Your Driver Files May Be Organized — But What About Your Trucks?
When trucking companies think about an FMCSA audit, Driver Qualification Files, drug and alcohol testing, medical cards, Clearinghouse requirements, and Hours of Service often receive most of the attention.
But FMCSA compliance doesn't stop with the driver.
Motor carriers are also responsible for systematically inspecting, repairing, and maintaining commercial motor vehicles subject to their control and maintaining required vehicle records.
That raises an important question:
If an FMCSA investigator asked you today for the maintenance file for one of your trucks, could you produce it?
For many small carriers, the answer isn't as simple as it should be.
Vehicle Maintenance Record Violations Are More Common Than You May Think
Vehicle recordkeeping isn't an obscure FMCSA requirement.
FMCSA's 2025 investigation data show that:
1,718 violations involved carriers failing to have a means of indicating maintenance due dates.
1,490 violations involved failing to keep a maintenance record identifying the vehicle.
In FMCSA's national investigation data, those ranked among the most frequently recorded violations.
That's important for small trucking companies because having the truck properly maintained isn't the entire compliance requirement.
You also need the records to demonstrate it.
A carrier may regularly service its equipment and still have a compliance problem if the required documentation isn't properly maintained.
What Vehicle Maintenance Records Does FMCSA Require?
Under 49 CFR §396.3, motor carriers must systematically inspect, repair, and maintain vehicles subject to their control.
For vehicles controlled for 30 consecutive days or more, required records generally include:
1. Vehicle Identification
The file should identify the vehicle, including required identifying information such as the make, company number if applicable, serial number, year, and tire size.
If the vehicle isn't owned by the motor carrier, the records must also identify the party furnishing the vehicle.
2. Inspection and Maintenance Schedule
The carrier needs a way to indicate the nature and due date of inspection and maintenance operations that need to be performed.
In other words, simply keeping receipts after repairs isn't the same as maintaining a systematic maintenance record.
3. Inspection, Repair and Maintenance History
Records should document inspections, repairs, and maintenance, including their dates and the type of work performed.
These records create a history showing how the carrier has maintained the vehicle.
What Could an FMCSA Auditor Ask For?
FMCSA safety-audit materials make the vehicle-maintenance portion very clear.
An investigator may want to determine whether a carrier can produce maintenance files for requested vehicles and evidence that required periodic inspections have been completed.
Auditors may also evaluate whether the carrier has established an effective systematic maintenance program.
This means an audit isn't the time to start searching through glove compartments, email inboxes, repair-shop receipts, filing cabinets, and text messages trying to reconstruct a truck's maintenance history.
Your records should already be organized.
How Long Do Vehicle Maintenance Records Need to Be Kept?
FMCSA generally requires the records specified under §396.3 to be retained where the vehicle is housed or maintained for one year and for six months after the motor vehicle leaves the motor carrier's control.
FMCSA also provides guidance for situations where records are kept somewhere other than where the vehicle is housed.
When requested by FMCSA, those maintenance records must be made available within a reasonable period of time. FMCSA guidance identifies that reasonable period as two working days.
That makes organization especially important.
It isn't enough to know that the paperwork exists somewhere.
A carrier needs to be able to retrieve its records when they're requested.
What Happens If Vehicle Records Are Missing?
Missing or incomplete maintenance records can result in FMCSA violations.
Depending on the circumstances, violations discovered during an investigation can contribute to enforcement actions and civil penalties.
FMCSA also classifies certain violations as acute or critical for enforcement purposes. A pattern of acute or critical violations can have significantly more serious consequences, including assessment of maximum statutory penalties in qualifying circumstances.
For New Entrant carriers, vehicle compliance is particularly important.
FMCSA states that New Entrants must maintain up-to-date records, conduct periodic inspections, maintain their CMVs, and pass a Safety Audit.
Certain serious vehicle-related violations can even result in an automatic failure of the New Entrant Safety Audit, including operating a CMV that has not received the required periodic inspection.
The cost of becoming compliant after a problem is discovered can be considerably greater than establishing an organized compliance system from the beginning.
"But I Keep My Maintenance Receipts."
Receipts are useful, but vehicle compliance management involves more than collecting receipts.
Consider these questions:
Can you immediately identify which records belong to each truck?
Can you see when required maintenance or inspections are due?
Can you produce the maintenance history for a specific vehicle?
Is your annual inspection documentation current?
Are repair and maintenance records consistently being added to the appropriate vehicle file?
Would you know what's missing before an auditor discovers it?
If you're unsure about any of those answers, your vehicle recordkeeping system may need attention.
Small Carriers Need Vehicle Files Too
It's easy to assume vehicle file management is something only large fleets need.
In reality, smaller carriers often have the least administrative support.
An owner-operator or small fleet owner may simultaneously be responsible for:
Driving
Dispatching
Booking loads
Billing
Managing drivers
Scheduling repairs
Tracking renewals
Maintaining compliance records
Something eventually gets overlooked.
And unfortunately, being a one-truck or two-truck operation doesn't automatically eliminate applicable FMCSA recordkeeping responsibilities.
Getting Organized Before an Audit Is More Cost-Effective
There are two ways to deal with vehicle compliance.
Option 1: Establish the proper vehicle files, maintain the records, track important dates, and stay organized as you operate.
Option 2: Wait until an audit, investigation, roadside issue, or compliance problem exposes what's missing—and then try to correct months of recordkeeping while simultaneously responding to FMCSA.
For most carriers, prevention is the better business decision.
BUnited Services created our Vehicle File Management service specifically to make ongoing vehicle compliance management affordable for small and growing carriers.
Vehicle File Management Starts at Just $10 Per Month
For carriers with only 1–2 vehicles, Vehicle File Management is just $10 per month.
Instead of trying to reconstruct your vehicle compliance records when someone asks for them, you can have a system in place from the beginning.
BUnited Services helps carriers maintain organized vehicle compliance files, track important documentation and expiration dates, and keep required vehicle records together.
Don't Wait Until FMCSA Asks for the File
Ask yourself one final question:
If an FMCSA investigator gave you the DOT number, unit number, or VIN of one of your vehicles and asked you to produce its maintenance history, how quickly could you do it?
If that question makes you uncomfortable, now is the time to get organized.
Your drivers aren't the only part of your operation that needs a compliance file.
Your trucks do too.
Get Your Vehicle Files Set Up
BUnited Services provides affordable Vehicle File Management for owner-operators and fleets of all sizes.
Starting at $10/month for 1–2 vehicles.
Set up your vehicle files now and put a compliance system in place before you're asked to prove you have one.
BUnited Services
Keeping Carriers Compliant.
Suggested FAQ Section for Google Search
Does FMCSA require vehicle maintenance records?
Yes. Under 49 CFR §396.3, applicable motor carriers must systematically inspect, repair, and maintain vehicles under their control. For vehicles controlled for 30 consecutive days or more, carriers must maintain specified identification, maintenance scheduling, inspection, repair, and maintenance records.
How long must FMCSA vehicle maintenance records be kept?
Records required under §396.3 generally must be retained where the vehicle is housed or maintained for one year and for six months after the vehicle leaves the carrier's control.
Can FMCSA ask to see my truck maintenance records during an audit?
Yes. FMCSA safety-audit materials include determining whether a carrier can produce maintenance files for requested vehicles and evidence of required periodic inspections.
Do owner-operators need vehicle maintenance records?
Applicable FMCSA vehicle maintenance requirements are based on the carrier's operation and vehicles, not simply on whether the company operates a large fleet. Small carriers should determine which Part 396 requirements apply to their operation and maintain the appropriate records.
What happens if I don't have vehicle maintenance records?
Missing required records can result in violations discovered during an FMCSA investigation or audit. Depending on the type, severity, frequency, and circumstances of violations, enforcement consequences can include civil penalties and other compliance actions.
What should be included in an FMCSA vehicle file?
Depending on the operation and applicable requirements, vehicle records may include required vehicle identification information, inspection and maintenance schedules, records of inspections, repairs and maintenance, periodic inspection documentation, and other applicable supporting records.
