Common IRP Mistakes

Who This Applies To

• Motor carriers with any IRP compliance history who want to identify patterns in registration, recordkeeping, and renewal errors.
• New IRP account holders who are completing their first full registration year and approaching the first renewal.
• Fleet managers conducting an annual IRP compliance review before the renewal window opens.
• Carriers who received an IRP audit notice and are trying to understand what records will be examined.

What To Verify

• That the current cab card in each vehicle lists all IRP member jurisdictions, matches the current plate and VIN, and reflects the current registration year — not a prior-year card left in the cab.
• That trip-level distance records exist for all vehicles for the full registration year. IRP auditors do not accept jurisdiction summaries without the underlying trip-level support.
• Whether any vehicles were added, removed, or changed during the year and whether the account supplements were processed and reflected in current credentials.
• That the renewal was submitted with actual prior-year distance — not estimated or prior-year figures carried forward without reconciliation against current records.

Step-by-Step Overview

1. Pull cab cards for every vehicle and verify: current registration year, correct VIN and plate, all member jurisdictions listed. Replace any expired or mismatched cards immediately.
2. Audit trip records for completeness: every qualifying vehicle should have trip-level records covering the full registration year, showing miles per jurisdiction per trip.
3. Check the IRP account for any unprocessed supplements — vehicles added or removed mid-year that weren't formally updated in the account can create gaps or overcharges.
4. Compare the jurisdiction distance summary for the upcoming renewal against the trip-level records. Any discrepancy found before submission is easier to resolve than one found during an audit.
5. Verify the base jurisdiction's retention requirement and confirm that records for all open audit years are accessible and organized.

Common Mistakes

• Leaving last year's cab card in the vehicle after renewal. The expired card is not valid — the current-year card must replace it. This is the most common IRP roadside violation.
• Dispatching a newly added vehicle before the supplement is processed. The cab card for a new vehicle does not exist until the supplement clears — operating without it requires trip permits.
• Confusing IRP renewal (registration fees and cab cards through the DMV) with IFTA renewal (license and decals through the tax authority). Both typically come due in the same period but are handled by different offices.
• Using estimated distance at renewal because actual trip records weren't maintained during the year. Estimated figures that diverge from what auditors find in third-party data (GPS, ELD records) result in back-fees and sometimes penalties.