New Carrier Records: What to Set Up in Your First 12 Months
Your new entrant period lasts 18 months, and the safety audit generally lands somewhere in the first 12 (49 CFR 385.307). The carriers who pass easily aren't the ones who cram when the letter arrives. They set up six folders before the first load and spend a few minutes a week keeping them current. This guide is that system: what to set up, what recurs, and how long to keep everything.
The six folders
Paper or digital, organize by the same areas FMCSA's New Entrant Web System uses for uploads. When the audit request comes, you just scan or export each folder.
- Company & insurance: USDOT/MC documents, MCS-150, insurance policy and MCS-90 (§ 387.7).
- Drivers: one DQ file per driver (§ 391.51).
- Drug & alcohol: consortium agreement, policy receipts, results, Clearinghouse records (Part 382).
- Hours of service: ELD exports and supporting documents (Part 395).
- Vehicles: one maintenance file per unit, annual inspections, DVIRs, roadside reports (Part 396).
- Accidents: the accident register and any reports (§ 390.15).
Before your first load (month 0)
- Confirm your MCS-150 contact address and email are ones you read. Audit requests go there.
- Insurance active at the required minimum (§ 387.9; generally $750,000 for general freight at 10,001 lbs or more, higher for some hazmat), with the policy and MCS-90 in folder 1.
- For CDL operations: consortium enrolled, policy distributed and receipt signed, pre-employment negative result received, Clearinghouse registered with C/TPA designated, pre-employment full query run (§§ 382.115, 382.301, 382.305, 382.701). Details in our drug and alcohol guide.
- A complete DQ file on every driver, including yourself: application, road test or equivalent, medical certification, and MVRs and employer history ordered (§§ 391.21–391.51). See the DQ file checklist.
- An ELD registered with FMCSA installed in each truck that needs one, with the user manual, malfunction instruction sheet, and blank paper logs for at least 8 days on board (§§ 395.8, 395.22).
- Every power unit and trailer with an annual inspection less than 12 months old, a copy of the report in its file, and proof on the vehicle (§ 396.17).
- A vehicle maintenance file started for every unit, with its identification (make, serial number, year, tire size, and owner if leased) and a schedule of inspections (§ 396.3(b)).
- An accident register started, even if the first entry is "none" (§ 390.15(b)).
Every week
- Review each driver's logs for violations and unassigned driving time; fix edits with annotations.
- File supporting documents (bills of lading, fuel receipts, dispatch records) by driver and date (§ 395.11).
- File the week's DVIRs. Any defect that affects safe operation must be repaired, and the repair certified, before the vehicle runs again (§ 396.11).
- File every roadside inspection report and return the signed repair certification within 15 days (§ 396.9(d)).
Every month
- Check your tracker for anything expiring in the next 60 days: medical certification, CDL, annual inspections, insurance, registration.
- Record preventive maintenance and repairs in each vehicle file.
- Update the accident register for any reportable accident: date, city/state, driver name, injuries, fatalities and hazmat release (§ 390.15(b)). Record a post-accident testing decision for each one.
Every quarter
- Confirm every CDL driver is on your consortium's random roster; save a dated copy.
- File any random selection notices and results.
- Do a 10-minute check against the auto-fail list.
Every 12 months (per driver or vehicle)
- Annual MVR and dated, signed annual review note for each driver (§ 391.25).
- Annual Clearinghouse query for each CDL driver, including yourself (§ 382.701(b)).
- Annual inspection for every power unit and trailer (§ 396.17).
- Insurance renewal, starting 30 days ahead.
- MCS-150 update when it's due (at least every 24 months), and UCR registration each year.
- Your consortium's annual summary (MIS) if they provide one.
A typical first-year timeline
| When | What usually happens |
|---|---|
| Month 0 | USDOT number issued; you enter the New Entrant Safety Assurance Program (§ 385.305). Folders set up before the first load. |
| Months 1–3 | You build up real records: logs, DVIRs, maybe a roadside inspection. FMCSA generally waits until there are records to review. |
| Months 3–12 | Audit request by letter or email, usually offsite through NEWS. You upload by the stated deadline. |
| Within 45 days of the audit | Pass, or a written failure notice starting the corrective-action clock (§ 385.319). If you fail, see our corrective action plan guide. |
| Month 12 | First annual MVRs, reviews, Clearinghouse queries and (if your trucks were inspected at purchase) annual inspections come due. |
| Month 18 | If you passed and weren't revoked, you leave the new entrant program (§ 385.333). |
How long to keep each record
| Record | Keep | Rule |
|---|---|---|
| DQ file | While employed + 3 years (some items removable after 3 years) | § 391.51(c)–(d) |
| Records of duty status and supporting documents | 6 months | § 395.8(k) |
| DVIRs and repair certification | 3 months | § 396.11 |
| Annual inspection report | 14 months | § 396.21(b) |
| Vehicle maintenance records | 1 year where the vehicle is housed, and 6 months after it leaves your control | § 396.3(c) |
| Roadside inspection reports | 12 months | § 396.9(d)(3) |
| Accident register | 3 years from the date of each accident | § 390.15(b) |
| Drug and alcohol records | 1, 2, 3 or 5 years depending on type | § 382.401 |
When in doubt, keep a record longer. Storage is cheap; a missing record during the audit isn't.
Keep it simple
You don't need compliance software in year one. A shared drive with the six folders, one spreadsheet tracking every due date, and a recurring calendar reminder will get a one- to five-truck carrier through the audit. What matters is that every required record exists, is dated honestly, and can be found in minutes. For the area-by-area audit view of the same records, see the new entrant safety audit checklist.
When the audit request arrives
If you followed the calendar, the request is mostly an upload job. Read the letter for the deadline and the list of documents requested. Log in to NEWS and match each folder to its upload category. Export ELD records for the review period the auditor names, and scan supporting documents in date order. Check every expiration date one last time against the auto-fail list. Name files clearly, for example "DQ - Smith - annual review 2026-08.pdf", so the auditor can find each item without guessing. Upload a few days early in case the system or a file gives you trouble, and keep a copy of everything you sent.
If you find a gap while preparing, don't hide it and never backdate a document. Fix it now, date the fix honestly, and note what you changed so it can't happen again. That is the same structure FMCSA expects in a corrective action plan, so if the gap does cost you the audit, your response is already half written.
When you add trucks or drivers
Growth is when good systems break. Each new driver needs a full DQ file, a pre-employment test and Clearinghouse query, and a spot on the random roster before the first trip. Each new truck or trailer needs a maintenance file, a current annual inspection and an entry in your vehicle list before it runs. Leased equipment counts too: get the lessor's inspection and maintenance records in writing. Add every new person and unit to your tracker on the day they join, not at the end of the month.
Frequently asked questions
What records does a new trucking company need to keep?
At minimum: driver qualification files (49 CFR 391.51), drug and alcohol testing records if you operate CDL vehicles (382.401), records of duty status and supporting documents (395.8, 395.11), vehicle maintenance and inspection records (396.3, 396.11, 396.17), proof of insurance (387.7), and an accident register (390.15).
How long is the new entrant monitoring period?
Eighteen months from when you receive your USDOT number as a new entrant. FMCSA generally conducts the safety audit within the first 12 months of operations (49 CFR 385.307).
How long do I keep ELD records?
Six months. Carriers must keep records of duty status and supporting documents for each driver for six months from receipt (49 CFR 395.8(k)).
How long do I keep annual inspection reports and DVIRs?
Keep the annual inspection report for 14 months from the date of the inspection (49 CFR 396.21(b)) and DVIRs, with the repair certification, for three months from the date the report was prepared (49 CFR 396.11).
Primary sources
- eCFR Title 49 (current text)
- FMCSA: New Entrant Safety Assurance Program
- FMCSA New Entrant Web System (NEWS) Help Center
Regulation text checked against eCFR Title 49 as of October 15, 2026.