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MVA Releases New Bill-of-Sale Guidance Following MCAA Advocacy

Maryland No Notary Required Bill of Sale
Maryland No Notary Required Bill of Sale

The Maryland Motor Vehicle Administration published new implementation guidance on September 15, 2026, regarding the repeal of Maryland’s notarized bill-of-sale requirement.

The guidance is particularly important to the Maryland Collectible Auto Association because MCAA raised concerns about how this change could affect collector and specialty vehicles well before MVA published its implementation procedures.

MCAA Raised the Issue Early

After the legislation passed during the 2026 General Assembly session, MCAA pressed Delegate April Miller and Senator J.B. Jennings to seek clarification directly from MVA regarding how the agency intended to implement the new law.

MCAA specifically raised concerns about the potential impact on the collector-car hobby and the difficulty of relying on generalized vehicle market data to establish the value of collectible, specialty, modified, rare, and otherwise unusual vehicles.

Unlike ordinary late-model used vehicles, collectible vehicles can vary dramatically in value based on condition, provenance, originality, options, modifications, restoration quality, production numbers, and other factors that may not be adequately reflected in standardized valuation databases.

MVA subsequently responded to the legislators’ inquiries. While the agency did not expressly acknowledge all of the concerns raised by MCAA, its response reflected some of the practical difficulties involved in determining market value for vehicles that do not fit neatly into conventional valuation systems.

Now, the implementation guidance released by MVA provides an important clarification: when the system cannot return a NADA value for a vehicle, the transaction is referred for processing by an MVA agent rather than simply assigning a standardized market value.

For Maryland’s collector-car community, that is an important distinction.

MCAA believes the new guidance addresses a significant portion of the concern we raised with legislators about applying generalized market-value data to collectible vehicles. We will continue monitoring implementation after October 1 and encourage enthusiasts, dealers, tag-and-title agents, and MCAA members to contact us if they encounter problems involving the valuation of collectible or specialty vehicles.

What Changes October 1?

Effective October 1, 2026, Maryland will no longer require a notarized bill of sale for the private-party sale of a vehicle less than seven years old. The change was enacted through SB 125/HB 251, Vehicle Laws – Transfer of Used Vehicles – Repeal of Notarized Bill of Sale Requirement.

Under MVA’s new procedure:

  • If the reported purchase price is within $500 of the NADA value returned by MVA’s system, excise tax will be calculated using the reported purchase price.
  • If the reported purchase price is more than $500 below the NADA value, the customer may be taxed using the NADA value or provide documentation supporting the lower purchase price.
  • If the NADA value is disputed, the transaction must be submitted for processing by an MVA agent.
  • If NADA does not return a value for the vehicle, the transaction must also be submitted for processing by an MVA agent.

Why This Matters for Maryland Car Enthusiasts

For most collectible vehicles, which are already seven years old or older, the immediate impact of the change is limited.

However, the underlying valuation issue remains important to the hobby. Enthusiasts routinely purchase newer specialty, limited-production, modified, performance, exotic, and future-collectible vehicles whose actual market values may not correspond neatly with standardized valuation systems.

MCAA’s concern has been straightforward: a computerized market value should not automatically determine the taxable value of a vehicle when reliable standardized market data does not exist for that particular vehicle.

MVA’s September 15 guidance provides a process for those situations rather than treating every vehicle as though a reliable NADA valuation necessarily exists.

The change also eliminates an additional notarization step for qualifying private-party transactions while retaining MVA’s ability to review transactions in which the reported purchase price is substantially below the system-generated value.

An MCAA Legislative Priority Moves to Implementation

The bill-of-sale and vehicle-valuation issue has been one of MCAA’s four legislative priorities.

With MVA now issuing implementation guidance that addresses an important concern raised by MCAA, this priority is moving from seeking clarification and change to monitoring implementation.

As MCAA develops its 2027 legislative agenda, this priority will be updated accordingly. Our focus will be on ensuring that MVA’s procedures work as intended in real-world transactions and that collectible and specialty vehicles without reliable standardized market values are handled appropriately.

This is also an example of why organized advocacy for Maryland’s automotive enthusiast community matters. MCAA identified a potential problem, raised it with members of the General Assembly, asked those legislators to obtain answers from MVA, and continued following the issue through the release of implementation guidance.

Important Date: October 1, 2026

The new rules take effect October 1, 2026. HB 251 and SB 125 were approved by the Governor on April 14, 2026, as Chapters 118 and 119 respectively.

MCAA will continue monitoring implementation of this change along with Maryland legislation and MVA policies affecting historic vehicles, registration, emissions, excise taxes, fees, and the broader collector-car community.

If you encounter an issue with MVA assigning a market value to a collectible, specialty, modified, or unusual vehicle after these procedures take effect, please let MCAA know. Real-world experiences from Maryland enthusiasts will help us determine whether additional legislative or administrative action is needed.

MCAA will continue working with legislators, state agencies, and Maryland’s automotive community to make sure the voice of the collector-car hobby is heard in Annapolis.

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