ELD Carrier Responsibilities

Who This Applies To

• Motor carriers subject to the ELD mandate who need to understand their obligations beyond simply installing compliant devices.
• Compliance managers at trucking companies auditing carrier-side ELD compliance for the first time.
• Carriers who received a Notice of Claim from FMCSA related to ELD records and need to understand what records should have been maintained.
• New carriers setting up ELD programs and trying to understand what the carrier — as distinct from the driver — is required to do.

What To Verify

• That the carrier must retain ELD records for each driver for a minimum of 6 months. This includes daily ELD logs, supporting documents (fuel receipts, trip sheets, bills of lading, weigh tickets, and toll receipts), and malfunction event records.
• That the carrier is responsible for providing compliant ELD training to each driver before the driver operates a vehicle equipped with an ELD. Training records should document what was covered and when.
• That the carrier must respond to an ELD malfunction within 8 days by repairing or replacing the device. If a driver reports a malfunction and the carrier does not act within 8 days, the carrier is in violation regardless of the driver's paper log compliance.
• That the carrier may not edit or delete a driver's certified log. Carriers may suggest amendments, but the driver must make and accept any change — unauthorized carrier edits to driver logs are a serious FMCSA violation.

Step-by-Step Overview

1. Maintain a record of all ELD devices in the fleet: device identifier, vehicle assignment, installation date, and FMCSA registered compliant device list reference. If a device is removed or replaced, document the change.
2. Keep a copy of ELD driver training records for each driver, including the date of training and confirmation the driver can log in, transfer data, and respond to a malfunction.
3. Retain ELD records for all drivers for at least 6 months. Supporting documents that validate log data must also be retained for the same period.
4. When a driver reports an ELD malfunction, open a repair or replacement process immediately and document the action taken. Confirm the device is repaired or replaced within 8 days.
5. Audit ELD records periodically. A pattern of unresolved diagnostics, frequent unassigned driving, or recurring paper log use may indicate a systemic compliance gap that needs correction before a formal FMCSA review.

Common Mistakes

• Not retaining supporting documents alongside ELD logs. The ELD log shows duty status — the supporting documents (fuel receipts, BOLs, scale tickets) corroborate the log's accuracy. Retaining one without the other leaves the record incomplete.
• Not training drivers on ELD use before the first trip. A driver who cannot operate the ELD, transfer data, or handle a malfunction exposes the carrier to enforcement findings even if the device itself is compliant.
• Failing to respond to a driver-reported ELD malfunction within 8 days. The carrier's 8-day repair obligation runs from the time the malfunction is reported — not from when the carrier begins investigating it.
• Editing or deleting certified driver logs without driver authorization and documentation. Unauthorized log edits are among the most serious ELD violations FMCSA can cite against a carrier.