FMCSA Pauses Biennial-Update Enforcement During Motus Rollout

When does FMCSA resume enforcement of the biennial-update requirement?

FMCSA has paused enforcement of the biennial-update requirement while the agency transitions carriers to Motus, its new registration platform. The agency has not published a date when enforcement will resume. Carriers who miss their biennial-update deadline during the transition will not face penalties while the pause remains in effect.

The biennial update (Form MCS-150) requires interstate carriers to confirm or update company information every two years. Missing the deadline normally triggers a deactivation of the carrier's USDOT number and operating authority. FMCSA built the pause into the Motus rollout after carriers reported service disruptions during the migration from the legacy Unified Registration System.

What Motus changes for carrier registration

Motus replaces the Unified Registration System that carriers have used since 2015 to file new-entrant applications, update MCS-150 data, and manage operating authority. FMCSA promoted the new system as mobile-friendly with stronger identity verification, real-time data validation, and centralized company accounts that let multiple users access the same carrier profile.

The agency's references to recovery and stabilization efforts in public guidance indicate the transition caused more problems than FMCSA anticipated. Carriers have reported login failures, missing data from legacy accounts, and error messages that block MCS-150 submissions.

FMCSA extended the hours of its Registration Customer Service Center to handle the volume of problem reports. Phone and chat assistance is now available weekdays from 8 a.m. to 11 p.m. Eastern time, plus Saturdays during the same hours. The agency advised carriers to submit one ticket through the FMCSA Contact Center and follow up on that case rather than creating duplicate tickets, which slow response times.

Intrastate carriers and the biennial-update rule

Motus does not offer a biennial-update option for intrastate carriers because those carriers are not subject to the federal biennial-update requirement. Intrastate carriers operate only within one state and fall under state DOT registration rules, not FMCSA's two-year MCS-150 cycle.

Interstate carriers (those who cross state lines or haul federally regulated commodities) must file the biennial update even if most of their miles stay in one state. The distinction turns on the type of commerce, not the geography of the routes. A carrier hauling hazardous materials entirely within Texas is interstate for FMCSA purposes and must update MCS-150 every 24 months.

What to do if your biennial-update deadline falls during the pause

Carriers whose biennial-update deadline arrives while enforcement is paused should still attempt to file through Motus if the system allows it. Completing the update on time avoids a backlog when FMCSA resumes enforcement. If Motus blocks the submission or returns an error, document the attempt with screenshots and a ticket number from the Contact Center.

When FMCSA resumes enforcement, the agency will likely announce a grace period for carriers who could not file because of system problems. The grace period will depend on how long the stabilization work takes and how many carriers are still locked out of Motus when the pause ends. Carriers who ignored the deadline without attempting to file or contact FMCSA should not expect leniency once enforcement restarts.

Check your biennial-update deadline by logging into Motus or calling the Registration Customer Service Center at the extended hours listed above. The deadline is exactly two years from the last time you filed MCS-150, not two years from the date you received your USDOT number. Missing it after the pause ends will deactivate your authority and put trucks out of service until you refile and FMCSA processes the update.

Motus and the rest of your FMCSA paperwork

The biennial update is one piece of the registration and compliance cycle that Motus now handles. New-entrant applications, process-agent filings (Form BOC-3), and cargo-insurance updates (Form BMC-91 or BMC-91X) also run through Motus. FMCSA has not paused enforcement of those requirements.

Carriers starting up or adding authority must still file complete applications and meet the new-entrant safety audit within the first 12 months. FMCSA revived a 17-year-old rule in July 2026 that would require new carriers to pass a proficiency exam before receiving operating authority, but that rule is still in the supplemental-notice stage and not yet in effect.

If Motus blocks a time-sensitive filing (a new authority application with a load waiting, or a cargo-bond update before the old policy expires), call the Registration Customer Service Center immediately and ask for escalation. Document every contact. FMCSA has not published workarounds for filings that must happen during the transition, so persistence and a clear paper trail are the only tools a carrier has if the system fails at a critical moment.