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IRP

IRP Recordkeeping Audit Prep - 2026 Checklist

IRP audit volume is rising. The 4-year retention rule under §1015 is the foundation; specific document types matter for clean audit findings.

What changed

The International Registration Plan (IRP) audit-coverage requirement of 3% of registrants per jurisdiction continues to drive consistent audit volume. With 31 IRP jurisdictions across the US and Canadian provinces, most multi-state carriers face an IRP audit at some point in any given 5-year window.

The §1015 records-retention rule requires the carrier to maintain mileage source documents for the current registration year plus three preceding years. Audit findings often turn on whether the ELD state-line data, fuel receipts, and dispatch logs reconcile to within audit-tolerance bands.

What auditors look at

Mileage by jurisdiction reported on the IRP renewal vs the underlying source documents. The auditor sample-tests a quarter of trips against drivers' trip sheets or ELD reports. Discrepancies above 5% trigger expanded sampling.

Fuel receipts that don't match the dispatch log timing are a red flag - the auditor reads these as evidence the trip records aren't being maintained contemporaneously. Maintaining clean fuel receipts in chronological order is a low-effort, high-impact audit-prep step.

How to prep proactively

Run an internal mileage reconciliation quarterly. Pick a week of operations and reconcile reported miles to ELD and fuel receipts. Discrepancies are easier to fix three months out than two years later during an audit.

Centralize records in a single system. Carriers with ELD reports in one system, fuel receipts in another, and dispatch logs in a third often fail audit reconciliation simply because they can't produce documents quickly enough.

What to do next

Start a 90-day internal IRP-audit drill. Imagine the auditor arrives next quarter - pull a sample week from the prior year and reconstruct the records. The exercise surfaces gaps before the real audit. Our /guides/irp-registration-complete-guide page walks through audit prep in detail.

Read more

IRP Registration Complete Guide