"Exempt" in the odometer box of a title means the seller wasn't legally required to state the mileage when the car changed hands. Under federal rules, in 2026 that covers model year 2010 and older vehicles, anything with a gross vehicle weight rating over 16,000 pounds, and trailers and other vehicles that aren't self-propelled. It is not a brand that says the miles are wrong, and it isn't a sign they're right. It just means nobody signed for them, which is why rollback artists like these cars.
I checked the federal rule on eCFR and three state DMV pages on the morning of October 17, 2026. The short version: if the car is a 2011 or newer passenger vehicle, it shouldn't say exempt at all, so a title or bill of sale that claims otherwise deserves a hard look.
Who qualifies as exempt in 2026
The list lives in 49 CFR 580.17. A seller doesn't have to disclose mileage on a vehicle over 16,000 pounds GVWR, a vehicle that isn't self-propelled, a vehicle the manufacturer sold directly to a federal agency under contract, or a brand-new vehicle before its first retail sale. Then come the age rules, which are where most confusion starts. Model year 2010 and older vehicles became exempt 10 years after January 1 of their model year. Model year 2011 and newer vehicles have to reach 20 years, and the rule's own example says the 2011 models won't go exempt until transfers in calendar year 2031.
So the age-exempt group is frozen right now. Every 2010-and-older car is in it, and nothing newer joins until January 1, 2031. A 2011 Accord sold this month still needs a signed odometer statement, even though it's 15 years old. The disclosure rules themselves are in our odometer disclosure statement rules post.
Why the 10-year cutoff changed
NHTSA's October 2, 2019 final rule explains it. When the 10-year exemption was adopted in 1988, the average car on the road was 7.6 years old; by 2017 the average light vehicle was 11.7. NHTSA proposed 25 years and settled on 20. The rule also quotes a 2008 Justice Department request noting that a growing number of "exempt" titles increased opportunities for odometer fraud, while mileage records in CARFAX and similar services made those titles more valuable to fraudsters. In plain terms, exempt titles are where rollbacks hide.
The change got pushed back once. After the American Association of Motor Vehicle Administrators and Delaware asked for more time, a November 26, 2019 notice moved the 20-year rule to January 1, 2021 and applied it starting with model year 2011. That's why 2010 models slipped into exempt status on January 1, 2020 under the old rule.
How exempt shows up on titles and reports
States label it differently. The Texas DMV odometer brands page lists the national NMVTIS brand "Exempt from Odometer Disclosure," meaning the vehicle meets criteria to change owners without a mileage reading, and Texas prints it as "Exempt." The Wisconsin DMV FAQ defines exempt status as age (model year 2010 or older), type (such as a trailer) or weight (over 16,000 pounds), and adds that once a record says EXEMPT, the status can't be changed. That stuck with me: a car can carry the word for life.
States can also be stricter than the federal floor. The Virginia DMV odometer page says the only vehicles exempt in Virginia are non-passenger vehicles over 16,000 pounds GVWR. Virginia does honor another state's exemption, coded "Exempt (Prior State)," but marks it on the new title. So a 2008 pickup bought in Virginia may show a mileage figure while the same truck titled elsewhere says exempt.
On a history report, exempt status doesn't stop mileage from being recorded. Service visits, inspections, auctions and registrations can still log odometer readings, and those are what you compare. A multi-year gap with no readings on a 2009 car proves nothing; a reading that goes down is a red flag. Our CARFAX odometer discrepancy guide walks through what those flags mean.
Exempt is not "not actual"
"Not Actual Mileage" is a brand saying the reading is known to be wrong, and Wisconsin says once a record is NOT ACTUAL it can't be changed back and may lower the car's value. "Exempt" says no one was required to vouch for the reading. If you're weighing a car with either word, read our not actual mileage brand explainer next to this one. Neither label tells you what the true mileage is.
What to check on an exempt car
The fraud problem isn't small. CARFAX said in a December 16, 2025 release that about 2.45 million cars on the road were suspected of rollbacks, up 14% in a year, with an average value hit of around $3,300. A CARFAX data VP pointed to cheap tools for altering digital odometers. On an old exempt car, assume the seller can type any number they want.
So decode the VIN and confirm the model year matches the title. If a 2011 or newer passenger car shows exempt, ask why and call the DMV. Compare the odometer to oil-change stickers, inspection records and the last reading on a history report. Check pedal and seat wear, and the tips in how to detect odometer rollback.
CarVins sells CARFAX and AutoCheck reports as a licensed reseller; we're not affiliated with CARFAX, AutoCheck or Experian. In mid October 2026 one report was about $5.50 as a guest or $4.50 with membership, and both together near $6.75, compared with $39.99 to $44.99 retail. Checkout shows today's price. On an exempt car, the mileage history is most of what you're buying.
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