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Published: September 09, 2026 | Reading time: 4 minutes
FMCSA paused enforcement of the biennial update. You should file anyway.
FMCSA's Office of Registration sent a notice to industry partners this week reiterating that it has temporarily stopped deactivating DOT numbers for carriers who miss the biennial update, due to the ongoing technical issues with MOTUS. The update says:
- Enforcement of the biennial update is temporarily suspended.
- USDOT numbers will not be inactivated for carriers who haven't completed one.
FMCSA's public web page on the suspension hasn't been updated since June 22 and still covers only the second one. The notice we posted is newer and adds an interesting detail.
FMCSA says it will give warning before the biennial update enforcement starts again. The requirement is still on the books. 49 CFR 390.19T still requires the update every 24 months, and paragraph (b)(4) still carries civil penalties and deactivation. FMCSA isn't enforcing them while it works out the bugs in MOTUS.
Your due date comes from your USDOT number. The last digit sets the month: 1 is January, 2 is February, on through 9 for September, and 0 for October. No carriers are due for a biennial update in November or December. The next-to-last digit sets the year the update is due. Even digits are required to file in even-numbered years and odd digits in odd ones.
The pause is temporary and FMCSA hasn't said when it ends. Anyone who stops filing is betting on getting enough warning to catch up, in a system that has struggled with routine work since May. Filing on your normal schedule costs nothing and takes the bet off the table.
It also keeps your number clean. PRISM is the program that ties your federal safety record to your state license plates, and every state now participates at full level. Under it, a state must deny a registration request when a carrier "possesses an inactive or deactivated USDOT number due to the biennial update not being completed when required." That is FMCSA's own language, and the pause on deactivation is the only thing standing between a missed update and your plates.
Here's that detail. The notice says that MOTUS no longer offers a biennial update option for intrastate carriers and that intrastate carriers are not subject to the federal biennial update requirement.
That's accurate for most intrastate operations. One group is the exception. 49 CFR 390.19T(a)(2) requires an intrastate carrier holding a hazardous materials safety permit to file Form MCS-150B, the hazmat version of the biennial update form, on the same 24-month schedule. That permit is a separate federal authorization for bulk placarded loads of the higher-risk hazard classes, not the hazmat endorsement on a driver's CDL. If that's you, the federal duty applies, MOTUS still shows you the option, and you sit outside the exemption in the notice.
For everyone else operating intrastate, MOTUS lets you update mileage, power units, and number of drivers. FMCSA says it's working on displaying the date of your most recent update so states can see when the record was last touched. That display isn't live yet.
Whether your state requires a recurring update is a state-by-state question. States vary, and FMCSA doesn't track intrastate rules the way it tracks federal ones. We also can't promise that editing those three fields satisfies whatever your state asks for. Call your state agency, or call us and we'll find out for you.
Since PRISM now covers every state, this one applies everywhere. 49 CFR 390.19T(i) says a motor carrier that registers its vehicles in a PRISM state "is exempt from the requirements of this section, provided it files all the required information with the appropriate State office." In practice FMCSA still wants the MCS-150, because states don't collect the full federal record. We're flagging it because it sits in the same section everyone cites at you. Almost nobody mentions this part of it.
- Find your due month. It's the last digit of your USDOT number.
- If MOTUS lets you file, file. The pause doesn't stop you from submitting.
- If MOTUS blocks you, open a ticket with FMCSA at ask.fmcsa.dot.gov or call 1-800-832-5660. That is the record that counts. Logging it at motusbugs.com helps us track what's broken. It doesn't replace an FMCSA ticket.
- Hazmat intrastate under a safety permit: you still owe an MCS-150B.
- Everyone else intrastate: check what your state expects.
We file biennial updates for carriers nationwide and we've been working inside MOTUS since the day it launched. If you're not sure whether your update is overdue, or what your state expects from you as an intrastate carrier, we can sort it out.
Call Don Norman Associates at 703-821-0000. DNA is our sister company and handles FMCSA authority work every day.
For background on the full MOTUS rollout, see our earlier posts:
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