Odometer disclosure for car dealers: which cars, what to write, what to keep

The federal odometer rules in plain English: which vehicles still need a mileage disclosure in 2026, what the statement must include, the three mileage certifications, and five years of records.

Federal law requires a written odometer disclosure when ownership of most vehicles changes hands. Your state's title forms usually build it in, but the rules behind them are federal, and dealers carry extra record-keeping duties.

Which vehicles need it

Model year 2011 and newer: a disclosure is needed until the vehicle is 20 years old (counted from January 1 of its model year). So in 2026, every 2011-or-newer vehicle needs one; the 2011 models drop out in 2031
Model year 2010 and older: exempt (the old 10-year rule)
Also exempt: vehicles over 16,000 pounds gross vehicle weight rating, vehicles that aren't self-propelled (like trailers), and a new vehicle before its first sale to someone who isn't buying to resell

What the statement must include

The odometer reading, without tenths of a mile, and the date of transfer
The seller's and the buyer's printed names and current addresses
The vehicle's make, model, year, body type and VIN
The federal warning that leaving out information or giving false information can lead to fines or imprisonment (in an electronic transaction, shown before anyone signs)

The three mileage certifications

The seller signs one of these:

Actual mileage: to the best of their knowledge, the reading is the vehicle's actual mileage
Exceeds mechanical limits: the mileage is more than the odometer can display (it has rolled over)
Not actual mileage: the reading is known to be wrong, should not be relied on, and there is a discrepancy (a warning)

Who signs

The seller signs and prints their name; the buyer then signs, prints their name and gets a copy. The same person can't sign as both seller and buyer in one transaction, except in the narrow power-of-attorney situations the rule allows.

Records dealers must keep

A copy of every odometer statement you issue and receive, for five years
Copies of any powers of attorney you hold for odometer purposes, also for five years
Kept at your main place of business, organised so they're easy to find; electronic copies must be in a format that can't be changed without showing it
On fully electronic titles, the state keeps the record, and your own copy is optional

Make it routine

Photograph the odometer when a car arrives and again at sale, keep the signed statement with each deal, and file both so you can pull any car's paperwork in a minute. If a reading ever looks wrong, use the "not actual mileage" certification rather than guessing.

Source: 49 CFR Part 580 (sections 580.5, 580.8 and 580.17). Updated October 2026.

General information in plain English, checked against the sources named when we wrote it. It isn't legal, tax or professional advice, and rules change: for your own business, check the official source or ask your accountant or attorney. See our website terms.