What Is the MCS-150 Biennial Update, and Why Does It Exist?
Every moving company with an active USDOT number has to file an MCS-150 update every 24 months, even if nothing about the business has changed. The requirement traces back to FMCSA's own rule under 49 CFR 390.19, and it's not optional or informal: the point of the biennial update is to keep the federal government's motor carrier database (the same one anyone can search on the SAFER System) accurate for every registered carrier, so brokers, shippers, and safety investigators are working from real numbers instead of stale registration data from years ago.
This is a different, ongoing requirement from getting your USDOT number and MC number in the first place — that's a one-time application process. The biennial update is the maintenance step that keeps an authority you already hold active and accurate.
The most common mistake movers make with this requirement is assuming it only applies when something changes -- a new truck, a new address, a different phone number. It doesn't. FMCSA requires the update on a fixed 24-month schedule regardless of whether your company's information has changed at all (FMCSA, "Updating Your Registration or Authority"). If your business is exactly the same as it was two years ago, you still have to file.
When Is Your Biennial Update Actually Due?
FMCSA doesn't run a single annual deadline for every carrier. Your filing month is tied to the last digit of your own USDOT number, on a rotating schedule FMCSA has used since the November 2013 compliance date for this rule (FMCSA, "When am I required to file a biennial update?"):
| USDOT number ends in | File by the last day of |
|---|---|
| 1 | January |
| 2 | February |
| 3 | March |
| 4 | April |
| 5 | May |
| 6 | June |
| 7 | July |
| 8 | August |
| 9 | September |
| 0 | October |
There's a second layer on top of the month: whether you file in an odd or even year depends on the next-to-last digit of your USDOT number. If that digit is odd, you file in odd-numbered calendar years. If it's even, you file in even-numbered years. Miss that detail and you can file on the right month but the wrong year -- which FMCSA's system treats the same as not filing at all.
There's one exception worth knowing: if you update your registration for any other reason (a new address, a new phone number, a change in fleet size) within 12 months of your biennial due date, FMCSA counts that as satisfying the current cycle's biennial requirement. You won't get a reminder for the cycle you already covered -- just the next one (FMCSA biennial update FAQ).
What Happens If You Miss the Deadline?
This is where the requirement stops being a paperwork formality and starts being an operational risk. FMCSA is explicit about the consequence: failing to complete a biennial update results in deactivation of your USDOT number, and can also trigger civil penalties of up to $1,000 per day, capped at $10,000 total (FMCSA, "What are the penalties for failure to submit my biennial update?"). For-hire carriers, freight forwarders, and brokers can face additional civil penalties authorized separately under 49 U.S.C. 14901(a).
Deactivation isn't a soft warning label on your SAFER record. An inactive USDOT number means you're not authorized to operate in interstate commerce until it's reactivated -- which means every crew, every truck, and every booked interstate job is exposed the moment your number goes inactive, regardless of whether your MC number itself is still in good standing. Brokers who pull your SAFER record before dispatching a load (the same verification behavior covered in our carrier packet guide, alongside a current certificate of insurance) will see the inactive status immediately, and most will stop referring jobs to you on the spot.
How Do You Actually File It?
If your USDOT number is currently active, you file online through your FMCSA Portal account. If you don't have one yet, FMCSA's process runs through three steps: get your USDOT PIN from the SAFER Company Snapshot site, create a free Login.gov account (the federal government's single sign-on service), then use that PIN once to link your Login.gov email to your FMCSA Portal account (FMCSA, "Form MCS-150 and Instructions"). After that first linking step, you never need the PIN again -- your Login.gov email is what gets you back in.
One detail that trips up carriers who haven't logged in for a while: FMCSA Portal accounts are disabled after 90 days of inactivity and archived entirely after 12 months. If your account has gone stale, you'll need to contact the FMCSA Contact Center to get it unlocked before you can file -- budget extra time for that step if it's been a while since you last logged in.
If your number is already inactive, online filing isn't available. You'll need to submit a paper form by mail, which FMCSA itself warns can delay processing -- all the more reason to file the biennial update before your number lapses rather than after.
What's Changing Right Now With FMCSA's Motus Rollout?
FMCSA is in the middle of rolling out Motus, a new registration system meant to eventually replace the FMCSA Portal for every registration action, including the biennial update itself. As of this year, existing carriers are being migrated over: a May 2026 FMCSA newsroom bulletin instructed every Portal account holder to confirm their account was active and current, specifically because the "Biennial Update (MCS-150)" menu item was moving into Motus (FMCSA newsroom, "Important Steps You Must Take to Prepare for FMCSA's New Registration System," May 11, 2026).
FMCSA's own "About FMCSA Registration Changes" page is careful about what's confirmed versus what's still pending: existing USDOT numbers and docket numbers won't change, and multiple existing authorities will keep sharing the same docket number. New USDOT numbers and docket numbers, on the other hand, will be randomized going forward as an anti-fraud measure. A few bigger changes -- eliminating docket numbers altogether, changes to the BOC-3 filing process -- are explicitly listed as "under consideration," open for public comment in a future rulemaking, not settled policy yet (FMCSA, "About FMCSA Registration Changes"). If you've filed a biennial update the same way for years, expect the screen layout and account-linking step to look different the next time you log in -- the underlying filing schedule and penalty structure covered above haven't changed, just where you go to do it.
Why a Missed Biennial Update Is a Tracking Problem, Not a Compliance-Knowledge Problem
Almost nobody misses a biennial update because they don't know the requirement exists. They miss it because a filing month tied to the last digit of a USDOT number isn't the kind of date that naturally shows up on anyone's calendar, and because the person who filed it two years ago may not be the person running the office today. The same pattern shows up across every FMCSA-adjacent compliance deadline a moving company carries -- insurance renewal dates, BOC-3 filings, and the biennial update all compete for the same easy-to-forget mental space.
A moving company CRM that's actually built for the industry treats compliance dates the same way it treats a job's move date: as a scheduled event with a reminder, not a fact someone has to remember unprompted. Tracking your USDOT number's filing month and year inside the same system where you already track crew schedules and customer follow-ups means the reminder shows up in a place you're already looking every day, instead of depending on a mental note from two years ago. Pair that with a reporting dashboard that surfaces upcoming compliance dates alongside revenue and booking-rate numbers, and the biennial update stops being a once-every-two-years scramble and becomes one more scheduled task your business already handles well.
Frequently Asked Questions
Do I have to file an MCS-150 update if nothing about my company has changed?
Yes. FMCSA requires the biennial update every 24 months regardless of whether your company information has changed, ceased interstate operations, or is still in business. There's no "nothing changed" exemption.
How do I find out which month my biennial update is due?
Check the last digit of your USDOT number against FMCSA's filing schedule (1=January through 0=October), then check whether the next-to-last digit is odd or even to confirm the correct year.
Is there a fee to file the biennial update?
No. FMCSA states the update itself is free. Any company charging a fee specifically for "processing" your biennial update is charging for a service you can complete yourself at no cost through the FMCSA Portal.
What happens to my USDOT number if I miss the deadline entirely?
FMCSA deactivates the number, and you can face civil penalties up to $1,000 per day capped at $10,000. An inactive number means you're not authorized to operate in interstate commerce until you reactivate it.
Does updating my address or phone number count as my biennial update for that cycle?
Yes, if the change is reported within 12 months of your biennial due date, FMCSA counts it as satisfying that cycle's requirement, and you won't get a reminder until the next cycle.
Will Motus change how often I need to file, or just where I go to file it?
Just where you go to file, based on what FMCSA has published so far. The 24-month schedule and the underlying penalty structure are unchanged; what's moving is the account/interface you use to submit it, as FMCSA migrates biennial-update filing from the legacy Portal into Motus.
---
*A missed compliance date shouldn't be the reason a broker stops sending you loads. See how DriveSales tracks compliance dates alongside every job on your calendar, or book a demo to see it running on your own USDOT filing schedule.*
