FMCSA ELD Mandate Compliance Checklist

Does the ELD mandate apply to your operation?

The ELD rule applies to most motor carriers and drivers who are required to keep records of duty status (RODS). FMCSA highlights that operators should first confirm applicability and any exemptions before building their program. If an exemption applies, maintain documentation to support it. 

From a compliance operations standpoint, we advise treating “applicability confirmation” as a recurring control: verify at onboarding, whenever the operation or vehicle use changes, and during quarterly audits. In our work at Simplex Group, we keep clients current on regulatory updates and translate them into clear, low-friction procedures, so applicability and documentation do not become afterthoughts in an audit.

Carrier ELDs checklist

Implementation plan and timeline

Build a written plan that covers rule understanding, exemption screening, device selection, process design, and training. FMCSA’s carrier checklist calls out planning, device evaluation, process development (annotations, supporting documents, malfunction workflows), training by role, installation/testing, and account setup for drivers and other users.

In our implementations, we convert the plan into a RACI matrix (who does what and when), with milestones for pilot, go-live, and post-implementation review. This helps keep deployment proactive rather than reactive, we manage the fleet proactively, not reactively, with clear processes, metrics, and ownership embedded from day one.

Training by audience

Provide initial, refresher, and “spot” training. Ensure coverage of compliance requirements, supporting documents, ELD operation, proper editing and annotation, data retention, harassment/coercion prevention, and troubleshooting of malfunctions or diagnostics.

Our trainers at Simplex Group routinely tailor sessions for compliance managers, dispatch, maintenance, and drivers. We also add a short “inspection simulation”, so teams practice transferring data to officials under time pressure.

On-board documentation (what must be in the cab)

As of the ELD compliance date, the following are mandatory in the vehicle:

• ELD User’s Manual
• Instruction sheet for transferring HOS records to safety officials
• Instruction sheet for reporting malfunctions and recordkeeping during malfunctions
• A supply of paper graph grids for at least 8 days (backup in case of malfunction) 

We routinely check these items during mock audits; if anything is missing, we correct it immediately and document the fix.

Supporting documents, retention, and backups

Carriers must retain no more than 8 supporting documents per day per driver for 6 months. ELD data and backup data must also be retained for 6 months and stored securely to protect driver privacy.

Our standard practice is to centralize retention in the back office and automate a dual-location backup. We also include retention rules in driver and dispatcher SOPs so the “8 per day” limit is respected across all business systems.

Harassment and coercion prevention

Harassment protections apply once you begin using ELDs; carriers face penalties for harassment in addition to any HOS violation. Build a written anti-harassment policy, define reporting channels, and train leaders and dispatch on prohibited conduct.

At Simplex Group, we embed this into our safety and risk program; we translate safety into an actionable risk-management plan executed in everyday routines.

Driver ELDs checklist

Drivers should complete training, read the user guide, and be able to: log in; manage unassigned driving; change duty status; edit records with annotations; certify records; access and review their RODS; display/print standardized log views; transfer data to officials (email or Bluetooth for local methods); and identify/report data diagnostic issues and malfunctions. 

Carry these in the vehicle: the ELD user manual; transfer instructions; malfunction/recordkeeping instructions; and paper graph grids for at least eight days. Drivers should also submit all supporting documents to the carrier within 13 days of generation. 

From the field, we add two practical habits:

1. End each shift by certifying your RODS before engine shutdown to avoid anomalies.
2. During inspections, follow your transfer script step-by-step; at Simplex Group, we drill this until it’s muscle memory, We keep clients informed and operational so no truck sits idle over paperwork.

Internal audit & inspection preparation

To stay inspection-ready, combine the checklists above with a short, recurring internal audit:

1. Device control: Confirm your exact models are FMCSA-registered and still compliant; use only devices on the agency’s registered list. 
2. Documentation spot-check: Randomly sample vehicles for the four mandatory on-board items and confirm driver familiarity with transfer/malfunction instructions.
3. Supporting documents & retention: Reconcile driver submissions, enforce the 8-per-day rule, and verify six-month retention and backups.
4. Training currency: Track initial, refresher, and ad-hoc coaching—especially on edits/annotations and unassigned driving.
5. Harassment prevention: Review complaints and dispatch practices against your policy and FMCSA guidance.

As part of our managed service, Simplex Group maintains these controls for clients and escalates exceptions weekly, which keeps fleets inspection-ready without last-minute scrambles.

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