Who is required to file
Any of the following, if they hold an active USDOT number, must file the biennial update:
- Owner-operators, regardless of fleet size
- For-hire and private motor carriers
- Freight forwarders and brokers issued a USDOT number
- Intermodal equipment providers and carriers holding a Hazardous Materials Safety Permit
Operating status does not exempt a company from this requirement. A USDOT number that is active but inactive in practice — no loads hauled, no equipment in service — still requires the update on schedule.
Filing schedule
Two digits of the USDOT number set the schedule, and each does a different job: the last digit sets the filing month (1=January, 2=February, continuing through 9=September, 0=October), and the next-to-last digit sets whether the filing falls in odd or even years — an odd digit (1,3,5,7,9) means odd-numbered years, an even digit (0,2,4,6,8) means even-numbered years. The filing is due by the last day of the assigned month. This schedule is fixed for the life of the number; it is not tied to a registration anniversary.
If no company information has changed
The update is still required. FMCSA's rule treats an unchanged record as something that still needs to be affirmatively re-confirmed, not assumed. A separate requirement applies outside the biennial cycle: any change to company information — name, address, or other listed details — must be filed within 30 days of that change, independent of the 24-month schedule.
Filing process
- Record lookup. Your existing FMCSA record is retrieved using your USDOT number.
- Review. You confirm the record or correct any field that has changed — address, fleet size, cargo classification, operation type.
- Submission. The update is filed electronically. A filing confirmation is issued for your records.
Filing errors that lead to rejection or deactivation
- Treating a reminder notice as confirmation of filing. Notices — from FMCSA or third parties — indicate a filing is due, not that it has been completed.
- Filing under an incorrect operation classification. Interstate/intrastate mismatches can create conflicts with a carrier's insurance filings on record.
- Filing after deactivation rather than within the open window. Once deactivated, the carrier must file for reactivation, a separate process from the standard update.