Who is required to file
Any of the following, if they hold an active USDOT number, must file the biennial update:
- Owner-operators, regardless of fleet size
- For-hire and private motor carriers
- Freight forwarders and brokers issued a USDOT number
- Intermodal equipment providers and carriers holding a Hazardous Materials Safety Permit
Operating status does not exempt a company from this requirement. A USDOT number that is active but inactive in practice — no loads hauled, no equipment in service — still requires the update on schedule.
Filing schedule
Two digits of the USDOT number set the schedule, and each does a different job: the last digit sets the filing month (1=January, 2=February, continuing through 9=September, 0=October), and the next-to-last digit sets whether the filing falls in odd or even years — an odd digit (1,3,5,7,9) means odd-numbered years, an even digit (0,2,4,6,8) means even-numbered years. The filing is due by the last day of the assigned month. This schedule is fixed for the life of the number; it is not tied to a registration anniversary.
If no company information has changed
The update is still required. FMCSA's rule treats an unchanged record as something that still needs to be affirmatively re-confirmed, not assumed. A separate requirement applies outside the biennial cycle: any change to company information — name, address, or other listed details — must be filed within 30 days of that change, independent of the 24-month schedule.
Filing process
As of 2026, MCS-150 updates are filed through Motus, FMCSA's new registration system, which has replaced the older FMCSA Portal and Unified Registration System. The requirement itself hasn't changed — only the system it's filed through. If you're expecting the older portal interface, you'll be redirected to Motus. See our Motus Transition Guide if you haven't set up account access yet.
- Record lookup. Your existing FMCSA record is retrieved using your USDOT number.
- Review. You confirm the record or correct any field that has changed — address, fleet size, cargo classification, operation type.
- Submission. The update is filed electronically through Motus. A filing confirmation is issued for your records.
Who is exempt
Exemptions here are narrower than they're sometimes made out to be, and worth getting right. Most exemptions people ask about are actually exemptions from needing operating authority (an MC number) — not from needing a USDOT number itself. A carrier that only transports its own employees, for example, is exempt from the operating authority requirement, but still needs a USDOT number, and therefore still needs to file the MCS-150.
The genuinely narrow group exempt from a USDOT number altogether includes for-hire carriers that exclusively haul federally exempt commodities, and carriers operating entirely within a federally designated commercial zone. "Strictly intrastate" is not, by itself, a blanket exemption — intrastate requirements vary by state, and intrastate hazmat carriers requiring a safety permit are required to register regardless. If you're unsure which category applies to your operation, it's worth confirming directly rather than assuming.
Why the data matters beyond the filing itself
MCS-150 data feeds directly into FMCSA's PRISM program (Performance and Registration Information Systems Management), which uses it to identify higher-risk carriers and factors into Compliance, Safety, Accountability (CSA) scoring. Outdated or inaccurate information on your MCS-150 doesn't just risk a rejected filing — it can create a mismatch with your CSA profile, and insurance providers, brokers, and shippers do check these records when deciding who to work with. Keeping the filing accurate is part of your safety reputation, not just paperwork.
Filing errors that lead to rejection or deactivation
- Treating a reminder notice as confirmation of filing. Notices — from FMCSA or third parties — indicate a filing is due, not that it has been completed.
- Filing under an incorrect operation classification. Interstate/intrastate mismatches can create conflicts with a carrier's insurance filings on record.
- Filing after deactivation rather than within the open window. Once deactivated, the carrier must file for reactivation, a separate process from the standard update.