Records
Fleet maintenance records: what to keep, and for how long
Every carrier subject to the Federal Motor Carrier Safety Regulations must systematically inspect, repair and maintain its vehicles, and must be able to prove it. The proof is the vehicle maintenance file. The rule is 49 CFR 396.3, and three related sections set their own retention periods. Here is what goes in the file, how long each piece stays, and how to organize it so an auditor finds what they ask for.
The duty behind the file
Section 396.3(a) requires every motor carrier to "systematically inspect, repair, and maintain" all motor vehicles subject to its control, or have that done. Parts and accessories must be in safe and proper operating condition at all times, including those in Part 393 and others that affect safety, such as frames, suspension, axles, wheels and rims, and steering. "Systematically" is the important word: an investigator looks for a program, meaning scheduled work that happens on schedule, not just repairs after breakdowns. A written preventive maintenance schedule is the usual way to show one.
Which vehicles need a file
Records are required for each motor vehicle the carrier controls for 30 consecutive days (396.3(b)). That threshold catches long-term leased and rented units, not only owned ones. A private motor carrier of passengers (nonbusiness) is exempt from the record requirement.
What 396.3(b) requires in each file
| Required record | What it means in practice |
|---|---|
| Vehicle identification: company number if marked, make, serial number, year | Unit number, make, VIN and model year on the first page of the file |
| The name of the person furnishing the vehicle, if the carrier does not own it | Lessor or rental company, with the lease reference |
| A means to indicate the nature and due date of the various inspection and maintenance operations to be performed | The vehicle's PM schedule: each task and when it is next due, by miles, hours or date |
| A record of inspection, repairs and maintenance, indicating their date and nature | Work orders and invoices, each dated, saying what was done; the odometer or engine-hour reading is good practice |
| For buses: a record of tests on pushout windows, emergency doors and emergency door marking lights | Those items must be inspected at least every 90 days (396.3(a)(2)) |
The second item is the one most often missing. A drawer of receipts shows what was done; it does not show what is due next. An auditor will ask how you know when each vehicle's next service is due.
How long each record is kept
| Record | Retention | Where | Rule |
|---|---|---|---|
| Inspection, repair and maintenance records (the vehicle file) | 1 year, and for 6 months after the vehicle leaves the carrier's control | Where the vehicle is housed or maintained | 396.3(c) |
| Driver vehicle inspection reports, repair certifications and the driver's review | 3 months from the date the report was prepared | Not specified | 396.11(a)(4) |
| Annual (periodic) inspection report | 14 months from the date of the report | Where the vehicle is housed or maintained | 396.21(b) |
| Evidence of the annual inspector's qualifications | While they perform annual inspections for the carrier, and 1 year after | Not specified | 396.19(b) |
Read the vehicle-file rule carefully. "1 year and for 6 months after the motor vehicle leaves the motor carrier's control" means a record must be held for a year, and a vehicle that is sold or returned keeps its file for six months after it goes. Many fleets simply keep the complete history of every vehicle for its life plus six months, which satisfies the rule and helps at resale and in warranty disputes; see fleet warranty claims.
These are the federal minimums under Part 396. Other records have their own periods, such as the fuel and distance records behind a fuel tax return (see fuel economy and IFTA), and your insurer, lender or state may require longer.
Paper, spreadsheet or software
Any of them can satisfy the rule. 49 CFR 390.32 allows records required by the FMCSRs to be generated and kept electronically, and allows electronic signatures, as long as the documents accurately reflect the required information and are capable of being retained. Whatever you use, the test is the same: can someone else, on a bad day, produce the file for one unit within minutes?
A vehicle file that survives an audit
| Section | Contents |
|---|---|
| 1. Identity | Unit number, make, VIN, year; owner or lessor if not owned; date placed in and taken out of service |
| 2. Schedule | Each PM task with its interval and next due date or reading |
| 3. Annual inspection | The current report and the previous one; who inspected |
| 4. Work history | Work orders and invoices in date order, each with the reading at the time |
| 5. Defects | DVIRs with defects, and their repair certifications, for the last three months |
| 6. Components and warranties | Tires, batteries and major parts fitted, with serials and warranty terms |
- One file per unit, including each trailer and converter dolly.
- Every entry dated, and every repair says what was done, not just "serviced".
- Overdue items are visible without reading the whole file.
- Records are kept where the vehicle is housed or maintained, or can be produced there.
- Files of sold or returned vehicles are held for at least six months after they leave.
In Cargovate, work orders are completed with the reading at which the work was done, and a completed work order cannot be reopened and signed off again.
Related: DVIR requirements · annual DOT inspection · maintenance cost per mile.
Last reviewed 2026-11-04