Do I Need to File an MCS-150 Biennial Update?

The short answer: if you hold a USDOT number, you need to file MCS-150 every 24 months. The longer answer is about who holds a USDOT number in the first place and which intrastate carriers fall inside or outside the federal system. Here is the breakdown.

The Core Rule: Every USDOT Holder Files

Under 49 CFR Part 390, every entity with an active USDOT number must file MCS-150 at least once every 24 months. Fleet size does not matter. Operation type does not change the filing requirement — it only changes which fields on the form apply to you.

If the SAFER system at safer.fmcsa.dot.gov returns a result when you look up your company, you file MCS-150. If it does not, you are outside the federal USDOT system and this form does not apply.

Interstate Motor Carriers

Yes — every interstate motor carrier files MCS-150 on the biennial schedule. That is true for for-hire and private carriers, for single-truck owner-operators and 500-truck fleets, and for carriers of property, household goods, or passengers. The rule is universal for anyone operating a commercial motor vehicle across state lines under a USDOT.

Intrastate Motor Carriers

Intrastate is where the answer gets more nuanced. Most states run their motor carrier registrations through the FMCSA system, which means an intrastate carrier ends up with a USDOT number even though they never cross state lines. If that is your situation, you file MCS-150 on the same 24-month schedule as interstate carriers.

A handful of states operate separate intrastate-only registrations that never attach to the FMCSA system. Those carriers file state-level forms instead and are outside the MCS-150 rule. The fastest way to check: look up your business at safer.fmcsa.dot.gov. If you have a USDOT number listed, you file MCS-150.

Private Carriers

Private carriers — companies that haul their own goods rather than for hire — file MCS-150 whenever they operate a USDOT-registered CMV. The threshold for USDOT registration is vehicle weight (over 10,001 lbs GVWR), passenger count (9 or more including the driver, for compensation), or hazmat status. Private carriers above any of those thresholds hold USDOTs and file MCS-150.

Owner-Operators

Owner-operators fall into two camps:

• Operating under your own authority: you hold the USDOT and MC number directly, and you file your own MCS-150 every 24 months.
• Leased to a carrier: you operate under the lessor carrier's USDOT, and the lessor files their MCS-150. You do not file a separate one unless you also hold your own authority.

Freight Brokers and Freight Forwarders

Both file MCS-150 every 24 months. Brokers (MC-B) and freight forwarders (MC-FF) hold USDOT numbers tied to their operating authority, and the biennial update requirement applies to them the same way it applies to motor carriers. The form has different fields that apply — fleet and mileage do not, since brokers do not operate equipment — but the filing itself is required.

Who Is Exempt

Narrow list:

• Carriers who do not hold a USDOT number and operate purely intrastate under a state-only registration.
• Carriers who have voluntarily deactivated their USDOT and are no longer operating.
• Certain agricultural and small-scale non-commercial operations below federal USDOT thresholds.

If none of those describe you and you have an active USDOT, you file MCS-150.