Every car you retail that's model year 2011 or newer needs a mileage disclosure, signed by you and acknowledged by the buyer. Most of the time it goes on the title. This guide covers what the statement has to say, which cars are exempt this year, when the title isn't enough, what you have to keep, and the separate form each state uses.
Under 49 CFR 580.5, the disclosure has the same parts whether it's printed on the title, on a state form, or on your own statement. If yours is missing one, it isn't a compliant disclosure:
On a retail sale your dealership is the seller (the “transferor”) and the customer is the buyer. On a trade-in it flips: the customer discloses to you, and you keep their statement.
The old rule exempted anything 10 years old. That changed: under 49 CFR 580.17, model year 2010 and older vehicles are exempt, but model year 2011 and newer stay covered until they're 20 years old. So a 2012 trade you'd have skipped a few years ago now needs a disclosure. Some state forms and websites still print the old 10-year language; go by the federal rule.
| Sale made in | Disclosure required | Exempt by age |
|---|---|---|
| 2026 | Model year 2011 and newer | Model year 2010 and older |
| 2030 | Model year 2011 and newer | Model year 2010 and older |
| 2031 | Model year 2012 and newer | Model year 2011 and older |
| 2032 | Model year 2013 and newer | Model year 2012 and older |
The rule also exempts vehicles with a gross vehicle weight rating over 16,000 pounds, vehicles that aren't self-propelled (trailers), vehicles a manufacturer sells straight to a federal agency, and a new vehicle's transfers before its first sale to an end buyer, which is why you don't get one from the manufacturer on a new unit.
On the title. When the car has a paper title with an odometer section, that's where the disclosure goes. When you buy a car, the seller fills in the assignment and you sign as the buyer. When you sell it, you use the dealer reassignment section.
On a separate form. A vehicle that has never been titled gets its disclosure on a separate document. Some states also publish their own statement for titles that don't carry a conforming odometer section, or ask for one with the title application. Federal rules let you use a separate reassignment document only after the titled owner has made the disclosure on the title and assigned it, and never with an electronic title.
By secure power of attorney. When a lender holds the title, the title is lost, or an electronic title can't be reached, the seller can appoint the buyer to make the disclosure for them (49 CFR 580.13). The form has to be issued by the state and printed by a secure process, so a generic POA you typed up doesn't qualify. This is the one that comes up on trades with a payoff.
Electronic titles. In states with electronic titles, the disclosure is made electronically and becomes part of the electronic title record.
DealerVLO fills the federal odometer disclosure from the deal: the car, the buyer, your dealership, the reading, and its status. $29/month, free to try — cancel any time.
These states publish their own separate odometer statement. Each form number and name below is taken from the agency's current PDF. A state that isn't listed either relies on the title's odometer section or we haven't verified its form yet, so check with your state agency.
| State | Form | Name on the form | Official PDF | Walkthrough |
|---|---|---|---|---|
| Alaska | V6 | Odometer Disclosure Statement | — | |
| Arkansas | 10-313 | Vehicle Bill of Sale / Odometer Disclosure Statement Bill of sale and odometer disclosure on one form | — | |
| Florida | HSMV 82993 | Separate Odometer Disclosure Statement and Acknowledgment | Box by box | |
| Indiana | State Form 43230 | Odometer Disclosure Statement | — | |
| Kentucky | TC 96-5 | Odometer Disclosure Statement Attach to the title and registration application | — | |
| Louisiana | DPSMV 1606 | Odometer Disclosure Statement | — | |
| Maryland | VR-197 | Odometer Disclosure Statement | — | |
| Michigan | BDVR-108 | Odometer Mileage Statement | Box by box | |
| Missouri | Form 3019 | Odometer Disclosure Statement | — | |
| Montana | MV90A | Odometer Disclosure Statement | — | |
| Nebraska | (unnumbered) | Odometer Disclosure Statement Only for the special cases the form lists, such as court-ordered titles | — | |
| New Hampshire | TDMV 12 | Odometer Disclosure Statement | — | |
| New Jersey | OS/SS-2 | Odometer Disclosure Statement | — | |
| New Mexico | MVD-10187 | Odometer Disclosure Statement | — | |
| New York | MV-103 | Odometer and Damage Disclosure Statement Covers damage disclosure too | Box by box | |
| North Carolina | MVR-180 | Odometer Disclosure Statement | Box by box | |
| Ohio | BMV 3724 | Odometer Disclosure Statement | — | |
| Oklahoma | Form 729 | Odometer Disclosure Statement | — | |
| Tennessee | RV-F1317001 | Odometer Disclosure Statement | Box by box | |
| Utah | TC-891 | Odometer Disclosure Statement | — | |
| Vermont | VT-005 | Bill of Sale and Odometer Disclosure Statement Bill of sale and odometer disclosure on one form | — | |
| Virginia | VSA 5 | Odometer Disclosure Statement The form says not to use it when a title exists | — |
These are the state-issued forms that let a buyer, usually the dealer, disclose the mileage for the seller when the title can't be signed.
| State | Form | Name on the form | Official PDF | Walkthrough |
|---|---|---|---|---|
| Florida | HSMV 82995 | Motor Vehicle Power of Attorney / Odometer Disclosure | — | |
| Kansas | TR-40 | Power of Attorney, Purchase Price & Odometer Disclosure for Electronic Title | — | |
| Missouri | Form 5086 | Secure Power of Attorney | — | |
| New Jersey | DLR-SPOA | Dealer Secure Power of Attorney / Odometer Disclosure Only when the title is held by a lienholder or lost | — |
Checked against each agency's PDF in October 2026. States revise forms, so confirm you have the current revision before you file.
49 CFR 580.8 is the part private sellers never deal with. A dealer has to keep, for five years, a copy of every odometer disclosure it issues and every one it receives. That means the statements on your retail sales and the ones customers give you on trades. You also keep every power of attorney you receive for five years. Copies live at your primary place of business, and an electronic copy counts.
The exception is an electronic title: the state keeps that record for at least five years, and you don't have to.
In practice, the record lives in the deal jacket. In DealerVLO, the generated odometer statement and every other document for the sale stay on the deal, so pulling a four-year-old disclosure for an audit is a search, not a trip to the storage unit.
It doesn't sign anything for you, and it doesn't decide the odometer status. You set that on the deal from what you know about the car.
One deal record fills the odometer statement, the bill of sale, the Buyers Guide, and your state's title application. $29/month, free to try — cancel any time.
It's the seller's written statement of a vehicle's mileage at the time ownership changes hands, required by the federal Truth in Mileage Act and 49 CFR Part 580. It gives the odometer reading (no tenths), the date, both parties' names and addresses, and the vehicle's year, make, model, body type, and VIN. The seller certifies whether the reading is the actual mileage, exceeds the odometer's mechanical limits, or is not the actual mileage, and the buyer signs to acknowledge it. On most sales it's made in the odometer section of the title itself.
If you're transferring a vehicle of model year 2011 or newer, yes, until it's 20 years old. Model year 2010 and older vehicles are exempt. So are vehicles over 16,000 pounds GVWR, vehicles that aren't self-propelled, and a new vehicle moving to a dealer before its first retail sale. Whether you need a separate form, rather than the title's own odometer section, depends on the state and on whether the title can carry the disclosure.
Usually, yes. Federal rules put the disclosure on the title when the vehicle has one. A separate form comes in when the vehicle has never been titled, when the state's title doesn't have a conforming odometer section, when the title is held by a lender or lost (that's a secure power of attorney, not a plain statement), or when the state asks for its own form anyway. A separate statement in the deal jacket is still a useful signed record of what you disclosed.
From your state's motor vehicle agency. The table on this page links the official PDF for every state we've verified. In states without a separate form, the disclosure goes in the title assignment. DealerVLO also generates a federal odometer disclosure statement from each deal, filled with the car, the buyer, and the reading.
Five years. 49 CFR 580.8 requires dealers to keep a copy of every odometer disclosure they issue and every one they receive, at their primary place of business, for five years. The same five years applies to powers of attorney a dealer receives. Electronic copies count. For electronic titles, the state keeps the record and the dealer doesn't have to.
Only if it carries every element the federal rule requires: the reading, the date, both parties' names and addresses, the full vehicle description and VIN, the seller's certification and printed name, the federal-law warning, and the buyer's signature. A few states, like Arkansas and Vermont, publish a combined bill of sale and odometer disclosure form. A plain bill of sale with a mileage line isn't a disclosure statement.
Under 49 U.S.C. 32710, a person who violates the federal odometer rules with intent to defraud is liable for three times the actual damages or $10,000, whichever is greater, and the buyer has two years to sue. State law can add its own penalties. Fix a mistake by starting a clean form. Some state forms, like North Carolina's MVR-180, say alterations or erasures void them.
No. A secure power of attorney is a state-issued form, printed by a secure process, that lets the buyer (often the dealer) disclose the mileage on the seller's behalf. Federal rules allow it only when a lender holds the title, the title is lost, or an electronic title can't be accessed. Florida's HSMV 82995 and New Jersey's DLR-SPOA are examples.
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