ELD Compliance Checklist for Trucking Companies

Mandatory In-Cab Documentation

One of the most prevalent infractions during a DOT inspection is the lack of physical or digital documentation. Availability of the following must be possible in every commercial motor vehicle (CMV) to its driver:

• ELD User’s Manual: A guide that describes the usage of the hardware and software installed in the truck.
• Data Transfer Instruction Sheet: Specific procedures that the driver is to use in transferring Record of Duty Status (RODS) to the safety department using telematics (wireless) or local data transfer (USB/Bluetooth).
• Malfunction Instruction Sheet: This document contains instructions which the motor carrier or the driver must follow if the ELD malfunctions.
• Blank Paper Log Supply: A minimum of eight (8) days-worth of blank grid graph paper log books in case there is a device malfunction.

Note that these types of documents may be saved in an electronic form within the ELD system, but an internet connection must not be necessary in order for quick and immediate access to be obtained.

Technical & Hardware Synchronization

To comply, one has to start at the engine level. An ELD is only acceptable if it is fully integrated with an Engine Control Module (ECM).

• Hardware Verification Points: Automatic Motion Detection: The system should initiate "Driving" when the car speed exceeds 5 mph at any time.
• Odometer & Engine Hours Accuracy: Data has to be extracted directly from ECM, not estimated from GPS calculations.
• Registry Confirmation: All providers’ continued inclusion on the FMCSA Registered ELDs must be checked from time to time. When a device is moved to the Revoked List, you have a strict 60 days to replace that device.
• Tamper Resistance: The system should be able to detect and record "unidentified driving" occurrences in order to preclude unchecked movements.

Driver Duty Status & Operational Proficiency

A compliant device will only work effectively if the person operating the device is knowledgeable about how to work it correctly. Compliance officials will, at times, test how well the device operator can work with the device interface during Level III compliance testing.

Action Item	Compliance Requirement
Log Certification	Drivers must certify their logs at the end of every 24-hour period.
Unassigned Driving	Upon login, drivers must review and either "Accept" or "Reject" any unassigned driving segments recorded by the vehicle.
Edit Traceability	All manual edits must include an annotation (remark) and be re-certified by the driver. Original data is never overwritten; it remains visible in the audit trail.
Special Categories	Ensure "Personal Conveyance" (PC) and "Yard Move" (YM) settings are configured correctly according to company policy and FMCSA limits.

Administrative & Back-Office Audit Trail

The obligation of the carrier is not limited to the cab. The fleets’ data management must be very tight in order to survive an audit or compliance review.

• Data Retention: Maintain ELD records, including accompanying documentation (fuel receipts, Bills of Lading, toll records) for no less than 6 months.
• Unassigned Mileage Management: The Carrier must review and assign "Unidentified Driving" transactions to the proper driver or assign an attribution for the mileage that was non-utils miles (for example, a drive for a mechanical test).
• Protection from Harassment: The system must not use the information to harass drivers into violating safety standards, which are subject to severe legal punishment.
• Malfunction Reports: In cases of a reported failure, the carrier will have eight days to make repairs and replace the unit if necessary. However, if additional time beyond the eight days is necessary, the FMCSA Division Administrator must be formally notified of this need via filing of an extension.

Effective knowledge and implementation regarding ELD compliance need a combination of reliable hardware from telematics providers and strict driving behavior. Trucking fleet operators can minimize their chances of getting an Out-of-Service order by following this checklist.