The biennial-update duty for a U.S. carrier is §390.19T. Under §390.19T(a)(1), every motor carrier conducting operations in interstate commerce — U.S.-, Canada-, Mexico-, or non-North America-domiciled — must file Form MCS-150, the Motor Carrier Identification Report. §390.19T(b) sets the schedule: before the carrier begins operations ((b)(1)), and every 24 months ((b)(2)) in the month fixed by the last digit of the USDOT number and the year fixed by its next-to-last digit ((b)(3)). Only the legal name or a single trade name of the carrier may appear on the form ((f)).
Why the "T". §390.19T is a temporary section standing in for §390.201, the Unified Registration System rule, which was suspended indefinitely effective November 17, 2023 (88 FR 80184). The un-suffixed §390.19 — the number this page used to carry — is a separate section for certain Mexico-domiciled carriers and is itself suspended indefinitely under the same notice. The old address now redirects here.
What happens if you miss the biennial
§390.19T(b)(4): a person that fails to complete a biennial update is subject to the penalties prescribed in 49 U.S.C. 521(b)(2)(B) or 49 U.S.C. 14901(a), "as appropriate," and to deactivation of its USDOT Number. For carriers within 14901(a)'s scope, the inflation-adjusted amounts are in 49 CFR Part 386, Appendix B, ¶(g)(16): a minimum of $1,365 and a maximum of $10,269 per violation. Operating with a deactivated USDOT number is operating unregistered; reactivation means filing the overdue update.
Enforcement is temporarily suspended. FMCSA's registration page (last updated September 10, 2026) says that, to reduce disruption during the transition to Motus — the USDOT Registration System launched May 19 — the agency "has temporarily suspended enforcement of biennial updates and the inactivation of USDOT Numbers" for entities that have not completed the update. Registrants whose update was due on or after June 1, 2026 will receive additional time and will not have their number inactivated for a missed update. The rule has not changed, only its enforcement, and the notice promises further guidance — so file on schedule and keep the confirmation.
How to file
Updating your information is free — FMCSA's "Updating Your Registration" page says so in those words. Anyone offering to file it for you is charging for a service the agency does not charge for. The filing itself runs through FMCSA's registration system; the agency's current guidance points to Motus and, for form uploads, the Ask FMCSA website, with mail as the slow alternative.
See our step-by-step MCS-150 guide for the walkthrough.
When the update is due
The month comes from the last digit of your USDOT number (1 = January, 2 = February … 9 = September, 0 = October) and the year from the next-to-last digit — odd digit, odd-numbered years; even digit, even-numbered years (§390.19T(b)(2)–(3)). The cycle is keyed to the number, not to the month the number was issued. Check the "MCS-150 Form Date" on your SAFER Company Snapshot to see when you last filed.
How to prevent it
- Set a calendar reminder 60 days before each biennial.
- Update the MCS-150 whenever your legal name, address, operation, or fleet size changes; FMCSA's guidance is to keep the record current "in a timely manner," and a stale record is what an auditor notices first.
- Keep the email address on file current — it is how FMCSA notifies you.
How Roadworthy HQ helps
Roadworthy HQ tracks your MCS-150 last-filed date and surfaces the next biennial in the dashboard alert window with 60- and 30-day reminders. The MCS-150 confirmation receipt is stored on the carrier record.