When Does a Motor Carrier Need a USDOT Number, and How Is It Kept Current?

A USDOT Number is the identification number FMCSA issues to a motor carrier after it files its identification report. The current filing rules are in 49 CFR 390.19T, and the marking rules in 49 CFR 390.21T. Whether an operation is subject to these rules depends on the definitions explained in what is a DOT-regulated employer and understanding DOT regulated.

Who files. Under 49 CFR 390.19T(a):

• A motor carrier conducting operations in interstate commerce, whether domiciled in the U.S., Canada, Mexico or outside North America, files the Motor Carrier Identification Report, Form MCS-150.
• A motor carrier operating in intrastate commerce that needs a hazardous materials Safety Permit under 49 CFR Part 385, Subpart E, files Form MCS-150B.
• An intermodal equipment provider offering equipment in interstate commerce files Form MCS-150C.

After processing the form, FMCSA issues the USDOT Number (49 CFR 390.19T(h)(1)). A for-hire carrier should submit the form with its operating authority application (49 CFR 390.19T(e)).

New private and exempt for-hire applicants. Since January 14, 2017, a new applicant private motor carrier or new applicant exempt for-hire motor carrier files Form MCSA-1, the Unified Registration System (URS) online application (49 CFR 390.200T). A new applicant is one that has not previously held an active registration or a USDOT, MC, MX or FF number. The broader URS section, 49 CFR 390.201, was suspended indefinitely effective November 17, 2023.

New registration system. FMCSA is replacing the Unified Registration System with a new online system called Motus. The USDOT Number remains the identifier. The changes announced so far do not eliminate MC numbers or change safety registration rules, which would require separate rulemaking (91 FR 23144). Until the regulations change, the forms and deadlines in 49 CFR 390.19T continue to apply.

Keeping it current. The form is filed before operations begin and updated once in each 24-month cycle (49 CFR 390.19T(b)). The filing month follows the last digit of the USDOT Number: 1 is January through 9 in September, and 0 is October. The year follows the next-to-last digit: an odd digit files in odd-numbered years and an even digit in even-numbered years. A carrier that skips the biennial update faces penalties under 49 U.S.C. 521(b)(2)(B) or 14901(a) and deactivation of its USDOT Number (49 CFR 390.19T(b)(4)). False or misleading information on the form carries the same 521(b)(2)(B) penalties (49 CFR 390.19T(g)).

Marking the vehicle. Each self-propelled CMV subject to the rules displays the legal name or single trade name on the MCS-150 and the number preceded by "USDOT" (49 CFR 390.21T(b)). If another company's name appears on the vehicle, the operating carrier's name follows the words "operated by." The marking appears on both sides, contrasts sharply with the background and is readable in daylight from 50 feet while the vehicle is stationary (49 CFR 390.21T(c)).

Example. A carrier with USDOT Number ending in 47 files its update by the last day of July in even-numbered years. The DOT acronym FAQ covers the agency itself.