DOT Audit Checklist
When a DOT auditor shows up, they’re checking five core areas. This article lists exactly what they look at in each, plus the violations that automatically fail you regardless of how well you perform elsewhere.
The Five Core Audit Areas
The FMCSA audits motor carriers on these five areas. Audit is conducted through a documented review of your records, not by inspecting vehicles or observing operations.
1. Driver Qualification Files (DQF)
The auditor will verify that your company maintains complete Driver Qualification Files for every driver on your payroll before they operate a vehicle.
What they check:
- A current, valid Commercial Driver’s License (CDL) for each driver
- Current Medical Examiner’s Certificate (FMCSA Form MCSA-5876) or the equivalent CDLIS medical certification record for CDL holders
- Driving record from the past 3 years (certified from the state where the license is issued)
- Previous employer history (work for previous carriers where the driver operated a commercial motor vehicle)
- Road test results, or evidence of waiver (if applicable)
- Any required endorsements (hazmat, double/triple trailers, passenger, etc.)
The files must be organized and in your office — auditors expect to pull out a file folder with a driver’s name on it and see all of this documentation inside.
Most common failure here: Drivers on the road without a copy of their CDL or medical certificate available in the vehicle, or DQF missing documents entirely.
2. Drug and Alcohol Testing Program
You must have a written, documented drug and alcohol testing program that is actively being followed.
What they check:
- A written policy describing your program (pre-employment, random, post-accident, reasonable suspicion)
- Documentation that random testing is actually happening on a schedule (FMCSA’s current annual random-testing minimums are 50% of drivers for drugs, 10% for alcohol)
- Records of test results and follow-up actions
- Evidence of compliance with reporting requirements (if a driver tests positive or refuses, that goes into a national Clearinghouse)
The rule is simple: You must have the program written down, and you must be following it. If you have drivers but no documented testing record, you fail.
Most common failure here: Having a written policy but no evidence tests are actually being conducted, or no knowledge of the federal Clearinghouse (which is now mandatory).
3. Hours of Service (HOS) Records
Your drivers must maintain records of duty status (logs), and those logs must be kept by the carrier and available for audit.
What they check:
- Electronic logs (ELDs) or paper logbooks, current and complete
- Logs cover all operating periods and match dispatch records, payroll, and vehicle maintenance records
- Proper use of duty statuses (on-duty, off-duty, sleeper berth, driving)
- Compliance with 11-hour driving limit, 14-hour on-duty limit, and 10-hour rest period
- Logs signed or certified as accurate by the driver
The files must match: If your payroll says a driver worked 60 hours last week but logs show 50, that’s a red flag. Auditors cross-check logs against dispatch, payroll, and maintenance records for consistency.
Most common failure here: Incomplete logs, logs that don’t match dispatch/payroll, or drivers operating past the 11-hour driving limit without a documented rest period.
4. Vehicle Maintenance
You must maintain a written vehicle maintenance program and keep records showing that program is being followed.
What they check:
- A written preventive maintenance plan (how often vehicles are serviced, what gets inspected)
- Maintenance and repair records for each vehicle (dates, work done, driver inspection reports)
- Documentation of pre-trip and post-trip inspections (Driver Vehicle Inspection Reports) and corrective actions
- Records of vehicle registrations, title, and inspection stickers
The records must show a pattern: If a vehicle goes 6 months without maintenance records, or a driver reports a brake issue on a DVIR but there’s no record of repair, the auditor will flag it.
Most common failure here: No written maintenance plan at all, or maintenance records that are incomplete or missing for some vehicles.
5. Insurance and Accident Records
You must have current, valid commercial auto insurance, and you must maintain records of accidents and claims.
What they check:
- Proof of current liability insurance coverage (minimum $750,000 for general freight haulers)
- Insurance policy declarations pages or certificates of insurance
- An accident register showing all crashes/incidents (even minor ones) and follow-up documentation
- Any investigation reports or claim files related to accidents
The register must be complete: FMCSA expects you to have a log of every accident involving a company vehicle, even if insurance didn’t pay out or there was no injury.
Most common failure here: No written accident register, or gaps in the record (accidents that happened but aren’t logged).
Automatic-Failure Violations (49 CFR §385.321)
These violations are so critical that a single one of these will end your audit immediately, regardless of your performance in other areas. You will fail.
These are pass/fail, not scoreable. The FMCSA considers them disqualifying.
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No drug and alcohol testing program. If you operate commercial vehicles but have no written, documented drug and alcohol program with evidence of testing, you automatically fail.
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No random testing program. If you have a drug/alcohol program but are not conducting random tests, you automatically fail.
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Driver operating without a valid CDL. If a driver on your payroll operated a commercial vehicle and you cannot produce a valid CDL on file, you automatically fail.
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Driver operating with a disqualified or revoked license. If a driver operated a vehicle and their CDL was suspended or revoked at the time, you automatically fail.
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Medically unqualified driver. If a driver operated without a current medical certificate on file, or if the certificate shows they were medically unqualified, you automatically fail.
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Operating without required insurance. If you cannot produce proof of valid commercial liability insurance, you automatically fail.
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Failure to maintain HOS records. If required drivers are operating but no hours of service records exist (no logs, no documentation of duty status), you automatically fail.
These are not negotiable. There is no “maybe” or “partial credit.” If any one of these applies to your operation at the time of audit, you will be found in violation and the audit is over.
How to Prepare Right Now
For Each Driver:
- Pull together a file folder with: current CDL, current medical certificate, past 3 years of driving records, and work history documentation.
- File it in a cabinet or folder labeled with the driver’s name.
- Verify that every driver on your payroll is in this file before they drive.
For Drug/Alcohol:
- Write down your testing policy (or formalize one if you don’t have it). Include: pre-employment, random schedule, post-accident, and reasonable suspicion testing.
- Set up random testing on a schedule. Document each test (results, date, driver name).
- Register with the federal Clearinghouse and check your drivers’ histories before hiring.
For Maintenance:
- If you don’t have one, write a vehicle maintenance schedule (when does each vehicle get serviced, what gets checked).
- Keep a maintenance log for each vehicle. After every repair, record the date, work done, and mileage.
- Require drivers to complete a pre-trip and post-trip inspection (DVIR) every day. Keep these in your office by vehicle.
For Hours of Service:
- If you don’t already use electronic logs, set up an ELD system (FMCSA-compliant; many options available).
- If you use paper logs, ensure every driver is keeping them complete and accurate, signing them daily.
- Cross-check logs against your dispatch and payroll. They must match.
For Insurance and Accidents:
- Print out your current insurance certificate and keep it in a visible place in your office.
- Create an accident register (a simple spreadsheet works) with columns for: date, driver, vehicle, location, description, injuries, damage, and insurance claim number.
- When an accident happens, log it immediately. Follow up with any police reports, photos, or witness statements, and keep all of these in a file.
What Comes Next
If you’re a brand-new carrier facing your first-ever audit, New Entrant Safety Audit explains the timeline and consequences of failing.
If you want to assess where your compliance stands right now, use the free Audit Readiness Checker tool — it scores your compliance across these five areas and flags what needs attention.
For specific articles on how to build these systems, see: