Avoid These 5 Common FMCSA Recordkeeping Violations
April 15, 2025
Maintaining accurate and up-to-date records isn’t just the best practice for motor carriers — it’s a critical component of staying compliant with the Federal Motor Carrier Safety Regulations (FMCSRs). During audits, the Federal Motor Carrier Safety Administration (FMCSA) frequently uncovers the same recordkeeping issues across fleets, many of which are preventable.
Even the most experienced safety professionals can overlook a requirement here and there. That’s why being proactive is key. Below are five of the most common FMCSA recordkeeping violations and how your company can avoid them.
1. Using the Wrong Logging Method (49 CFR 395.8(a)(1))
One of the most frequently cited violations involves driver logbooks. With few exceptions, commercial motor vehicle drivers are required to use an FMCSA-compliant electronic logging device (ELD) to track hours of service (HOS). Paper logs are only permitted in certain exempted situations, such as short-haul operations or during ELD malfunctions of up to 8 days where the ELD cannot accurately record hours-of-service.
To stay compliant, ensure that your drivers know when and how to use ELDs — and double-check that your devices meet FMCSA technical specifications.
2. Failing to Track Maintenance Due Dates (49 CFR 396.3(b)(2))
Another common misstep is failing to document vehicle maintenance schedules. The FMCSRs require fleets to have a systematic inspection and maintenance program in place. This includes maintaining records that clearly indicate what type of maintenance is needed and when it’s due.
Missing this step could result in overdue service, which not only risks an audit violation or a roadside inspection citation but also endangers driver safety and increases liability exposure.
3. Missing Vehicle Identification Details (49 CFR 396.3(b))
Carriers are also required to maintain detailed records for every vehicle operated under their control for 30 consecutive days or more. These records must include identification data like make, model, and VIN, and should be retained for at least 12 months after the vehicle leaves the fleet. Documentation is also required for:
- The scheduled and actual completion dates of inspections and maintenance, and
- For buses, a record of tests conducted on pushout windows, emergency doors and the marking lights for these doors.
When this information is incomplete or missing altogether, it signals a breakdown in fleet oversight and triggers auditor scrutiny.
4. Failing to Keep the Initial MVR on File (49 CFR 391.51(b)(2))
You may be keeping the last three years of annual motor vehicle records (MVRs) on file — but don’t forget the one from the driver’s date of hire. FMCSA requires carriers to retain the initial MVR for the duration of employment and for three years after the driver leaves the company.
Not having this document on hand is a surprisingly common — and easily avoidable — violation.
5. Incomplete or Missing DOT Employment Applications (49 CFR 391.21(a))
The driver employment application isn’t just another form — it’s a federally required document that must include specific information, such as driving history, previous employers, social security number, birthdate, and safety performance. Each section must be completed fully by the applicant. Skipping fields or using a non-compliant form not containing all elements from 391.21(b) can lead to fines and failed audits.
Stay Ahead with a Self-Audit
The best way to avoid these violations is to conduct a thorough self-audit of your driver qualification files, maintenance logs, and hours-of-service records. Identifying and correcting these issues before an audit can save your company time, money, and stress.
Don’t wait for a compliance review to find out where you stand — take action now to ensure your recordkeeping practices are audit-ready.