The short answer: if you hold a USDOT number and operate in interstate commerce, 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 rule. Here is the breakdown.
The Core Rule: Interstate USDOT Holders File
Under 49 CFR §390.19T(a), every motor carrier, broker, and freight forwarder conducting operations in interstate commerce must file MCS-150 at least once every 24 months on the biennial update cycle. 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 FMCSA record in FMCSA's Motus public search returns a result when you look up your company by USDOT number or company name and you operate interstate, 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. Many states require intrastate carriers to get a USDOT number even though they never cross state lines, but the number alone does not create the federal biennial duty: 49 CFR §390.19T(a)(1) covers carriers in interstate commerce. Intrastate-only carriers are not subject to the federal biennial update (FMCSA, Sept 2026); some states require them to update their FMCSA record on a recurring basis — check your state.
The exception is hazmat. An intrastate carrier that needs an FMCSA Hazardous Materials Safety Permit files the combined MCS-150B under §390.19T(a)(2). And any carrier with a USDOT number should still update the record within 30 days when its information changes.
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:
- Intrastate-only carriers, with or without a USDOT number, under the federal rule — though some states require recurring FMCSA record updates.
- 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 for interstate operations, you file MCS-150.
Due for Your MCS-150? File It Now
Interstate USDOT holders file every 24 months. Your MCS-150 is prepared and submitted for you for $175 standard or $400 lifetime updates.
File your MCS-150