Transportation: FMCSA Biennial Update Requirement  

According to the Federal Motor Carrier Safety Administration (FMCSA), the agency is continuing its transition to Motus, the USDOT Registration System, which launched on May 19, 2026.¹  

To reduce disruptions during the transition, FMCSA has temporarily suspended enforcement of the biennial update requirement and the inactivation of USDOT Numbers for entities that have not completed their required biennial update.¹  

FMCSA has indicated that it will provide advance notice through official registration alerts and public communications before enforcement resumes. Carriers should monitor the Motus system and FMCSA notification channels for further guidance.¹  

Who Must Complete the Biennial Update?  

Entities required to complete the biennial update include:²  

• For-hire motor carriers operating commercial vehicles across state lines  

• Private carriers using commercial motor vehicles for their own purposes  

• Owner-operators with an active USDOT Number  

• Trucking companies, passenger carriers, and other transportation businesses holding a USDOT Number

The requirement generally applies even if:  

• The company has not changed any information since its last update.²  

• The company has ceased interstate operations but has not properly notified FMCSA.²  

• The company is no longer operating but has not notified FMCSA.²  

What Does the Temporary Suspension Mean?  

FMCSA updated its guidance on September 10, 2026, confirming the temporary suspension of enforcement of the biennial update requirement.¹  

Under the current suspension:  

• Carriers whose biennial update was due on or after June 1, 2026, will not have their USDOT Number inactivated for failing to file the update during the suspension period.¹  

• Additional time will be provided for carriers to complete the filing while FMCSA continues updating the Motus system.¹  

The federal biennial update requirement has not been eliminated. It remains in place and is expected to resume once FMCSA provides further notice.¹  

FMCSA has not provided a specific date for when enforcement will resume.¹  

Carriers should continue to monitor FMCSA communications and be prepared to complete their required update once the agency announces that enforcement has resumed.¹  

The federal biennial update requirement applies to carriers operating in interstate commerce. Carriers whose operations are entirely within a single state and are not part of an interstate movement may be exempt from the federal MCS-150 filing requirement, although state-specific requirements may still apply.³  

Understanding “Interstate Commerce”  

For purposes of the federal requirements, interstate commerce generally involves the transportation of goods or passengers across state lines, as well as certain transportation that is part of an interstate movement even when the actual trip occurs entirely within one state.³  

E-Commerce: Economic Nexus Update  

There have been developments regarding economic nexus requirements for e-commerce businesses.  

Economic nexus rules allow states to require remote sellers to collect and remit sales tax when their sales into the state exceed a specified threshold, even when the seller does not have a physical presence in that state.⁶  

Thresholds vary by state. Common thresholds include:⁶  

• $100,000: Most states with a statewide sales tax  

• $250,000: Alabama and Mississippi  

• $500,000: California, New York, and Texas  

• No statewide sales tax: Delaware, Montana, New Hampshire, and Oregon  

Some states also impose a transaction-count requirement in addition to a sales threshold.⁶  

Examples:   

• New York:  

• $500,000 in gross sales and 100 or more transactions in the immediately preceding four sales tax quarters.⁶  

• Connecticut: 

• $100,000 in sales and 200 or more retail transactions.⁶  

Businesses should treat these figures as general guidance rather than a substitute for reviewing the applicable state law. Economic nexus rules can differ regarding transaction thresholds, marketplace sales, aggregation of related sales, and the applicable measurement period.⁶  

Businesses engaged in e-commerce should review the requirements in each state where they make sales to determine whether they have an obligation to register, collect, and remit sales tax.⁶  

Questions?  

NRLA and ABMA will continue to keep our members informed of developments that may affect the industry.  

If you have any questions regarding these issues, please contact Kevin Scorsone, Director of Legislative & Regulatory Affairs, at kscorsone@nrla.org.  

Sources  

¹ Federal Motor Carrier Safety Administration, Temporary Suspension of the Biennial Update Requirement, September 10, 2026.  

² Federal Motor Carrier Safety Administration, How Do You Complete a Biennial Update?  

³ Federal Motor Carrier Safety Administration, Form MCS-150 and Instructions – Motor Carrier Identification Report; see also eCFR, 29 CFR § 782.7 – Interstate Commerce Requirements of Exemption.  

⁴ RLLC, DOT Biennial Update.  

⁵ US Compliance Services, Understanding the MCS-150 Form and Biennial Update Requirements.  

⁶ TaxCloud, Economic Nexus by State 2026.  

⁷ DOT Operating Authority, USDOT Biennial Update Filing.  

⁸ FMCSA.com, MCS-150 Biennial Update: What Carriers Need to File and When.