What documents do I need for a safety audit?

Chapter 01

What will the auditor ask me for?

The auditor requests records in five areas: driver qualification, drivers’ hours, vehicle maintenance, accidents, and drug and alcohol testing (the audit rule). The rules that score the audit also cover insurance (how the audit is scored). The auditor checks a sample of each, not every page. Many people call this list the DOT safety audit requirements. Here is what each area includes and how to gather the documents.

Here is how that looks in real life. Say you run three trucks and three trailers. You hauled your first load on February 2, 2026. You drive one truck yourself, and two hired drivers run the others. One of them quit in May, and a new driver started in June. In April, you traded one truck for a newer one. Now it is September. The audit comes once a new company has enough records to judge. That is generally after at least 3 months of hauling (the new entrant rule). Yours could come any week now. What should you gather first? The whole audit, from start to finish, is in our main guide to the new entrant safety audit. This page focuses on the documents.

Start with your company documents. Proof of insurance must be kept at your main office (the insurance rule). That proof is usually the MCS-90 form your insurer issues. For general freight in trucks of 10,001 pounds or more, the minimum is $750,000 (the minimum amounts). Check that the policy names your company and provided coverage on every day you operated.

Smaller vehicles have a separate insurance category. For carriers hauling nonhazardous property for hire, a fleet made up only of vehicles below 10,001 pounds GVWR has a $300,000 minimum. GVWR means the manufacturer’s rated loaded weight, not what the vehicle weighs empty (the insurance rule for small vehicles, FMCSA’s filing table). Do not apply that lower amount to your fleet of heavy trucks. An insurance filing requirement also does not decide whether you need a safety audit.

Keep your BOC-3 with the company papers where your operating authority requires it. This form names the agents who can receive court papers for your company. It supports your authority to operate; it is not proof that you passed the safety audit. Keep a current copy at your main office (the rule on naming process agents).

Next comes the drug and alcohol program. These rules cover drivers who need a CDL. The program must start the day you begin hauling (the rule on when testing must start). The auditor looks for a written testing policy, with each driver’s signed receipt for it (the policy rule). The auditor looks for a negative drug test for each driver, received before that driver’s first trip (the pre-employment rule). A limited exception applies to some drivers recently covered by another company’s testing program. You need records showing that the exception applies. And the auditor looks for proof that every driver is in a random testing pool. A small carrier can do this through a consortium. That is a testing service that puts drivers from many companies in one shared pool.

Keep proof of your Clearinghouse checks too. Clearinghouse is FMCSA’s database of drug and alcohol violations. You need one before a driver starts, and another at least once a year (the Clearinghouse rule). Your own testing records belong here too. If you drive, these rules treat you as both the company and a driver (who the testing rules cover). So your name belongs in the random pool too. An owner who is the company’s only driver must be in a pool of two or more, so he has to join a shared pool.

You also supervise the hired drivers in this example, so keep proof of your supervisor training. It must include at least 60 minutes on alcohol misuse and another 60 on controlled substances. The training helps you decide when signs of use justify a test (the supervisor training rule). An owner-operator employing only himself as a driver is exempt from this training, FMCSA explains. That is not your case while you supervise hired CDL drivers. Keep training records while the person performs that role and for two years afterward (the records rule).

Then comes a file on each driver, called a driver qualification file (the driver file rule). Keep the job application and road test certificate, or the CDL copy accepted in place of that certificate. Include proof of medical qualification. For a CDL driver, use the State driving record showing medical status; for other drivers, keep the medical certificate. Add driving records from every State where the driver held a license in the past 3 years. You must ask for those within 30 days of hiring (the hiring checks rule). Keep replies from trucking employers over the past 3 years in a separate file. Those replies are also due within 30 days of hiring. And each year the file gets a new driving record, with a note on who reviewed it and when (the yearly review rule). Keep a file on yourself too. When the carrier is also a driver, the rules say the driver rules bind it as well (the rule on the carrier’s duty).

Next, gather the logs, called records of duty status in the rules. If your trucks have an ELD, an electronic logging device, the logs live there. Gather the supporting documents used to verify those logs. These are bills of lading, dispatch records, fuel and other expense receipts, messages from your fleet system, and pay records (the supporting documents rule). The auditor uses them to check that the logs are true. You also need a backup copy of the ELD records on a separate device (the ELD rule).

Next, gather maintenance records for every truck and trailer. Each record identifies the vehicle, shows what service is due and when, and lists each inspection and repair with its date (the maintenance rule). Each truck and each trailer needs an annual inspection report from the past 12 months (the annual inspection rule). And when a driver reports a defect, you need that driver vehicle inspection report, or DVIR. It must carry your note that the defect was fixed, or did not need fixing (the DVIR rule).

Finally, prepare the accident register, a list of crashes that meet the reporting definition below. For each one, it shows the date, the city and State, the driver, the injuries and deaths, and whether hazardous materials spilled. Copies of any accident reports go with it (the accident register rule). A crash belongs in this register if someone died or received medical treatment away from the scene. It also qualifies if disabling damage required a tow (the federal definition). A scrape with no injury and no tow does not count.

The auditor also uses information from outside your files. The audit also weighs your roadside inspections from the last 12 months, and your accident rate over the same year (how the audit is scored). The rate is measured per million miles, so have your mileage records ready. If an inspection on your record is not yours, get it fixed first with a DataQs request.

Some violations revealed by these records cause an automatic failure. Having no random testing program fails it outright. So does running without the required insurance (the failure rule). All 16 of those items are on our page about what automatically fails a new entrant safety audit.

Chapter 02

How far back do I need records, and whose should I keep?

Keep records for every driver who worked for you and every truck and trailer you operated. Each type has its own retention period. For a company under 18 months old, many periods exceed the company’s age. That often means keeping records from your first load onward. The table below shows the periods and exceptions. Keep logs and supporting documents for 6 months (the logs rule). Keep DVIRs for 3 months (the DVIR rule).

Count your people first. You run three trucks, but you need four driver files. There is yours, one for each of your two current drivers, and one for the driver who quit in May. His file stays for 3 years after he left (the driver file rule). Then count the vehicles. The truck you traded in April is gone. But its maintenance records must stay for 6 months after it left you, so until October (the maintenance rule). Each of your three trailers needs its own annual inspection, just like the trucks. The rule counts each vehicle in a combination on its own (the annual inspection rule).

The table shows how long to keep each type of record. Each period links to its rule.

Two notes on that list. First, “everything since your first load” is not a rule of its own. It is what the rules add up to for a company your age. Second, copies are fine instead of originals. Electronic records count too, as long as they are clear and complete (the copies rule, the electronic records rule).

Where you keep the records matters too. They belong at your principal place of business, which means your main office. If FMCSA asks, you must produce them there within 48 hours, not counting weekends and federal holidays (the federal definition). For drug and alcohol records, the limit is two business days (the testing records rule). Records left in a truck may not be available when you need them.

Chapter 03

How do I organize my records and find gaps?

Give every document a clear place in your filing system. Make one folder per driver and one per truck and trailer. Keep drug and alcohol records in a secure location. Use a company folder for insurance, the testing policy and the accident register. Compare dates across the records to find missing documents and inconsistencies. Correct genuine errors, but never fabricate or backdate a record to hide a violation (the rule against false records).

Here is how that goes for you. One Saturday, you build the folders. There are four driver folders, three truck folders, three trailer folders, and one for the truck you traded. Store drug and alcohol records separately with access restricted. The rule is plain: those records must be kept in a secure place with controlled access (the testing records rule). A protected folder on your computer works too, if access is restricted. Name each file by driver or unit, then by date. That makes each document easy to find.

Then you run the check. Do it in this order:

1. List every driver who drove for you since your first load. Note the day each one started, and the day each one left. Do the same for every truck and trailer.
2. For each driver, check four documents: the application, the road test or CDL copy, the Clearinghouse check and the negative drug test. All four must be dated before the first trip. The driving records and the replies from past employers must be in the file within 30 days of the start.
3. Check that each driver’s medical qualification was current on every day they drove. A certificate lasts 24 months at most (the medical exam rule).
4. For each truck and trailer, check that the annual inspection is less than 12 months old, and that every repair record shows the right VIN.
5. Lay a week of logs next to that week’s fuel receipts and bills of lading. The times and places should agree.
6. Check that every driver, you included, is on the random pool list, and that the insurance provided coverage on every day you operated.

Here is what the check turns up in your files. Your June driver’s drug test came back negative on June 10, but his log shows him driving on June 9. The rule says no driver may drive until a negative result is in (the pre-employment rule). Your trailers came with inspection decals but no reports. When someone else did the last annual inspection, getting a copy of the report is still your job (the inspection records rule). A tire invoice shows a VIN that matches none of your trucks, because the shop typed one digit wrong. And a fuel receipt from July 18 says 3:40 in the afternoon in Amarillo, Texas. That driver’s log has him off duty in Oklahoma City at that hour.

Each problem needs a different response. The VIN typo is easy: ask the shop for a corrected invoice. For the trailers, ask the seller or the shop for the reports, or have the trailers inspected now. The drug test and the log are different. Those events have already happened. Rewriting a document cannot undo them. Do not change the date on the test. Do not falsify the old log to hide the conflict with the receipt. The rule bans any false entry on a record you must keep (the rule against false records). A false record creates a separate, more serious problem.

So write down what happened and what you changed. For the drug test, the change is an office rule: no driver gets a load until the negative result is in your hands. For the log, talk to the driver, and check logs against receipts every week from now on. Neither violation in this example is one of the 16 automatic failures. But the auditor can still cite each one. Enough problems in three of the audit’s scoring areas can fail it too (how the audit is scored). When the review is done, the auditor goes over the findings with you (the audit completion rule).

Chapter 04

What records must I keep up after the audit?

Safety audit preparation does not end when the audit does. The auditor reviews existing documents, but your duty to keep records continues. Each new driver needs a file started, and a negative drug test, before the first trip. Each year, every driver needs a new driving record, a review and a Clearinghouse check. Each truck and trailer needs a new annual inspection within 12 months of the last one (the annual inspection rule). Continue keeping logs, receipts and any required DVIRs as you work. Those records will be part of the next review.

Say your audit goes well. You still stay under close watch for the rest of your first 18 months (the audit completion rule). After that, FMCSA judges you on the same basis as any other carrier (the end of the new entrant period). Keep using the folders you created and add new records as they come in.

Put every renewal and review deadline on one calendar. In your case, the yearly driving records for your first drivers come due by February 2027, 12 months after they started (the yearly review rule). Each medical certificate has its own end date, printed on it. The yearly Clearinghouse check is due at least once a year for each driver (the Clearinghouse rule). Each trailer’s next inspection is due within 12 months of its latest one. And random tests go on all year.

Watch out for old checklists. Many lists online were written before recent rule changes. Some still tell you to collect a yearly list of violations signed by each driver. That rule ended on May 9, 2022 (the 2022 change). Some say every truck must carry the ELD user’s manual. That ended on July 22, 2026 (the 2026 change). The instruction sheets and blank log pages are still required (the ELD rule). Some tell you to fill in a DVIR every day for every truck. The rule asks for one only when a driver finds or hears of a defect. And if you run a single truck, it does not apply at all (the DVIR rule). Since March 23, 2026, the rule also says plainly that a DVIR can be electronic (the 2026 DVIR change). And for CDL drivers, the note that you checked the doctor on FMCSA’s National Registry was needed only through June 22, 2025. For drivers without a CDL, it is still needed (the driver file rule).

There are things we could not check. FMCSA’s own pages block automated readers. The web archive we use as a backup did not answer when we tried on September 21, 2026. So we could not read FMCSA’s own description of what the audit request asks for. The list on this page comes from the rules the audit checks. The auditor’s request will specify which records to send and which dates they must cover. How to send it is in our guide to the offsite audit. If the audit goes badly, what happens if you fail covers the next steps. If you are not sure the audit applies to you, see who needs a new entrant safety audit.

If you would rather have someone build these files and keep them current every month, here is what that costs.