Complete DOT Audit Checklist for Small Fleets (2025)

A DOT audit notification strikes fear into many fleet operators. The Federal Motor Carrier Safety Administration (FMCSA) conducts compliance reviews to ensure motor carriers operate safely and follow federal regulations. Missing documentation or compliance gaps can result in penalties ranging from $1,000 to $16,000+ per violation—and in severe cases, an unsatisfactory safety rating that shuts down your operation.

The good news: DOT audits follow a predictable structure. Auditors examine the same six compliance areas for every carrier. With proper preparation and organization, you can approach your audit with confidence rather than anxiety.

This guide provides a complete DOT audit checklist based on FMCSA's compliance review procedures, updated for 2025. Whether you're facing your first audit or want to improve your compliance program, use this checklist to identify gaps before auditors do.

What is a DOT Audit?

A DOT audit—officially called a Compliance Review (CR)—is a comprehensive examination of a motor carrier's operations by FMCSA investigators. The audit evaluates whether a carrier complies with Federal Motor Carrier Safety Regulations (FMCSRs) and Hazardous Materials Regulations (HMRs) if applicable.

Unlike roadside inspections that examine individual vehicles and drivers, compliance reviews examine your entire operation: safety management systems, driver qualification procedures, vehicle maintenance programs, and operational records.

Types of DOT Audits

Comprehensive Compliance Review: A full examination of all six compliance areas. Typically triggered by safety concerns, complaints, or poor CSA scores.

Focused Compliance Review: Examines specific compliance areas based on identified concerns. May focus only on driver qualification files or hours of service, for example.

New Entrant Safety Audit: Required for all new motor carriers within 18 months of receiving operating authority. Focuses on verifying the carrier understands and follows safety regulations.

What Triggers a DOT Audit?

FMCSA prioritizes carriers for compliance reviews based on:

• High CSA Scores: Carriers with Safety Measurement System (SMS) scores above intervention thresholds in any BASIC category
• Crash History: Recent DOT-recordable crashes, especially those involving fatalities or injuries
• Complaints: Reports from drivers, shippers, or the public about safety violations
• Roadside Inspection Results: High out-of-service rates or patterns of violations
• New Entrant Status: All new carriers receive a safety audit within 18 months
• Random Selection: FMCSA conducts some audits randomly to maintain oversight

The Six DOT Audit Compliance Areas

Every DOT compliance review examines six specific areas. Understanding what auditors look for in each area is the first step to passing your audit.

Area 1: General Compliance Checklist

This area covers your authority to operate as a motor carrier and basic business compliance.

Required Documents

• USDOT Number: Current registration with biennial update completed (MCS-150)
• Operating Authority (MC Number): Active authority for the type of operation conducted
• Insurance Filing: BMC-91 or BMC-91X on file with FMCSA ($750,000 minimum for general freight)
• BOC-3 Filing: Designation of process agent in each state where you operate
• UCR Registration: Unified Carrier Registration current for the registration year
• IRP Registration: International Registration Plan credentials (if operating interstate)
• IFTA License: International Fuel Tax Agreement credentials (if operating interstate)
• Marking Requirements: Proper display of USDOT number on vehicles (§390.21)

Common Violations

Key Takeaway: Verify your USDOT registration, insurance filings, and operating authority are current before any audit. These are easy wins—or easy violations.

Area 2: Driver Qualification File Checklist

Driver qualification files (DQFs) are often the most scrutinized area during DOT audits. Auditors will request files for a sample of your drivers—typically 10% of your fleet or all drivers if you have fewer than 20.

Required Documents in Each DQF (§391.51)

• Driver Application (§391.21): Complete employment history for past 3 years with no gaps exceeding 1 month
• Previous Employer Verification (§391.23): Safety performance history from all DOT-regulated employers for past 3 years
• MVR (§391.23): Motor vehicle record from every state where driver held a license in past 3 years
• Medical Certificate (§391.43): Current medical examiner's certificate (maximum 24-month validity)
• Road Test Certificate or CDL (§391.31): Documentation that driver is qualified to operate the vehicle type
• Annual MVR (§391.25): Motor vehicle record pulled within past 12 months
• Annual Review (§391.25): Signed certification that driver's safety performance was reviewed
• Clearinghouse Query (§382.701): Pre-employment query and annual limited queries

For a complete breakdown of DQF requirements, see our Driver Qualification File Checklist.

Common Violations

Key Takeaway: Review every driver file quarterly to catch expirations before they become violations. One expired medical certificate can result in a $1,000+ fine.

Area 3: Hours of Service Checklist

Hours of service (HOS) violations are among the most common findings in DOT audits. Auditors examine ELD records and supporting documents to verify drivers comply with driving time limits.

Required Records

• ELD Records (§395.8): Electronic logging device data for all drivers operating CMVs
• Supporting Documents (§395.11): Bills of lading, delivery receipts, fuel receipts, toll receipts that corroborate ELD records
• Shipping Documentation: Records showing the commodity transported, origin/destination, and dates
• Driver Logs (if applicable): Paper logs for drivers exempt from ELD mandate
• Time Records: Documentation of driver start times, end times, and rest periods

What Auditors Check

• 11-hour driving limit compliance
• 14-hour on-duty limit compliance
• 30-minute break requirement
• 60/70-hour weekly limits
• 34-hour restart compliance (if used)
• Log edits and supporting documentation for changes
• Unassigned driving time on ELDs

Learn more about HOS requirements in our Hours of Service Complete Guide.

Key Takeaway: Review ELD records weekly to identify and correct violations before audit. Pay special attention to unassigned driving time and log edit documentation.

Area 4: Vehicle Maintenance Checklist

A systematic vehicle maintenance program is required under §396. Auditors verify you have processes to keep vehicles safe and maintain required documentation.

Required Documentation

• Driver Vehicle Inspection Reports (DVIR) (§396.11): Pre-trip and post-trip inspection reports for every CMV operated
• DVIR Certification (§396.11): Documentation that defects were repaired before vehicle returned to service
• Annual Inspections (§396.17): Periodic inspection by qualified inspector within past 12 months for each vehicle
• Maintenance Records (§396.3): Records of all inspections, repairs, and maintenance for each vehicle
• Brake Adjustment Records: Documentation of brake inspections and adjustments
• Tire Records: Documentation that tires meet minimum tread depth requirements

Record Retention Requirements

Key Takeaway: Maintain a vehicle file for each unit with annual inspection, maintenance history, and recent DVIRs. Auditors will check specific vehicles against your records.

Area 5: Drug and Alcohol Testing Checklist

FMCSA requires motor carriers to maintain a comprehensive drug and alcohol testing program for all safety-sensitive employees. This is a heavily scrutinized area with significant penalties for non-compliance.

Required Program Elements

• Written Policy (§382.601): Drug and alcohol policy distributed to all drivers
• Pre-Employment Testing (§382.301): Negative drug test before any driver operates a CMV
• Random Testing (§382.305): Random drug (50%) and alcohol (10%) testing program
• Post-Accident Testing (§382.303): Testing following DOT-recordable accidents
• Reasonable Suspicion Testing (§382.307): Testing when supervisor has reasonable suspicion of drug/alcohol use
• Return-to-Duty Testing (§382.309): Testing before driver returns after violation
• Follow-Up Testing (§382.311): Unannounced testing after return to duty

Clearinghouse Requirements (§382.701)

• Pre-employment query for all new drivers (full or limited with consent)
• Annual limited query for all current drivers
• Full query if limited query shows record exists
• Report all positive tests, refusals, and violations to Clearinghouse

For detailed testing requirements, see our FMCSA Drug and Alcohol Testing Guide.

Key Takeaway: Document every aspect of your drug and alcohol program. Maintain training records for supervisors, testing documentation, and Clearinghouse query results for all drivers.

Area 6: Accident Register Checklist

Motor carriers must maintain records of all DOT-recordable accidents and ensure proper post-accident testing is conducted.

Required Documentation

• Accident Register (§390.15): Record of all DOT-recordable accidents for past 3 years
• Accident Information: Date, location, driver name, fatalities, injuries, hazmat release
• Post-Accident Drug Test (§382.303): Required when accident meets testing thresholds
• Post-Accident Alcohol Test (§382.303): Required within 8 hours of accident (if applicable)
• Copies of Accident Reports: Police reports, insurance claims, internal investigation documents

DOT-Recordable Accident Definition

An accident is DOT-recordable if it involves a commercial motor vehicle and results in:

• A fatality
• An injury requiring immediate medical treatment away from the scene
• A vehicle being towed from the scene due to disabling damage

Key Takeaway: Maintain a separate accident register with all required information. Ensure post-accident testing is conducted within required timeframes—8 hours for alcohol, 32 hours for drugs.

What Happens During a DOT Audit?

Understanding the audit process helps you prepare effectively and reduces anxiety.

Before the Audit

1. Notice: You'll receive written notification 3-5 business days before an onsite audit (except in urgent safety situations)
2. Document Request: The notice specifies which records to have available
3. Preparation: Gather all requested documents and organize them by compliance area

During the Audit

1. Opening Conference: Auditor explains the process and what they'll examine
2. Document Review: Auditor examines records in each compliance area
3. Driver File Review: Auditor selects random driver files to examine in detail
4. Vehicle Review: Auditor may inspect vehicles and verify maintenance records
5. Interviews: Auditor may speak with drivers and safety personnel
6. Closing Conference: Auditor summarizes findings and explains next steps

After the Audit

1. Written Report: You'll receive a detailed report of findings within 30-45 days
2. Safety Rating: If applicable, a safety rating (Satisfactory, Conditional, Unsatisfactory) is assigned
3. Corrective Action Plan: You must address violations within specified timeframes
4. Civil Penalties: If violations are cited, you may receive a Notice of Claim with proposed penalties

DOT Audit Penalty Reference

Understanding potential penalties helps prioritize compliance efforts.

Note: Penalty amounts are adjusted annually. Current maximums effective 2025 per FMCSA civil penalty inflation adjustments.

Frequently Asked Questions

How often do DOT audits occur?

There's no set schedule for DOT audits. Carriers with high CSA scores, crash history, or complaints may be audited more frequently. New entrant carriers receive a mandatory safety audit within 18 months of registration. Some carriers go years without an audit, while others may face multiple reviews.

Can I refuse a DOT audit?

No. Motor carriers are required by law to cooperate with FMCSA compliance reviews. Refusing an audit or failing to provide requested records can result in an automatic Unsatisfactory safety rating and civil penalties. If you're operating under FMCSA authority, you've agreed to submit to compliance reviews.

How long does a DOT audit take?

A typical onsite compliance review takes 1-3 days depending on your fleet size and the scope of the review. Larger fleets or focused reviews on multiple problem areas may take longer. The auditor will provide an estimated timeline during the opening conference.

What happens if I fail a DOT audit?

Failing an audit can result in a Conditional or Unsatisfactory safety rating. A Conditional rating allows you to continue operating but requires corrective action. An Unsatisfactory rating means you must cease operations until issues are resolved. Additionally, you'll face civil penalties for violations discovered and may receive an Out-of-Service order.

How can I check my CSA scores before an audit?

Visit the FMCSA SMS website to view your Safety Measurement System scores. Monitoring your CSA scores regularly helps you identify compliance areas that may trigger an audit and allows you to address issues proactively.

Do I need a lawyer for a DOT audit?

Most carriers don't need legal representation for routine compliance reviews. However, if you're facing serious violations, have a history of non-compliance, or receive an Unsatisfactory rating, consulting a transportation attorney is advisable before responding to penalty notices or challenging findings.

Checklist: 30-Day DOT Audit Preparation

If you receive notice of an upcoming audit, use this timeline to prepare:

Maintain Audit-Ready Status Year-Round with FleetCollect

Preparing for a DOT audit shouldn't require weeks of frantic document gathering. The most successful carriers maintain audit-ready compliance programs that continuously monitor requirements and flag issues before they become violations.

FleetCollect helps small fleets maintain continuous compliance:

Automated Expiration Tracking:

• Receive alerts 90, 60, and 30 days before medical certificates, CDLs, and annual inspections expire
• Never let a driver operate with expired credentials
• Track annual review and MVR due dates automatically

Centralized Document Storage:

• Store all DQF documents in one secure, cloud-based location
• Pull complete driver files instantly during audits
• Organize documents by FMCSA regulation citations

Compliance Dashboard:

• See your entire fleet's compliance status at a glance
• Identify missing documents before auditors do
• Generate audit-ready reports in seconds

Pass Your DOT Audit with Confidence

DOT audits don't have to be stressful. When you understand what auditors examine and maintain organized records in each compliance area, the audit becomes a validation of your safety program rather than a source of anxiety.

Use this checklist to evaluate your current compliance status. Address gaps proactively—don't wait for an audit notice to discover missing documents or expired certifications. The carriers who pass audits consistently are those who treat compliance as an ongoing process, not a periodic scramble.

Whether you manage compliance manually or use fleet compliance software like FleetCollect, the goal is the same: complete, organized, accessible records that demonstrate your commitment to safety and regulatory compliance.