MCS-150 biennial update vs name change
The biennial update is mandatory every 24 months under 49 CFR §390.19T(b)(2)–(3) and is keyed to the last two digits of the USDOT number - the last digit sets the month (USDOT ending in 1 updates in January, ending in 5 in May, ending in 0 in October) and the next-to-last digit sets the odd or even filing year. A name-change MCS-150 is a one-off filing required within 30 days of the legal-name change under FMCSA registration guidance, and the change typically requires re-filing BOC-3 (FastBOC3Filing) under 49 CFR §366.4 because the new legal name supersedes the old one on FMCSA's record. Both use the same MCS-150 form - only the trigger and timing differ. Filing a name change does not reset the biennial cycle; the next biennial is still due on the USDOT's assigned schedule. A missed biennial update can lead to civil penalties and deactivation of the USDOT number (49 CFR 390.19T(b)(4)). Note: FMCSA has temporarily suspended enforcement of biennial updates and USDOT inactivation for updates due on or after June 1, 2026, until further notice.
Side-by-side comparison
| Dimension | Biennial Update | Name Change |
|---|---|---|
| Trigger | 24 months from last filing | Legal-name or DBA change |
| CFR anchor | §390.19T(b)(2)–(3) | FMCSA registration guidance |
| Deadline | USDOT-digit-driven month/year | 30 days from name change |
| Form used | MCS-150 (or MCS-150B for hazmat) | MCS-150 (same form) |
| Penalty for missing | Civil penalties and USDOT deactivation (§390.19T(b)(4)) | USDOT record out of date |
| MC re-issuance needed | No | Yes - Form OP-1A separately |
| FastMCS150 fee | $175 standard | $175 standard (covers MCS-150 only; OP-1A separate) |
When to file the biennial update
The biennial schedule is set by the carrier's USDOT digits. Look up the next due month on the FMCSA biennial calendar (or use the FastMCS150 due-date checker), and file in that month even if no carrier data has changed. A missed biennial update can lead to civil penalties and deactivation of the USDOT number (49 CFR 390.19T(b)(4)). Note: FMCSA has temporarily suspended enforcement of biennial updates and USDOT inactivation for updates due on or after June 1, 2026, until further notice.
When to file a name-change update
File a name-change MCS-150 within 30 days of any legal-name or DBA change at the state SOS. The form has fields for the old name and new name; submitting the form updates the USDOT-side record. Most carriers also re-print bills of lading and other commercial documents in the new name, but those are state/commercial-side actions independent of FMCSA.
Operating-authority documents (the MC certificate) need separate re-issuance under Form OP-1A. Without OP-1A, the MC certificate continues to read in the old name even after the MCS-150 name change.
Frequently asked questions
Does a name change reset the biennial cycle?
No. The biennial schedule is keyed to the USDOT number, not the carrier name. A name-change MCS-150 satisfies FMCSA's 30-day update rule but does not move the next biennial deadline.
What if I need both a biennial update and a name change at the same time?
File one MCS-150 covering both. The form has fields for the new name plus all the standard biennial-update data; no need to file two separate forms. FMCSA processes the name change and biennial update in one submission.
Does an MC name change require a separate filing?
Yes. A name change on the MC side requires Form OP-1A (re-issuance of operating authority). The MCS-150 covers the USDOT-side name change, but operating-authority documents need to be re-issued under OP-1A separately.
File MCS-150 - biennial or name change - for $175
Same fee for either trigger. Your MCS-150 is prepared and submitted to FMCSA for you.
File MCS-150