New Entrant Safety Audit, compliance reviews, IRP, IFTA. Send us the notice: we break it down, assemble the documents, and handle the auditor from there.
The notice arrives without drama: for the New Entrant Safety Audit, FMCSA itself tells you by phone or mail which format you got (onsite at your place of business, or offsite with documents submitted electronically). Investigations come as a letter from FMCSA; IRP and IFTA audits come from your base state. Most owners then follow one of two instincts: ignore it, or rush everything to the auditor at once. Both are bad. Ignoring it leads to revocation, and a raw, unchecked package creates violations the auditor was not even looking for.
Our approach: send us the notice, and we talk to the auditor from there. That is legal and normal: in FMCSA proceedings a party may appear in person, by counsel, or by other representative, and the representative files a notice of appearance (49 CFR 386.4(a)). The auditor gets one clean, pre-checked package and one point of contact who understands what was requested and why.
Below is a comparison across five parameters. Every figure comes from primary sources: 49 CFR Part 385, the IRP Plan, and the IFTA manuals.
| Parameter | New Entrant Safety Audit | Investigation / Compliance Review | IRP audit | IFTA audit |
|---|---|---|---|---|
| Who runs it | An FMCSA-certified auditor, onsite or offsite (documents via the NEWS system, by mail, or by fax) | FMCSA: offsite investigation, onsite focused, or onsite comprehensive | Your IRP base jurisdiction (the state where the fleet is registered) | Your IFTA base jurisdiction (the state that issued the license) |
| Trigger | New entrant status itself: 18 months of monitoring (49 CFR 385.307), the audit usually after 3 months of operations and within 12 months for property carriers | Safety data: SMS/BASIC performance, crashes, complaints; can happen at any time | Scheduled sampling: on average 3% of fleets per year (IRP Plan Section 1025) | Scheduled sampling: on average 3% of accounts per year, at least 15% low-distance and 25% high-distance (Audit Manual A250, A260) |
| Documents | Drivers list, CDLs, MVRs, medical certificates, 30 days of RODS plus the ELD output file, vehicle list with VINs, annual inspections, proof of insurance (MCS-90), drug and alcohol program, accident register | The same areas plus anything the investigator requests for the problem BASICs; an offsite investigation runs on documents alone | IVDR/GPS trip data, odometer readings, distance per jurisdiction, monthly and quarterly summaries; kept 3 years after the close of the registration year | Trip data and fuel receipts by quarter; kept 4 years from the return's filing date or due date (P510) |
| Deadline pressure | After a failure, the CAP is due in 60 days (property) or 45 days (passenger, HM); out-of-service from Day 61 / Day 46 | A proposed Unsatisfactory becomes final in 60 days (45 for passenger and HM carriers); prohibitions start on Day 61 / Day 46 | 30 calendar days to produce records after a written request; at least 30 days to appeal the findings | Records on written demand; without them the assessment follows the P570 formula immediately |
| Worst outcome | Revocation of the new entrant registration plus out-of-service; reapplying no sooner than 30 days later, with a fresh 18-month monitoring cycle | Final Unsatisfactory: an OOS order and revocation of operating authority (49 U.S.C. 13902); operating after a final Unsat brings a federal civil penalty for every day of operation | An assessment of 20% / 50% / 100% of the fleet's annual apportionable fees (first / second / third offense, IRP Plan Section 1015) | Fleet recalculated at 4.00 MPG or reported MPG cut by 20%, tax-paid credits disallowed, IFTA license revoked (P570) |
One nuance about investigations: an offsite investigation cannot end in a safety rating, only in penalties. A Satisfactory, Conditional, or Unsatisfactory rating can come only from an onsite review. CSA interventions themselves run in three tiers: Early Contact (warning letters, targeted roadside inspections), Investigation (offsite, onsite focused, onsite comprehensive), and Follow-On (Cooperative Safety Plan, Notice of Violation, Notice of Claim with civil penalties, an operational OOS order). Details: csa.fmcsa.dot.gov. For new entrant audits, many reviews now run offsite; the official word on formats and the NEWS system is at ai.fmcsa.dot.gov.
The calendar that actually shuts companies down. Every row is verified against the text of the rules.
| Deadline | What happens | Rule |
|---|---|---|
| 45 days after audit completion | FMCSA must send the written pass/fail notice for the new entrant audit | 49 CFR 385.319(b) |
| 60 days / 45 days | Corrective Action Plan due after a failure: 60 for property carriers, 45 for passenger and HM carriers | 49 CFR 385.319(c) |
| +60 days / +10 days | Possible CAP extensions: up to 60 days for a good-faith effort (property); up to 10 days for passenger/HM, and only if evidence was already submitted | 49 CFR 385.323 |
| Day 61 / Day 46 | Registration revoked and out-of-service order effective if no acceptable CAP | 49 CFR 385.325 |
| 90 days (15 days to beat the OOS date) | Administrative review of a failed new entrant audit; decided within 45 days (30 for passenger/HM) | 49 CFR 385.327 |
| 30 days | Response to an expedited-action notice (driver without a CDL, positive test, operating without insurance, 50%+ OOS rate on 3+ inspections in 90 days); no response means revocation | 49 CFR 385.308 |
| 30 days after the review | Safety rating (Satisfactory / Conditional / Unsatisfactory) must be issued after a compliance review | 49 CFR 385.9, 385.11(a) |
| 60 days / 45 days | A proposed Unsatisfactory becomes final (60 for most carriers, 45 for passenger and HM); up to 60 extra days for good faith | 49 CFR 385.11(c), 385.13(a) |
| 30 calendar days | Produce IRP records after a written request; otherwise a 20/50/100% assessment of apportionable fees | IRP Plan Section 1015 |
| 3 years | IRP record retention after the close of the registration year | IRP Plan Section 1000 |
| 4 years | IFTA record retention from the return's filing date or due date, whichever is later | IFTA Procedures Manual P510 |
| At least 30 days | Written appeal of IRP audit findings | IRP Plan Section 1065 |
Automatic failure comes from violating any one of 16 regulations in the table to 49 CFR 385.321(b). For most of them a single occurrence is enough:
Two items are measured against a 51%-of-records threshold: failing to require records of duty status (395.8(a)) and using vehicles without periodic inspection (396.17(a)). A separate trap is the expedited-action list in 49 CFR 385.308: a driver without a valid CDL, a positive test, operating without required insurance, or a 50%+ out-of-service rate based on at least 3 inspections within 90 consecutive days can bring an expedited audit or a demand for written corrective action, with only 30 days to respond.
If a carrier refuses the audit outright, FMCSA gives 10 days to agree in writing; after that comes revocation. After a revocation, the carrier may reapply no sooner than 30 days later, must fix the deficiencies, and restarts the full 18-month monitoring cycle (49 CFR 385.337, 385.329T).
Casper runs 3 trucks and is still a new entrant. He handled the offsite audit notice himself: started emailing the auditor, sent the package in pieces, and could not document that his drivers were enrolled in a consortium's random testing pool, which risks automatic failure under 382.305. Result: a failed audit and a notice pointing toward revocation. That is where we came in: rebuilt the complete package, gathered the evidence of correction (the consortium agreement, the random pool roster, completed tests), prepared the Corrective Action Plan, and filed it before the 60-day deadline. The revocation never took effect and the company kept running. The second half of the job: we moved Casper's files onto the ongoing Safety Compliance subscription, so the package stays audit-ready through the rest of the 18-month monitoring window.
Audit representation costs $499: a one-time fee that covers one audit from the notice review to closure. The fee includes the document pre-check, all communication with the auditor, and the Corrective Action Plan if one is needed. The first step is free: send us the notice and we assess it at no charge, then confirm the scope before you pay. No surprises mid-audit.
What sits next to this service:
Go deeper: the DOT audit types explained, the audit document checklist, how quarterly IFTA filing works.
These are the exact questions owners type into Google and ChatGPT about DOT audits, answered with the numbers, deadlines, and rule sections.
Anyone you designate: the owner, a lawyer, or a compliance consultant. In formal FMCSA proceedings a party may appear in person, by counsel, or by other representative, and the representative files a notice of appearance (49 CFR 386.4(a)); for a safety audit or investigation it is enough to tell the auditor in writing who speaks for the company. The auditor still needs the carrier's records, so the representative works from your DQ files, ELD data, maintenance records, and drug and alcohol program, not from memory. In practice the job is three things: read the notice correctly, pre-check the package against the 16 automatic-failure items in 49 CFR 385.321(b), and keep every exchange with the auditor in one written channel. That is what TruckerNavi's DOT Audit Representation does for a flat $499 per audit; the notice assessment itself is free at (315) 871-0833.
File a written request for a rating change under 49 CFR 385.17 with proof that the violations behind the Conditional rating are fixed. The request goes to the FMCSA Service Center for your principal place of business and must describe each corrective action with evidence: new policies, completed training, updated DQ files, maintenance records, test results. The rule sets no review deadline for Conditional requests; the 30-day and 45-day review windows in 385.17(e) apply only to carriers with an Unsatisfactory rating, so a Conditional upgrade can take months. The other path, administrative review under 49 CFR 385.15, is only for a rating that was wrong on the facts and must be requested within 90 days. The step-by-step process, evidence list, and common mistakes are in our Conditional rating upgrade guide. TruckerNavi assembles the evidence and files the 385.17 request as part of the $499 representation.
Expect one audit within your first 12 months of operation, and no sooner than about 3 months in, inside an 18-month monitoring period (49 CFR 385.307). FMCSA tells you whether it runs onsite or offsite; offsite documents are uploaded through the New Entrant Web System (NEWS), sent from the ELD by web service, or faxed with the NEWS cover sheet. The auditor asks for your drivers list, CDLs, MVRs, medical certificates, records of duty status with the ELD output file, vehicle list, annual inspections, proof of insurance, drug and alcohol records, and the accident register. The written pass or fail notice arrives within 45 days of completion (49 CFR 385.319(b) and (c)); a fail starts the 60-day Corrective Action Plan clock. The full walk-through is in what happens during a DOT audit; once the notice is in your hands, TruckerNavi represents you for $499.
Ten groups of records, following FMCSA's Safety Audit Resource Guide: (1) drivers list with hire dates; (2) CDLs; (3) MVRs; (4) medical examiner's certificates; (5) records of duty status for the period requested, with supporting documents and the ELD output file; (6) vehicle list with unit numbers, VINs, plates, and state; (7) periodic (annual) inspection reports; (8) proof of insurance such as the MCS-90 endorsement; (9) drug and alcohol program documents: pre-employment tests, consortium enrollment, the random pool roster; (10) the accident register. Investigations add whatever the investigator requests for the problem BASICs. The full printable version with retention periods is at the DOT audit document checklist. Pre-checking these ten groups before anything reaches the auditor is the core of TruckerNavi's $499 audit representation.
$499 at TruckerNavi: a flat one-time fee that covers one audit from the notice review to written closure, including the document pre-check, all communication with the auditor, and the Corrective Action Plan if the audit is failed. The notice assessment before you pay is free. Nothing in this fee goes to FMCSA: it is TruckerNavi's service fee only, and FMCSA's published fees cover registration ($300 per authority) and reinstatement ($80), not the audit. For comparison, here is where the number sits next to the related TruckerNavi services:
| Service | Price | When it fits |
|---|---|---|
| DOT Audit Representation | $499 one-time | A notice has arrived; one audit from notice to closure |
| Mock DOT Audit | $399 one-time | No notice yet; dress rehearsal across the same areas |
| Safety Compliance BASIC | $99/month, 1 truck | Files kept audit-ready year-round; starts after a free trial week |
| Safety Compliance START | $189/month, 2-3 trucks | DQ files, drug and alcohol, CSA monitoring |
| Safety Compliance PREMIUM | $499/month | Personal manager, mock DOT audit twice a year |
| IFTA filing | Included in the Safety Compliance subscription | Distance and fuel records kept the way an IFTA auditor reads them |
To confirm the scope for your notice, call (315) 871-0833.
16 regulations, listed in the table to 49 CFR 385.321(b); violating any one of them fails the audit. For most, a single occurrence is enough: no alcohol and drug testing program (382.115), a driver with an alcohol concentration of 0.04 or greater on a safety-sensitive function (382.201), a driver who refused a test (382.211) or tested positive (382.215) still driving, no random testing program (382.305), knowingly using a driver without a valid CDL (383.23(a)), no minimum insurance (387.7(a)), operating a vehicle placed out of service before repairs (396.9(c)(2)). Two items use a 51%-of-records threshold: not requiring records of duty status (395.8(a)) and vehicles without periodic inspection (396.17(a)). TruckerNavi runs your package against all 16 before submission as part of the $499 representation; the same checklist drives the $399 Mock DOT Audit.
Yes, in two ways, both on a fixed calendar. A failed New Entrant Safety Audit without an accepted Corrective Action Plan ends in revocation and an out-of-service order on Day 61 (Day 46 for passenger and HM carriers) under 49 CFR 385.325. A compliance review that ends in a final Unsatisfactory rating brings an out-of-service order and revocation of operating authority under 49 CFR 385.13, effective 60 days after the proposed rating, 45 for passenger and HM carriers. Expedited actions under 49 CFR 385.308 (no CDL, a positive test, no insurance, a 50%-or-higher out-of-service rate on 3 or more inspections in 90 days) can trigger an early audit or a demand for corrective evidence with 30 days to respond. A revoked new entrant reapplies no sooner than 30 days later and restarts the 18-month cycle (49 CFR 385.329). Keeping those clocks is what TruckerNavi's $499 representation is for: (315) 871-0833.
The legally fixed part is 30 days: after a compliance review FMCSA must issue the safety rating, Satisfactory, Conditional, or Unsatisfactory, within 30 days (49 CFR 385.9(b), 385.11(a)). The fieldwork itself depends on format: an offsite investigation runs entirely on the documents you submit and cannot produce a rating; an onsite focused review covers the problem BASICs; an onsite comprehensive review covers every area and takes longer, usually a matter of days that scales with fleet size and how fast records are produced. If the proposed rating is Unsatisfactory, it becomes final 60 days later (45 for passenger and HM carriers), with up to 60 extra days for a documented good-faith effort (49 CFR 385.11(c), 385.13(a)). TruckerNavi's $499 representation covers the full span, from the first document request to the written rating.
No, FMCSA does not require one: you may handle the audit yourself, through counsel, or through another representative (49 CFR 386.4(a)). The question is whether your package survives the 16 automatic-failure items in 49 CFR 385.321(b), where a single missing random pool roster or one expired medical certificate on a working driver is enough to fail. A consultant earns the fee in three places: reading what the notice actually requests, finding and lawfully fixing gaps before submission, and answering the auditor in writing so that a casual remark does not become a finding. If you want a second pair of eyes without a notice, the Mock DOT Audit is $399; once a notice exists, TruckerNavi's representation is $499, and the first read of the notice is free.
You get a written failure notice within 45 days of the audit and 60 days from that notice to file a Corrective Action Plan (45 for passenger and HM carriers) under 49 CFR 385.319(c). The plan shows each violation, the fix, and the evidence; FMCSA can extend it by up to 60 days for a good-faith effort (10 days for passenger and HM, 49 CFR 385.323). With no acceptable plan on file, registration is revoked and an out-of-service order takes effect on Day 61 or Day 46 (49 CFR 385.325). Administrative review is available within 90 days, or within 15 days of the notice if you want a decision before the out-of-service date (49 CFR 385.327). More in what happens if you fail the audit. TruckerNavi writes and files the plan within the $499 representation.
Do not improvise with the auditor. Send us the notice: we identify the audit type, the document list, and the deadlines. The notice assessment is free, and from there we talk to the auditor.
Within the first 12 months for property carriers (49 U.S.C. 31144(g)), usually after 3 months of operations. New entrant monitoring runs 18 months total (49 CFR 385.307).
A violation of any one of 16 regulations in the table to 49 CFR 385.321(b): no testing program, a driver without a valid CDL, no minimum insurance, and others. Most trigger failure on a single occurrence.
60 days from the notice date for property carriers, 45 days for passenger and HM carriers (49 CFR 385.319(c)). Without an accepted CAP, revocation and out-of-service hit on Day 61 or Day 46.
Yes. Request administrative review within 90 days, and within 15 days if you need a decision before the out-of-service date (49 CFR 385.327 for new entrants, 385.15 for ratings).
An offsite investigation runs remotely from documents: penalties are possible, but no safety rating. Only an onsite review can produce a Satisfactory, Conditional, or Unsatisfactory rating.
The jurisdiction recalculates your fleet at 4.00 MPG or cuts your reported MPG by 20% (IFTA Procedures Manual P570), may disallow tax-paid fuel credits, and can revoke the IFTA license. Rule texts: iftach.org.
If no records are produced within 30 days of a written request: an assessment of 20% of the fleet's apportionable fees, 50% for a second offense, 100% for a third (IRP Plan Section 1015, irponline.org).
Send the notice on WhatsApp: we assess it free and list the documents and deadlines. Representation is a flat $499. We reply within 15 minutes.