333 (Ohio Ct. App. 1993). · cites it 2× “This section, however, relates only to insurance policies that are subject to proof of financial responsibility as required by R.C. 4509.45 and 4509.46. Bob-Boyd Lincoln Mercury v.”
Roberts v. State Farm Mut. Auto. Ins., 802 N.E.2d 157 (Ohio Ct. App. 2003). “{¶ 78} In Ohio, self-insurers, who comply with R.C. 4509.45(E) and 4509.72, are exempt from the requirements of R.”
Show all 43 citing cases →
Ohio Rev. Code § 4509.45(A): 2 cases
Matter of Cerny, 17 B.R. 221 (Bankr. N.D. Ohio 1982). “Debtor contends that the requirement of prospective financial responsibility insurance in a form prescribed by Section 4509.45 of the Ohio Revised Code violates the anti-discrimination provisions of 11 U.”
Gilchrist v. Gonsor, 2004 Ohio 7103 (Ohio 2004). “101(A)(1); R.C. 4509.45. As the majority states, R.C.”
Ohio Rev. Code § 4509.45(A)(1): 2 cases
Gilchrist v. Gonsor, 2004 Ohio 7103 (Ohio 2004). “101(A)(1); R.C. 4509.45. As the majority states, R.C.”
White v. Ins Co of PA (6th Cir. 2005).
Ohio Rev. Code § 4509.45(A)(2): 1 case
Safe Auto Ins. v. Koroma, 864 N.E.2d 703 (Ohio Ct. App. 2006).
Ohio Rev. Code § 4509.45(A)(3): 1 case
Gilchrist v. Gonsor, 2004 Ohio 7103 (Ohio 2004). “101(A)(1); R.C. 4509.45. As the majority states, R.C.”
Ohio Rev. Code § 4509.45(A)(5): 1 case
Gilchrist v. Gonsor, 2004 Ohio 7103 (Ohio 2004). “101(A)(1); R.C. 4509.45. As the majority states, R.C.”
Ohio Rev. Code § 4509.45(B): 2 cases
Grange Mut. Cas. Co. v. Refiners Transp. & Terminal Corp., 487 N.E.2d 310 (Ohio 1986). “As in the above cases, the instant appellant alleged in its complaint that Refiners was a self-insurer under R.C. 4509.45, which provides in relevant part: “Proof of financial responsibility * * * may be given by filing any of the following: “(A) A certificate of insurance * *…”
Grange Mut. Ins. Co. v. Patino, 2020 Ohio 466 (Ohio Ct. App. 2020).
Ohio Rev. Code § 4509.45(C): 1 case
Archer v. ACE, USA, 788 N.E.2d 662 (Ohio Ct. App. 2003). “45 provides: {¶ 11} “Proof of financial responsibility * * * may be given by filing any of the following: {¶ 12} “(A) A financial responsibility identification card * * *; {¶ 13} “(B) A certificate of insurance * * *; {¶ 14} “(C) A ¡financial surety] bond * * *; {¶ 15} “(D) A…”
Ohio Rev. Code § 4509.45(D): 10 cases
Grange Mut. Cas. Co. v. Refiners Transp. & Terminal Corp., 487 N.E.2d 310 (Ohio 1986). “As in the above cases, the instant appellant alleged in its complaint that Refiners was a self-insurer under R.C. 4509.45, which provides in relevant part: “Proof of financial responsibility * * * may be given by filing any of the following: “(A) A certificate of insurance * *…”
Hellman v. Motorists Mut. Ins., 794 N.E.2d 688 (Ohio Ct. App. 2003). “” The *413 Straubhaar court reasoned that a policy with a matching liability limit and deductible obviated the need for obtaining a certificate of self-insurance under R.C. 4509.45 and 4509.72. Id. at ¶ 3. Like the Straubhaar court, we see no difference between maintaining a…”
Lafferty v. Reliance Ins., 109 F. Supp. 2d 837 (S.D. Ohio 2000). “In effect, the policy was a “fronting agreement” in which the deductible amount is the same as the policy limits and Conrail relied on Reliance to file proof of insurance as required by various Ohio governmental agencies.”
Dolly v. Old Repub. Ins. Co., 200 F. Supp. 2d 823 (N.D. Ohio 2002). “The Refiners Transport court explained that, although the employer’s purchase of a surety bond and two excess insurance policies to meet its financial responsibility requirements did not make it a self-insurer “in the legal sense contemplated by R.C. 4509.45(D) and 4509.72,” id.…”
Dorsey v. Fed. Ins., 798 N.E.2d 47 (Ohio Ct. App. 2003).
Ohio Rev. Code § 4509.45(E): 1 case
Roberts v. State Farm Mut. Auto. Ins., 802 N.E.2d 157 (Ohio Ct. App. 2003). “{¶ 78} In Ohio, self-insurers, who comply with R.C. 4509.45(E) and 4509.72, are exempt from the requirements of R.”
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