FMCSA Audit Readiness Checklist

One file per driver. Auditors pull these first.

• Signed employment application with 10-year employment + 3-year driving history

  49 CFR 391.21

• Motor Vehicle Record (MVR) from each licensing state at hire

  49 CFR 391.23

• Annual MVR + annual review of driving record (signed, dated)

  49 CFR 391.25One per driver per 12 months; auditors check the dates.

• Road test certificate or accepted CDL in lieu of road test

  49 CFR 391.31 / 391.33

• Current Medical Examiner’s Certificate (and MVR showing med-cert status)

  49 CFR 391.45Expired med cards are the #1 DQF finding, so track the expiration.

• Pre-employment Clearinghouse query + annual Clearinghouse query (with driver consent)

  49 CFR 382.701

• Safety Performance History investigation: prior employers, last 3 years

  49 CFR 391.23(d)

Auditors request a sample of records and must be able to reconstruct each driver’s duty status.

• ELD in use and registered on the FMCSA list (or a valid exception documented)

  49 CFR 395.8

• Records of Duty Status (RODS) retained 6 months + supporting documents

  49 CFR 395.8(k)Supporting docs: BOLs, fuel/toll receipts, dispatch records.

• ELD malfunction + data-transfer records; driver ELD instruction packet in cab

  49 CFR 395.22 / 395.34

• Any HOS exemptions (short-haul 150 air-mile, etc.) documented and applied correctly

  49 CFR 395.1

A program that exists on paper but can’t produce records is treated as no program.

• Written D&A policy distributed to all drivers (signed receipt)

  49 CFR 382.601

• Pre-employment controlled-substances test (negative) before first dispatch

  49 CFR 382.301

• Random testing pool enrollment at current annual rates; selection records

  49 CFR 382.305Confirm the consortium/TPA selection logs are retrievable.

• Supervisor reasonable-suspicion training: 60 min drugs + 60 min alcohol

  49 CFR 382.603

• Post-accident testing records where required

  49 CFR 382.303

• Clearinghouse registration + queries; annual MIS data prepared

  49 CFR 382.705 / 382.401

Maintenance files are pulled per VIN, so keep them retrievable by unit.

• Annual (periodic) inspection on file for every CMV

  49 CFR 396.17Retain the most recent report for 14 months.

• Driver Vehicle Inspection Reports (DVIRs) with repairs certified

  49 CFR 396.11

• Maintenance + repair records by unit, retained per the rule

  49 CFR 396.3Keep while in control + 6 months after.

• Roadside inspection reports retained and repairs documented (15-day return)

  49 CFR 396.9

The carrier-level paperwork that proves you’re legal to operate.

• MCS-150 updated within the last 24 months (biennial update)

  49 CFR 390.19

• Operating authority (MC number) active for for-hire interstate operations

  49 CFR 365

• Financial responsibility / insurance on file at required limits (BMC-91/91X)

  49 CFR 387

• Accident register maintained for 3 years

  49 CFR 390.15Even "0 accidents" should be a documented register.

• USDOT number displayed on both sides of each CMV

  49 CFR 390.21

• UCR registration current for the year

  49 CFR 367