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Due to a federal rule change by NHTSA late last year, beginning January 1, 2021 odometer disclosures will be required for every sale or transfer for the first 20 years of a vehicle’s life, as opposed to the first 10 years as it is today. This change will only apply to Model Year 2011 and newer vehicles. 

Put another way, under current law, any vehicle more than 10 years old is exempt from reporting mileage upon sale or transfer. The new federal rule increases the exemption from 10 years to 20 years for vehicles with a 2011 or newer model year. So, beginning January 1, 2021, when a vehicle with a model year 2011 or newer is sold or transferred, the actual odometer mileage must be included on the odometer disclosure statement for 20 years before it becomes exempt.  

This does not change anything for vehicles that are currently exempt. Model Year 2010 and older vehicles will continue to be exempt from federal odometer disclosure requirements.  
The following chart can be used for reference:

Model Year 2010 and Older    Vehicles are exempt and will remain  
exempt from odometer disclosure:

Model Year 2011     Vehicles not exempt until 2031
Model Year 2012    Vehicles not exempt until 2032
Model Year 2013    Vehicles not exempt until 2033
Model Year 2014    Vehicles not exempt until 2034
Model Year 2015    Vehicles not exempt until 2035
Model Year 2016    Vehicles not exempt until 2036
Model Year 2017    Vehicles not exempt until 2037
Model Year 2018    Vehicles not exempt until 2038
Model Year 2019    Vehicles not exempt until 2039
Model Year 2020    Vehicles not exempt until 2040

NAAA has been informed that a handful of states may not be ready to implement this change on January 1. Titles from nonconforming states may be problematic if transferred without the proper odometer disclosure to a conforming state. Conforming state regulatory agencies will have to determine whether they will continue on with the inaccurate exempt odometer indicator on the title, conduct research and provide affidavits to show the actual mileage, or mark the vehicle Total Mileage Unknown (TMU) or Not Actual Mileage (NAM), possibly affecting the value of the vehicle. 

At this time, NAAA has only been made aware of one state – Texas – that has already made the decision to mark any incorrectly exempted title from a non-conforming state as “Not Actual Mileage”. This will only affect 2011 model year vehicles, as all states are expected to be in compliance within the next 6 to 12 months. 

U.S. Department of Transportation 
Office of Public Affairs 
1200 New Jersey Avenue SE 
Washington, D.C. 20590