Two layers of records, not just the log itself
Hours of Service (HOS) is the federal rule that limits how many hours a CDL driver can drive and work in a day and a week — and it comes with its own, separate recordkeeping requirements.
Most drivers today record their record of duty status (RODS) electronically through an ELD, but the RODS is only half of it. FMCSA also requires supporting documents — bills of lading, dispatch records, fuel and expense receipts, payroll or settlement records, and electronic communication logs — that corroborate what the RODS shows. Both pieces have their own retention rules, and they're shorter than almost every other recordkeeping requirement covered in this guide series.
This isn't run by a separate agency the way IFTA or IRP are — it's core FMCSA regulation (49 CFR Part 395), but the recordkeeping details are easy to get wrong in practice even though the rules are well established.
The retention window is short, and the ELD provider isn't the safety net
RODS and supporting documents only have to be retained for 6 months — far shorter than the 3-to-4-year windows that apply to IFTA, IRP, accident registers, and Clearinghouse queries. If a dispute, a compliance review, or an insurance question reaches back further than expected, the official retention period may have already passed unless you kept your own copies.
There's also a common misconception worth correcting directly: the retention obligation belongs to the motor carrier, not the ELD provider. If you switch ELD vendors, a subscription lapses, or a provider changes its data policy, that doesn't automatically mean your compliance records are safe somewhere else. Keeping your own exported copies is what protects you if the vendor relationship changes.
What every driver should understand about HOS recordkeeping
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RODS and supporting documents must be retained for only 6 months from the date received — much shorter than most other retention periods in this guide series. Many carriers choose to keep records longer anyway, since compliance reviews and liability disputes can reach back further.
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Supporting documents fall into five categories: bills of lading/dispatch or trip records, expense receipts tied to on-duty-not-driving time, electronic mobile communication records, and payroll or settlement records. Up to 8 per 24-hour period are required; if more than 8 exist for a day, only the first and last generated need to be kept.
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Drivers must submit supporting documents to the carrier within 13 days of receiving them, and must keep a copy of their own RODS for the previous 7 consecutive days in their possession, available for inspection while on duty.
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The ELD provider isn't automatically your safety net. The retention obligation under this rule belongs to the motor carrier, not the ELD vendor — if you change providers or lose access to an account, you can lose your own compliance record unless it was exported and kept independently.
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Unassigned driving time on an ELD must be reviewed and assigned to the correct driver by the carrier. Leaving unassigned time unresolved is its own recordkeeping violation, separate from any underlying HOS issue.
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If the ELD malfunctions, specific steps apply: notify the carrier within 24 hours, reconstruct the RODS for the current 24-hour period plus the previous 7 days on paper logs (or from data you already have), and continue manual paper logs until the device is fixed. The carrier then has 8 days to repair, replace, or service the ELD.
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Reconstructed records don't have to be handwritten from scratch. A printed or electronic copy of the previous 7 days — a PDF, for example — is acceptable during a malfunction, but both the reconstructed records and any available ELD data must be shown to an inspecting officer together.
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Your ELD should be checked against FMCSA's registered ELD list, especially if FMCSA announces removals or revocations of specific devices.
Check That Your ELD Is Still Registered
FMCSA maintains a list of registered Electronic Logging Devices (ELDs) that meet the agency's minimum requirements. FMCSA may also remove or revoke ELDs from that list when a provider no longer meets those requirements.
Drivers and carriers should periodically confirm that the ELD being used is still on FMCSA's registered ELD list. If an ELD is removed from the registered list, the motor carrier may need to discontinue using that device, use paper logs or logging software temporarily if allowed by FMCSA, and replace the device by the FMCSA deadline.
Drivers should keep a copy of ELD records, notices, screenshots, vendor communications, and replacement records for their own files. Clear To Roll can help drivers organize documents and reminders, but Clear To Roll does not verify whether an ELD is compliant or registered.
Current FMCSA Update: July 9, 2026
On July 9, 2026, FMCSA removed 10 ELDs from its registered devices list. Motor carriers using those revoked devices have until September 8, 2026 to replace them with a compliant registered ELD.
On or after September 8, 2026, continued use of one of the revoked devices may result in a “No record of duty status” violation under 49 CFR 395.8(a)(1), and drivers may be placed out of service.
The 10 revoked ELDs are:
- Ontime Logs iosix
- Porter ELD
- EV ELD IOSIX
- PREMIERRIDE LOGS
- 305 ELD
- LAST MINUTE ELD
- Zee HOS Compliance
- Light and Travel ELD
- 2BRO ELD
- TT ELD 40
Source: FMCSA ELD News and Events. View FMCSA ELD updates.