MCS-150: filing and updating your USDOT number every two years

Who files an MCS-150

Every motor carrier operating in interstate commerce files Form MCS-150 with FMCSA, under 49 CFR 390.19T. For a NEMT company, the question is whether any paid trip crosses a state line, such as a dialysis or hospital run into the next state. Our guide to whether a NEMT company needs a DOT number works through that test and through the states that ask in-state carriers for a USDOT number too.

The same form does two jobs. The first MCS-150 is the application that gets you a USDOT number, filed before you start operating, and a for-hire carrier can send it along with its application for operating authority. After that, the same form is the update FMCSA requires every 24 months.

When your update is due

The USDOT number itself sets the deadline. Its last digit picks the month, and you must file by the last day of that month.

The next-to-last digit picks the year. If it is odd, you update in odd-numbered years. If it is even, you update in even-numbered years.

For example, a USDOT number ending in 31 is due in January, because the last digit is 1. The digit before it, 3, is odd, so its next update falls due by January 31, 2027, and then every second January after that. Put the date on your compliance calendar the day the number is issued.

What the form asks

The MCS-150 is a short company profile. FMCSA’s 2025 description of the information collection lists what it covers:

• Who you are. The business that owns and controls the operation, and the address and phone number of its principal place of business.
• Your identifiers. The numbers FMCSA has already assigned.
• What you do. The type of operation and the kinds of cargo usually carried. A NEMT company carries passengers.
• Your equipment and people. The number of vehicles owned, term leased, and trip leased, plus driver information.
• A signature. A certification signed by someone authorized to sign for the business.

FMCSA estimates a biennial update takes about 7.5 minutes. Use only your legal name or one trade name on the form. That same name has to appear on the side of each commercial vehicle, as the vehicle signage guide explains. The vehicle count matters beyond FMCSA too: Unified Carrier Registration may size your fee from the vehicle count you reported on your latest MCS-150.

What a missed update costs

Skipping the update puts the USDOT number itself at risk. Under 390.19T(b)(4), a carrier that does not complete its biennial update faces civil penalties under 49 U.S.C. 521(b)(2)(B) or 49 U.S.C. 14901(a), and deactivation of its USDOT number. Under the first statute, every day a required report stays unfiled can cost up to $1,000, with a $10,000 cap for a single violation, amounts FMCSA adjusts for inflation in 49 CFR part 386, appendix B. Filing false or misleading information on the form carries penalties too.

Enforcement is on hold for now. FMCSA’s registration notice, last updated September 10, 2026, says it has temporarily suspended enforcement of biennial updates and the inactivation of USDOT numbers while carriers move into Motus. Registrants whose update was due on or after June 1, 2026 get extra time and will not have their number inactivated for missing it. FMCSA says more guidance will follow, so file in your month anyway.

Filing through Motus

Biennial updates now go through Motus, the registration system FMCSA opened in May 2026. FMCSA’s April 29, 2026 notice says Motus replaces the older registration system and the FMCSA Portal, and that registrants who use Motus will not be cited or penalized for not using the old paper forms during the rollout. A company official can claim the existing USDOT number to speed up account setup. FMCSA also asked carriers to check their records for accuracy and to remove former staff from their FMCSA Portal accounts, which is worth doing before your month arrives. The DOT number guide covers the rest of the Motus move, including operating authority.