Trucking record retention schedule: ELD, HOS, DQ files and maintenance

How long does a trucking company have to keep its records?#

A trucking company has to keep each record type for its own period, and no single number covers the whole operation. FMCSA's hours-of-service rules set a six-month minimum for records of duty status and supporting documents, while driver qualification files run for the length of employment plus three years.

Those federal periods are floors. Insurers, fuel tax and registration audits, cargo claims, shipper contracts and litigation holds can each require longer, and the right period for a record is the longest one that applies. A written schedule makes that choice once, by record type, instead of leaving it to whoever cleans up a server or changes a vendor setting.

Retention schedule template by record type#

The retention schedule below lists the main record types, the rule to verify, the minimum period where it is established, and a column for records that should be excluded from any dataset the company might later license or share. Confirm every period against the current regulation text and with your safety consultant or counsel before adopting it.

Copy the table into the company's own schedule and add two columns: the system that holds each record, and the person who approves deletion.

ELD and HOS records: the six-month floor#

ELD and HOS records carry a six-month federal minimum. FMCSA guidance on 49 CFR 395.8(k)(1) says a carrier must keep each driver's records of duty status and supporting documents at its principal place of business for six months from the date of receipt, and its ELD FAQ adds that the back-up copy must sit on a device separate from the original data.

Supporting documents are broader than many safety teams assume. FMCSA describes them as records kept in the ordinary course of business that verify the log, such as bills of lading, itineraries, schedules or equivalent documents showing trip origin and destination, and expense receipts for on-duty not-driving time. They often live in the TMS or accounting system rather than the ELD.

Check the ELD vendor's retention settings against your schedule. Samsara, for example, lets customers keep HOS logs and violation reports for as long as they remain a customer or for six months (184 days), under Settings > Data Retention. Choosing the shorter setting deletes older history, so export first if you plan to shorten a setting or leave a vendor.

Driver qualification files: the longest federal clock#

Driver qualification files have the longest federal period in this schedule: 49 CFR 391.51(c) requires keeping each file for as long as the carrier employs the driver and for three years after. Under 391.51(d), certain items, such as annual MVR inquiries, annual review notes and medical examiner's certificates, may be removed three years after they were executed.

The practical problem is the start date for those three years. Termination dates often sit in payroll or HR systems, not in the safety software that holds the DQ file, so purge reviews go wrong when the two are not linked. Record the separation date on the DQ file itself.

Keep DQ files, medical certificates and testing records apart from operating archives, both physically and in folder permissions. They are personnel records with sensitive personal and health information, and they should never be swept into a general export of fleet data.

Maintenance and inspection records follow the unit#

Maintenance and inspection records are organized by vehicle, so their clock is tied to the unit rather than to a driver or a trip. FMCSA's inspection, repair and maintenance rules set the requirements; verify the current periods in the regulation text, and remember that a unit sold, traded or returned to a lessor still needs its file handled under the schedule.

Work orders, PM schedules, parts used, tire records and inspection reports often sit in a fleet maintenance system separate from the TMS and ELD. When that system is replaced, export the history with unit numbers and VINs so it can still be matched to the right truck or trailer.

Unlike driver files, maintenance histories are mostly company operating records with limited personal information. After technician and driver names are reviewed, they are often the strongest candidates in a carrier's archive for any later assessment.

What extends a retention period#

Federal minimums rarely end the analysis, because other obligations stretch retention for specific records. Build these extenders into the schedule as overrides that pause deletion until the owner of each override signs off.

• 1Litigation holds: a crash, cargo claim or employment dispute freezes every related log, video, file and email until counsel releases it.
• 2Insurance requirements: policies and claims adjusters may ask for logs, video and maintenance files beyond federal periods.
• 3Tax audits: fuel tax, registration and income tax records follow their own audit windows, set with your tax adviser.
• 4Shipper contracts: some customers require proof-of-delivery, temperature or seal records for periods they set.
• 5Open compliance reviews: keep everything in scope until a safety audit or investigation is formally closed.

Illustrative: a regional refrigerated carrier rebuilds its schedule#

Illustrative: a fictional regional refrigerated carrier discovers that its retention practice is whatever each system defaults to. The ELD account keeps logs for as long as the carrier stays a customer, dash cam video rolls off on the vendor default, DQ files are paper in the safety office, and the old maintenance system still holds unit histories for trucks sold years ago.

The COO adopts a schedule by record type, adds the dataset exclusion column and sets overrides for holds. DQ files are scanned and indexed with separation dates, the maintenance history is exported with VINs before the old system is retired, and ELD settings are reviewed against the schedule. When leadership later asks which records could ever be assessed for licensing, the exclusion column answers most of the question in a single meeting.

How SourceX uses the exclusion column#

SourceX starts from the same exclusion logic. Driver qualification files, medical and testing records, raw logs tied to named drivers and crash files are excluded from any package, and the remaining operating records, such as maintenance histories, dispatch exceptions and delivery records, are considered only after the Rights and Preparation steps of the SourceX five-step transaction.

Every package that proceeds carries a SourceX Evidence Packet with its provenance, licensing rights, permitted use, privacy record and release authorization. A retention schedule helps here as well, because it shows which records the carrier still holds for a stated purpose and which were already due for deletion.