Odometers Guidelines
The Truth in Mileage Act is a Federal Law requires all states to obtain and record a vehicle’s odometer reading (Federal Odometer Disclosure Statement) at the time of processing a transfer of ownership with a Certificate of Title or Title Transfer (Bill of Sale), form #38-1306.

The Truth in Mileage Act requires the specific language (listed below) be printed on a title to be considered 'conforming' and secure. Arizona titles have the specific language, so they are considered conforming. The language will state:
'I certify to the best of my knowledge that the odometer reading is the actual mileage of the vehicle unless one of the following statements is checked.'. See arrow below.
- Mileage In Excess Of The Odometer Mechanical Limits
- Indicates the odometer has exceed the maximum reading the vehicle is capable of recording and has 'rolled over' or started over at zero
- NOT Actual Miles, WARNING – ODOMETER DISCREPANCY
- Indicates there is a discrepancy or the odometer has been tampered with, broken, or replaced
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When neither box is checked, this indicates 'Actual' mileage. |
All MCOs and Arizona Titles (1987 to current) are conforming, therefore a separate Federal Odometer Disclosure Statement is not required when processing an MCO or Arizona title, unless:
- An error was made when the customer wrote the wrong odometer reading or reading type in the odometer section
- The out-of-state title being submitted does not have this language

The odometer code, along with the odometer reading, based on the information declared on the odometer disclosure will need to be enetered or recorded on documentation. The odometer code indicates if the odometer reading is accurate, inaccurate, and/or broken or exceeds mechanical limits.
Reading Type |
Definition |
DRT Data Entry |
Actual |
When the vehicle's odometer displays the actual mileage that has been driven |
A |
Mileage in excess of the odometer mechanical limits |
This happens on older vehicles when the odometer only displays up to 99,999, then goes back 000000 Many newer vehicles have odometers that display 999,999 |
B |
Not Actual Mileage - 'WARNING - ODOMETER DISCREPANCY)*
*Requires documentation to be submitted |
Indicating the odometer has been changed, broken, etc. |
C |
Unknown, if applicable |
Used when an Arizona title and the odometer reading will not change on the record and will stay the same as the front of the title Used when there is no odometer reading on the vehicle (e.g., ATV, golf carts) |
X, if applicable |
Exempt, if applicable |
Used when an out-of-state title displays 'exempt' odometer disclosure |
Exempt, if applicable |
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If the kilometer box is checked on a title for the odometer reading, or if the verbal odometer reading is given in kilometers, no conversion will be completed. Enter the odometer reading and label the odometer code as 'kilometers' during data entry. |

A vehicle's model year will determine the type of paperwork required to record an odometer reading.
Non-Exempt (Required)
- The odometer statement on the back of the title or MCO
- On some out-of-state titles, the 'Transfer of Ownership' will be on the front of the title
- A Secure Odometer Disclosure form #96-0165 (from a dealer) or Odometer Disclosure (Electronic), form #96-0695
- A dealership is able to capture an electronic signature on a Odometer Disclosure (Electronic), form #96-0695, a fillable PDF, electronic version of the Secure Odometer Disclosure
- This form may be printed, but not used to capture a hand-written signature
- Separate Federal Odometer Disclosure Statement
- Power of Attorney with Odometer Disclosure, form #48-7104
- Dealer Reassignment Transfer (DRT), form #38-1304; the form is only available to eligible dealers
- Arizona Dealer Retail Bill of Sale, form #38-1305
Exempt (Not Required)
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If the vehicle is exempt from the Federal Odometer Disclosure Statement, the documentation may be provided, but is not required. View the Vehicles Exempt from Odometer Disclosure Statement section for more information. |
- Any of the documentation listed above, OR
- The odometer statement on the back of the title or MCO
- T&R Application (Single), form #96-0236
- Level I, II, or III Inspection
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The odometer reading on the inspection or T&R Application (Single) may be used when the odometer reading is not written on the title and a separate Federal Odometer Disclosure Statement is not submitted. |

Vehicles, depending on their model year, must comply with the Federal Odometer Disclosure Statement which indicates the buyer and the seller must print and sign their name on the title, MCO, Odometer Disclosure Statement, or other approved documentation.
Along with the buyer and seller printed and signed names, the buyer's full address is required on the signed title, signed Title Summary, or signed T&R Application, form #96-0236.
This confirms the seller has written the correct odometer reading and marked the appropriate reading type on the required documentation.
Model Years & Odometer Disclosures
2010 model year vehicles and older are required to have an Odometer Disclosure for 10 years.*
2011 model year vehicles and newer are required to have an Odometer Disclosure for 20 years.**
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*A 2009 vehicle will require a 10 year disclosure requirement (until 2019). **A 2018 vehicle will require a 20 year disclosure requirement (until 2038). |
Once the vehicle has passed the required 10 or 20 year time frame, the disclosure is no longer required.
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The Federal Odometer Disclosure Statement for a brand new vehicle coming from a manufacturer to a dealer is not required, until the vehicle is sold to a retail buyer. |
When a non-conforming title is submitted and the customer has requested to keep the reading type as 'ACTUAL', a separate Federal Odometer Disclosure Statement will be required at that time.
When an error is made on the Federal Odometer Disclosure (on the back of the MCO or title), a Power of Attorney with Odometer Disclosure, form #48-7104 will need to be completed by the seller.

An owner of an exempt vehicle is not required to submit an Federal Odometer Disclosure Statement, but may do so if they wish. Exempt vehicles include:
- A motor vehicle that is 2010 model year or older is exempt when the motor vehicle is 10 model years of age or older
- Out-of-state titles showing an EXEMPT odometer disclosure will be kept as EXEMPT in MVD's system (leaving odometer reading and unit blank on title)
- A motor vehicle that is a 2011 model year or newer is exempt when the motor vehicle is 20 model years of age or older
- A vehicle that has a gross vehicle weight rating of 16,000 lbs. or more
- A vehicle that is not self-propelled
- A new motor vehicle that is purchased for resale and not for use by the purchaser
- A vehicle sold directly by the manufacturer to an agency of the United States in conformity with contractual specifications

The same person cannot represent the seller and buyer for the odometer statement transaction when signing for the Federal Odometer Disclosure Statement.
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Exception: An individual that operates a business as Sole Proprietor and has a vehicle titled in the operating name of the business can provide proof of Sole Proprietorship to sign off as seller and buyer for the odometer disclosure. |
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Any person who is completing a Non-Probate Affidavit, form #32-6901 will have to complete and sign the odometer statement on the Non-Probate form. |
No person will sign a title odometer statement as both the transferor and transferee in the same title transactions.
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Henry owns the company Limited One and has all of the vehicles in the company name. Henry wants to transfer one of the newer vehicles (2017 Kia) from the company name into his own personal name. On the ‘Seller Name (printed)’ and ‘Seller Signature’ section of the back of the title someone else from the company needs to sign on behalf of the company in order to relinquish ownership in the vehicle to Henry and to sign for the odometer statement. In the ‘Buyer Name (printed)’ and the ‘Buyer Signature’ section for the odometer certification Henry will fill out his name and sign for the odometer statement. Now two different people are signing for the odometer disclosure statement, not just one person. |
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Janet’s company, TyeDyed, has a surplus of vehicles so Janet decided to take title into her name for one of the vehicles (2019 Ford). In the ‘Buyer Name (printed)’ and the ‘Buyer Signature’ section for the odometer certification Janet will fill out her name and sign for the odometer statement. On the ‘Seller Name (printed)’ and ‘Seller Signature’ section on the back of the title, someone else from the company needs to sign on behalf of the company in order to relinquish ownership in the vehicle to Janet and to sign for the odometer statement. Again, now two different people are signing for the odometer disclosure statement, not just one person. |

When a customer decides to sell his vehicle and realizes there is a discrepancy between the odometer reading on title (generally a higher amount) and what is displaying on the vehicle (a lesser amount); a notarized statement (not a Division form) from the seller to the buyer with the buyer also signing that they are aware of the discrepancy. The statement must indicate the odometer reading and/or reading type was entered incorrectly when the seller originally titled the vehicle in his name.
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This statement is not needed for regular use of the vehicle, meaning that the odometer reading increases each mile the vehicle is driven, giving a higher mileage on the odometer reading then on the title. |
When the odometer reading is altered or has been reset to reflect fewer miles than what the vehicle has been driven, a notarized statement (not a Division form) from the buyer and the seller must accompany the supporting documents.
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The exception to this is when a discrepancy is the result of a CSR error and it is resolved by researching archived documents (OnBase, film records, or MAX), which can be used to verify the correct odometer reading and reading type. |
When the customer makes a mistake writing the odometer reading on a title or MCO during a sale, corrections cannot be made on the same document. Depending on the age of the vehicle a Power of Attorney with Odometer Disclosure, form #48-7104 may be required for data entry. The age of the vehicle, will determine if the disclosure must be signed by both the buyer and the seller.