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ELD rules for small fleets: devices, exemptions and records

Helm PartnersUpdated Nov 4, 2026Sources checked Nov 4, 2026

This guide is general information, not advice on any policy.

Short answer

If your drivers must keep a record of duty status, they generally have to use an ELD (49 CFR 395.8). Paper logs are allowed only for drivers who log on 8 or fewer days in any 30, driveaway-towaway moves and trucks built before model year 2000. Keep logs and supporting documents for 6 months.

In this guide
  • Who must use an ELD
  • The four exemptions
  • Choosing a device
  • What goes in the cab
  • When an ELD malfunctions
  • Records and supporting documents
  • A fleet checklist
  • FAQ

For a fleet of 3 to 20 trucks, the ELD rule is less about the device and more about the records around it. Here is what the regulations require, read from the current eCFR.

Who must use an ELD

A carrier subject to Part 395 must require each driver to record duty status, and must install and require an ELD for that purpose (49 CFR 395.8(a)(1)). The driver sends logs to the carrier within 13 days (395.8(a)(2)). Hours limits are covered in hours of service for property carriers.

The four exemptions

  • Occasional logging. A driver who needs a record of duty status on no more than 8 days in any 30-day period may use paper logs.
  • Driveaway-towaway when the vehicle driven is part of the shipment.
  • Driveaway-towaway of a motor home or recreation vehicle trailer.
  • Older vehicles manufactured before model year 2000, as shown by the VIN on the registration.

Separately, drivers who meet the 150 air-mile short-haul conditions keep time records and no log at all (395.1(e)(1)). See the 150 air-mile short-haul exception.

Choosing a device

Providers self-certify their devices. Pick one from FMCSA's registered ELD list and check that it is not on the revoked list. Confirm that it can transfer data the way roadside officers ask for it.

What goes in the cab

Each truck carries an ELD packet (395.22(h)):

  • An instruction sheet for transferring logs to an officer.
  • An instruction sheet for reporting malfunctions and keeping records during one.
  • Blank paper log grids for at least 8 days.

When an ELD malfunctions

  • The driver gives the carrier written notice within 24 hours (395.34(a)).
  • The driver rebuilds the current 24 hours and previous 7 days on paper, unless the records can be pulled from the device.
  • Paper logs continue until the ELD is back in compliance.
  • The carrier corrects the malfunction within 8 days of discovery or the driver's notice (395.34(d)).

Records and supporting documents

Keep logs and supporting documents for at least 6 months (395.8(k)). Supporting documents include bills of lading or itineraries, dispatch and trip records, expense receipts tied to on-duty time, fleet messaging records, and payroll or settlement records (395.11). The carrier also keeps a back-up copy of ELD records on a separate device for 6 months (395.22(i)).

Hours of service violations count in the CSA system, and they are one of the first things reviewed in an audit. See CSA BASICs for small fleets and what underwriters look at in a trucking fleet.

A fleet checklist

  1. List every driver and decide who logs on an ELD, who logs on paper and who uses short-haul time records.
  2. Confirm each device is on the FMCSA registered list.
  3. Stock every cab with the ELD packet and 8 days of blank grids.
  4. Write a malfunction procedure and train drivers on it when you hire.
  5. Review unassigned driving time and edits each week.
  6. File supporting documents by driver and date, and keep them 6 months.
  7. Keep each driver's qualification file current alongside the logs.

Related: dry van trucking insurance requirements and all fleet trucking guides.

FAQ

Does every truck in my fleet need an ELD?

Every driver who must keep a record of duty status needs one unless an exemption applies (49 CFR 395.8(a)(1)). Drivers who qualify for the 150 air-mile short-haul exception keep time records instead of logs (395.1(e)(1)).

Can older trucks still use paper logs?

Yes, if the vehicle was manufactured before model year 2000, as shown by the VIN on its registration (395.8(a)(1)(ii)(A)(4)). Those drivers keep paper logs on the standard grid.

What happens if an ELD stops working on the road?

The driver notes the malfunction, tells the carrier in writing within 24 hours, rebuilds the current day and previous 7 days on paper if they are not retrievable, and keeps paper logs until the device is fixed. The carrier must fix or replace it within 8 days of learning about it (395.34).

How long do I keep ELD records?

At least 6 months, together with supporting documents such as bills of lading, dispatch records, expense receipts, fleet messaging records and payroll or settlement records (395.8(k); 395.11). The carrier also keeps a back-up copy on a separate device (395.22(i)).

How do I know an ELD is allowed?

Choose a device on FMCSA's registered ELD list and check the revoked list before you buy or renew. Providers self-certify, so FMCSA can remove a device that does not meet the rules.

This guide is general information, not advice on any policy. For your own operation, check the rules linked below or ask FMCSA.

Sources