ELD mandate compliance checklist: the office and the cab
FMCSA's own ELD checklists were last updated in 2017, and they still list a user's manual that no longer has to ride in the cab. Here is the list rebuilt from the rule as it reads today, split between the people in the office and the person in the driver's seat.
Written by Rigo Diaz
The ELD mandate in numbers
An ELD mandate compliance checklist has two halves. Carriers must run a registered device, give every user a unique account, keep logs and supporting documents for 6 months, and review unidentified driving. Drivers must log in, annotate, certify each day, submit records within 13 days, and transfer logs to an officer on request.
An ELD problem that turns into a fine usually starts with people, not hardware: a shared login, an edit the office pushed through, a receipt nobody kept. The device can be on FMCSA's list and working perfectly while the records around it fall apart.
I spent more than six years in risk management before I founded Simplex, and I have led it for more than 25 years since. I read this checklist as a list of exposures. Each line is a rule, and each missed line is a recordkeeping or harassment finding with a dollar figure attached.
The full briefing, read aloud
8 chapters. Select one to jump to it.
Generated with AI text-to-speech from this article's key insights, in order, rather than reading it word for word. Chapter times come from a transcript of the audio. The article itself was written and reviewed by Rigo Diaz.
Key takeaways
FMCSA's checklists date from 2017
They still list the ELD user's manual, which no longer has to be in the cab since July 22, 2026. The other in-cab items are still required.
Every user needs a unique account
Carriers create, update, and deactivate ELD accounts. A driver's license number or Social Security number can't be used as the username.
Eight supporting documents is a ceiling
You need not keep more than 8 per driver per 24 hours, but you must keep the earliest and latest of them, matched to the log, for 6 months.
Drivers have 13 days
Drivers submit their certified logs and their supporting documents to the carrier within 13 days.
Edits need the driver's yes
The office may request edits only after the driver submits, and the driver must confirm or reject them. Coercing a false certification is prohibited.
In this articleContents
Does the ELD mandate apply to your operation?
The ELD mandate applies to every motor carrier whose drivers must keep records of duty status. Under 49 CFR 395.8, those carriers have had to install ELDs and require drivers to use them since December 18, 2017. Older AOBRD units were allowed only until December 16, 2019.
A carrier may still have a driver keep paper logs when the driver:
- Keeps records of duty status on no more than 8 days in any 30-day period
- Drives in a driveaway-towaway operation where the vehicle driven is part of the shipment, or the cargo is a motor home or RV trailer
- Drives a vehicle manufactured before model year 2000, as shown by the VIN on its registration
FMCSA's carrier checklist adds one practical line: if you rely on an exemption, keep documentation that supports it. Owner-operators with leases, rentals, or older engines will find those edge cases in our ELD questions for owner-operators.
What changed since FMCSA's 2017 checklist?
FMCSA's carrier and driver checklists were last updated on August 2, 2017. Most of their items still hold, but one has been rescinded.
| 2017 checklist item | Status today |
|---|---|
| ELD user's manual in the cab | No longer required since July 22, 2026 (91 FR 37050) |
| Data transfer instruction sheet | Still required, 49 CFR 395.22(h)(1) |
| Malfunction instruction sheet | Still required, 49 CFR 395.22(h)(2) |
| Blank graph-grid logs for 8 days | Still required, 49 CFR 395.22(h)(3) |
| AOBRD grandfather period | Ended December 16, 2019 |
| Up to 8 supporting documents per day, kept 6 months | Unchanged, 49 CFR 395.11 and 395.8(k) |
Dropping the manual does not drop the skill. A driver must still produce and transfer records when an officer asks, following the carrier's instruction sheet.
What must the carrier have in place?
The carrier owns the device, the accounts, and the records. Under 49 CFR 395.22, your checklist is:
- A registered device. Use only ELDs on FMCSA's registered list, and recheck the list, because devices get removed. Our ELD compliance guide covers the registry and the malfunction clock.
- One account per person. Create, update, and deactivate accounts. Each user gets a unique username that is not their driver's license number or Social Security number.
- Accurate driver accounts. Name as shown on the license, license number, and issuing state, with a license that is valid and belongs to the driver using the account.
- Office accounts too. Support staff who view or suggest edits need their own accounts, with their name as shown on a government ID.
- Proper log-ins. Require every driver and staff member to log in with their own credentials.
- A maintained, mounted device. Calibrate and maintain it to the provider's specifications; mount a portable ELD in a fixed position the seated driver can see.
- The in-cab packet. The two instruction sheets and blank graph-grids for at least 8 days.
- A separate backup. Keep a 6-month backup on a device separate from the original, stored to protect driver privacy.
- Records on request. Produce ELD records electronically when an official asks; a carrier with several terminals may have up to 48 hours, excluding weekends and federal holidays, under 49 CFR 390.29.
What should a written ELD policy cover?
A written policy turns the rule into instructions your drivers and dispatchers can follow. It should name an owner and a deadline for each of these:
- Who opens accounts, and who deactivates them the day a driver or staff member leaves
- Whether drivers may use personal conveyance and yard moves, which are carrier options under 49 CFR 395.28, and on what terms
- How drivers turn in supporting documents, and how the office matches them to each log
- Who reviews unidentified driving, and how often
- How the office requests edits, and that drivers may reject them
- Who receives malfunction notices and tracks the repair
- A plain statement that dispatch will never use ELD data to push a driver past the hours rules, and how a driver can raise a concern
What supporting documents must you keep, and for how long?
You must keep the supporting documents that verify each driver's on-duty time, matched to that driver's log, for at least 6 months. Under 49 CFR 395.11, they come in five categories:
- Bills of lading, itineraries, schedules, or similar documents showing each trip's origin and destination
- Dispatch records and trip records
- Expense receipts for on-duty, not-driving time
- Electronic mobile communication records sent through a fleet management system
- Payroll records and settlement sheets showing payment to the driver
Each document must link to the driver by name, PIN, or unit number, and show the date, the nearest city or town, and the time. A document with no time still counts when the driver has fewer than eight that show all four.
The number 8 is a ceiling on what you must keep, not a limit on what you may keep. You need not keep more than 8 per driver per 24 hours, and if you have more, the 8 you keep must include the earliest and latest times.
Retention runs on several records at once:
| Record | Keep for |
|---|---|
| Records of duty status and supporting documents | At least 6 months from receipt, 395.8(k) |
| Backup copy of ELD records, on a separate device | 6 months, 395.22(i) |
| Unidentified driving records, for each ELD | At least 6 months from receipt, 395.32(c) |
| Original ELD data, even after edits | Never altered or erased, 395.30(f) |
No carrier or driver may deface, destroy, or alter information on a supporting document.
What must drivers do every day?
Drivers keep the record accurate as it happens and certify it every day. Under 49 CFR 395.8, 395.24 to 395.34, and 395.11, a driver's checklist is:
- Log in with your own account, never a co-driver's or a shared one
- At log-in, review any unassigned driving the ELD shows you, and accept what is yours or mark it as not yours
- Select your duty status, and enter annotations and your location when the ELD prompts you
- Enter or verify the power unit number, trailer numbers, and shipping document number
- Select personal conveyance or yard move before it starts and deselect it when it ends, if your carrier allows them
- Explain every edit or addition with an annotation
- Certify each 24-hour period by selecting "Agree" right after your final entry, and recertify after accepting any edit
- Submit your certified logs and supporting documents within 13 days
- Transfer your logs to an officer on request, following the instruction sheet, and show any supporting document you have with you
- Report a malfunction to the carrier in writing within 24 hours, and log on paper until it is fixed
The 13 days for supporting documents start from the 24-hour period they cover or the day you receive the document, whichever is later. For how each of these looks on the screen, see our guide to how an ELD logs your day.
Where do edits cross into coercion, and what does it cost?
An edit crosses the line when the office, not the driver, decides what the log says. Under 49 CFR 395.30, a carrier may request edits only after the driver submits the records, the driver must confirm or reject each one and recertify, and the carrier may not coerce a false certification.
Harassment is narrower and specific to ELDs. Under 49 CFR 390.36, it is a carrier action using ELD information that the carrier knew, or should have known, would make a driver break the hours rules or drive while ill or fatigued. Monitoring productivity is allowed, as long as it doesn't lead there.
A driver has 90 days to file a written harassment complaint with FMCSA. A carrier found to have harassed a driver faces a harassment penalty on top of the penalty for the hours violation, and FMCSA may treat harassment as serious enough for the maximum allowed by law.
| Violation | Maximum penalty |
|---|---|
| Missing, incomplete, inaccurate, or false record | $1,584 per day, up to $15,846 |
| Knowingly falsifying or destroying a record | $15,846 |
| Other safety-rule violations by a carrier | $19,246 per violation |
| Other safety-rule violations by a driver | $4,812 |
These are ceilings that FMCSA adjusts for inflation, not set fines. The cheaper habit is a weekly look at edits, unassigned driving, and missing certifications, which our weekly HOS and ELD audit playbook walks through, and which our DOT safety compliance team can run for you.
How Simplex helps you stay on the right side of the ELD mandate
The device is one line on the checklist. We help with the accounts, records, and reviews behind it.
ELD and hours-of-service support
Our DOT safety compliance team covers ELD and hours of service, driver qualification files, and audit support.
A program that keeps checking
Our compliance programs include HOS management, CSA monitoring, and mock audits, so gaps show up before an officer finds them.
ELD solutions for fleets
Simplex offers ELD solutions for trucking companies, and we help set up the process around the device.
Frequently asked questions
What is the ELD mandate?+
What documents must be in the truck under the ELD rule?+
How many supporting documents must a carrier keep per driver?+
Who is exempt from the ELD mandate?+
What are the fines for ELD violations?+
Where this information comes from
The requirements below come from federal regulation, the Federal Register, and FMCSA's own ELD pages, checked on October 16, 2026 (eCFR up to date as of October 15, 2026).
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1
eCFR — 49 CFR 395.8
The December 18, 2017 mandate, paper-log exceptions, the 13-day submission, and 6-month retention.
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2
eCFR — 49 CFR 395.11
Supporting document categories, data elements, the 8-document ceiling, and the 13-day rule.
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3
eCFR — 49 CFR 395.22
Carrier duties: registered devices, user accounts, the in-cab packet, backups, and record production.
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4
eCFR — 49 CFR 395.30
Certification, edits, carrier-proposed edits, the coercion ban, and original-data retention.
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5
eCFR — 49 CFR Part 386
The 90-day harassment complaint (386.12(b)) and the Appendix B maximum civil penalties.
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6
Federal Register — ELD operator's manual rescinded
Final rule removing the in-cab manual requirement, effective July 22, 2026.
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7
FMCSA — ELD Checklist for Carriers
FMCSA's carrier checklist, last updated August 2, 2017, including the AOBRD dates.
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8
FMCSA — Harassment Protection
How FMCSA defines ELD harassment and the added penalty on top of the hours violation.
Written by
Rigo Diaz
Founder & CEO, Simplex Group
Founder and CEO of Simplex Group, with more than 25 years leading the company and helping trucking entrepreneurs navigate compliance, insurance, and the day-to-day demands of running a carrier. Before founding Simplex, he spent more than six years in risk management, experience that continues to shape how he approaches insurance, compliance, and carrier risk today.
Published · Updated
Related articles and services
The ELD mandate is mostly about people and paper
A registered device is one line on this checklist. Accounts, supporting documents, edits, and how dispatch uses the data make up the rest, and that is where the exposure sits.
If you want a second set of eyes on your accounts, records, and ELD policy, talk to our team.