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Erica Wall is a senior copywriter with almost 10 years experience turning complex tech and transportation speak into understandable English. Forever on the reader's side, her first responsibility is ensuring clarity and accuracy first, cleverness second. When she's away from the keyboard, Erica usually has her nose in a good book.
Summary: Most fleets subject to the ELD mandate already use electronic logging devices, yet Hours-of-Service (HoS) violations remain common. Compliance gaps often stem from exemption misunderstandings, paper-log processes, delayed record reviews and limited visibility into driver activity. This guide explains where HoS oversight breaks down, how to audit compliance risks and what to look for in ELD software for trucking fleets that supports stronger fleet-wide visibility.
Read time: 13 min
By December 2019, the Federal Motor Carrier Safety Administration’s (FMCSA’s) ELD mandate was in full effect. Carriers subject to the rule were required to use compliant electronic logging devices (ELDs) to document their drivers’ hours of service. No more transition period, no more paper logs, and no more grandfathered automatic on-board recording devices (AOBRDs). Today, most carriers and owner-operators subject to the ELD mandate already use ELD for trucking fleets, but hours-of-service (HoS) violations remain a problem. A big problem.
During the 2026 Commercial Vehicle Safety Alliance (CVSA) International Roadcheck, HoS violations were the second reason drivers were issued an out-of-service (OOS) violation. And it was a close race for first.
For several reasons, including that some fleets still operate under FMCSA exemptions, others temporarily use paper logs when an ELD malfunctions, and others still rely on manual processes. Then there are the complex regulations themselves; some fleet operators think they qualify for an exemption when they don’t.
Regardless of their reason, operating without ELD software reduces visibility into their drivers’ true hours of service. Limited visibility opens the door for HoS violations. Delayed paper log reviews, inconsistent documentation and fragmented records limit compliance oversight and make identifying violation risks more difficult. A fleet manager or driver may not see the problem on a paper log, but a roadside inspection officer will. Violations apply to carriers and their truck drivers, including owner-operators.
This guide explains where HoS compliance breaks down and how to audit those risks for stronger owner-operator and fleet management practices.
What are some need-to-know terms? Before reading further, here's a short list of acronyms to know as you go.
Also feel free to reference Code of Federal Regulations 49 CFR Part 395, which contains the official FMCSA Hours of Service of Drivers regulations.
Because as you can see by the 2026 CVSA International Roadcheck results, compliance challenges persist.
The official Code of Federal Regulations 49 CFR Part 395 sets an 11-hour driving limit. The regulation also outlines specific additional requirements and limitations on driver hours. An HoS violation can result in civil penalties of up to $19,246 per violation for motor carriers and up to $4,812 per violation for drivers, depending on the violation. Knowingly falsifying records can trigger penalties of up to $15,846. See Appendix B to Part 386: Penalty Schedule, Violations and Monetary Penalties for details.
Key takeaway? Violations are expensive and still common.
Some carriers and owner-operators operate under valid exemptions. Others feature mixed operations where exempt and non-exempt drivers follow different recordkeeping requirements.
HoS compliance is complex and requires accurate tracking of driver hours to ensure drivers operate as required. No ELD means limited visibility into true driver hours. Paper logbooks create a less accurate, less reliable audit trail. HoS violations become inevitable. As a fleet grows, ensuring accurate compliance becomes more and more difficult without ELD software to digitally capture driver hours.
Yes, FMCSA regulations include several exceptions to ELD mandate requirements, including:
Never assume that an exception applies to your fleet. Regulations and limitations are complex. Each exemption includes specific eligibility requirements, and some have recently been updated. See the FMCSA website for more on those.
If you think that your fleet qualifies for an exemption, periodically review operational practices, driver activity and vehicle specifications to verify continued eligibility.
One of the most overlooked compliance risks involves exemption misclassification. For example, a yard move carries a special driving category for which the driver’s status should be recorded as On-Duty, Not Driving. And yet, yard moves are one of the most frequent reasons drivers fail an HoS audit. Same goes for personal conveyance and sleeper berth.
For another example, a fleet may believe it qualifies for a short-haul exception even when it regularly operates outside the exemption's requirements. Another fleet may continue relying on an exemption after route changes, customer demands or operating procedures alter eligibility.
Exemption eligibility deserves the same level of oversight as any other compliance requirement. HoS gaps develop quickly when a fleet incorrectly applies a trucking ELD exemption.
Fleets fall behind on HoS compliance when driver hours are documented manually using paper logs and reviewed after the fact. Issues hide until roadside inspections, audits or investigations, and by then it’s too late to avoid violations.
Common contributing factors include:
Sometimes, drivers have no choice but to use a paper log, such as when an ELD for trucks malfunctions. However, when paper logbooks aren’t filled out correctly and reviewed in time, those errors incur a violation during a roadside inspection.
Paper logbooks create an unreliable audit trail and hide violations that surface during reviews and roadside stops. Drivers and fleet managers are unable to keep up with the accurate recordkeeping and driver hour capture required for strong compliance.
Paper logs and manual processes create lags between driver activity and compliance review. Managers may not discover a discrepancy until hours or days after it occurs.
Common issues such as missing duty-status changes, incomplete documentation, delayed submissions, recurring edits and missing supporting records are small mistakes that increase the risk of an HoS violation.
Consider this: When one of your drivers is pulled for a roadside inspection, do you want that driver providing coffee-stained, half-blank paper logs? Or perform a clean, fast data transfer?
The larger the fleet, the more difficult maintaining visibility becomes without an ELD. A compliance manager may effectively monitor a small group of drivers. Monitoring dozens or hundreds of drivers across multiple locations requires structured processes and centralized information.
Fleet leaders need to know:
Not being able to answer any of those questions means higher risk of non-compliance with HoS regulations.
Mistakes at the driver level are often a lack of consistent processes. When drivers interpret procedures differently or apply varying levels of detail to their paper logs, those inconsistencies create confusion during reviews and increase administrative workloads.
Many compliance issues originate from process variation rather than intentional violations.
HoS reviews are multi-faceted. Compliance teams often compare duty-status records with GPS data, dispatch records, fuel transactions, toll activity, maintenance records, and other operational information. Additional compliance review processes depend on the fleet, industry and company policy. Each step along the way is an opportunity for HoS compliance to suffer a gap, even when reviewers don’t notice at that time.
When those records reside in separate systems, investigations are more difficult and discrepancies become are harder to identify. Unassigned drive time is practically impossible to verify, leaving more room for violations and making the task of monitoring trends more difficult.
Compliance gaps aren’t always overnight oversights. Challenges such as repeated corrections, recurring scheduling conflicts and route-specific issues are red flags of higher compliance risk.
When fleet managers can’t see these red flags or notice these trends, drivers regularly operate near or over HoS limits. And that means more violations.
More work for everyone. The larger the fleet, the bigger the workload becomes.
Increased administrative workload: Staff need to locate information, investigate discrepancies, account for unassigned drive time as best they can, verify documentation and prepare reports.
Greater audit preparation effort: Preparing documentation from multiple systems and paper logbooks increases preparation time and introduces additional opportunities for inconsistencies.
Reduced confidence in operational decisions: Dispatchers, operations leaders and compliance teams depend on accurate information. Fragmented records make scheduling, resource planning and compliance oversight more difficult.
Regular audits identify compliance gaps before they lead to violations.
Know where the required information enters your fleet’s compliance process. Document every location where compliance information originates to make identifying gaps down the line easier.
These sources include:
Find out how long it takes for driver RODS to be reviewed and approved. In the process, you’ll find out where there needs to be greater visibility for finding and addressing gaps in HoS compliance.
Review how quickly information reaches managers and compliance personnel by assessing:
Never assume an exemption, remember? HoS exemptions span different legal statutes, permanent rules, temporary crisis waivers and individual company petitions, which makes verifying that your fleet’s current practices meet qualification requirements essential.
Confirm supporting documentation and review current operational practices. If your business has grown, updated routes or restructured, make sure that how it operates today qualifies instead of taking it for granted that any existing exemption still applies. It may or may not, and assuming it does creates risk of non-compliance.
Take the time to comb records and identify problematic trends that need to be addressed.
Review driver RODS for:
Resolve as many discrepancies, including unassigned drive time, as possible for a clear picture of your fleet’s activities. Cross-reference driver RODS against dispatch activity, fuel purchases, off-duty statuses, personal conveyance, telematics data, maintenance records and other operational information for a clear picture of driver hours and documentation habits.
Individual record reviews only focus on that record. They don’t tell the whole story. Trend analysis tells more of the story than any single drive time log can. Review data across 30-, 60- and 90-day periods.
Look for patterns involving:
Look for these common warning signs:
You don’t need to see every item on the list, but they are signs that more oversight is needed.
By providing clearer visibility, easier reporting, accurate drive time captures and centralized compliance data.
Visibility: Fleet managers need reliable insight into how many hours each driver has available, as well as who’s about to run over their limit. They need instant access to trends, locations and violations to monitor compliance.
Reporting: Teams and staff need to provide rock-solid, accurate audit trails during reviews. Close the gaps in records, and you’ll avoid more violations.
Accuracy: Electronic logging devices automatically record driver activity through the vehicle’s onboard telematics. And it provides drivers with the flexibility to update their logs more easily, while making falsification harder.
Centralization: Centralized records improve driver-hours visibility, simplify record reviews, support trend analysis, and strengthen oversight across the fleet.
A proven ELD technology with a dedicated provider. Most fleets subject to the ELD mandate already use electronic logging devices. However, trucking fleets that want to (or need to) move to ELDs instead of paper logs should look for a solution that strengthens compliance oversight and day-to-day operations.
Hours-of-Service compliance depends on accurate information and timely visibility into fleet operations.
Together, these technologies provide greater visibility into driver activity, compliance performance, and operational trends.
Ready to modernize your HoS compliance? Learn how Zonar improves safety, compliance, visibility and uptime for your fleet.
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ELDs help automate hours-of-service recordkeeping, but compliance gaps still develop. Common causes include incorrect exemption use, unresolved unassigned drive time, delayed log reviews, paper logs used during ELD malfunctions and inconsistent documentation practices. Technology supports compliance, but processes and oversight remain essential.
Most fleets benefit from ongoing record reviews combined with formal audits at regular intervals. Reviewing trends across 30-, 60- and 90-day periods helps identify recurring issues.
Under limited circumstances. Drivers use paper logs during qualifying ELD malfunctions or when operating under a valid FMCSA exemption. Fleets subject to the ELD mandate generally must use compliant electronic logging devices and maintain required records according to FMCSA regulations.
Frequent log corrections, recurring documentation issues, lengthy audit preparation cycles, repeated compliance exceptions and uncertainty about exemption eligibility are all signs that a fleet may have visibility gaps. These issues make it harder to identify compliance risks before they result in violations.
Look for trucking ELD software that supports accurate hours tracking, centralized records, audit-ready reporting and visibility into driver activity. The strongest solutions also help fleets identify compliance trends, monitor available driver hours and simplify roadside inspections and internal audits.
