IRP and IFTA Audit in 2026: What the State Asks For, How Many Years Back, and What Missing Records Cost

Published October 23, 2026 | TruckerNavi Inc | 39 min read

By the TruckerNavi compliance team, led by Dmitry Borovoy, a New Jersey-licensed insurance producer and author of "Safety Manager: From Zero to Expert".

Short answer: your base state is required to audit, on average, 3% of the IRP fleets it renews each year (IRP Plan, Section 1025) and 3% of its IFTA accounts (IFTA Audit Manual, A250), on behalf of every other state at once (Plan Section 1020, IFTA Articles R1310). An IRP audit checks only the distance behind your apportioned registration. An IFTA audit checks distance and fuel behind your quarterly returns. Under the Plan you keep IRP records for 3 years after the close of the registration year (Section 1000), but New Jersey asks for 5 years and New York for 6; IFTA records are kept 4 years from the due date or the filing date of the return, whichever is later (IFTA Procedures Manual, P510). You get at least 30 days' notice before the audit (IRP Audit Procedures Manual 401, IFTA Audit Manual A420), 30 days to answer a written request for records (Plan 1015, Articles R1210), and at least 30 calendar days to file a written appeal (Plan 1065, Articles R1390). If the records are not there: on IRP the state assesses 20% of your apportionable fees for that registration year, 50% the second time, 100% the third (Plan 1015); on IFTA your fleet MPG is cut to 4.00 or reduced by 20%, tax-paid fuel credit is denied, and a penalty of $50 or 10% plus interest goes on top (Procedures Manual P570, Articles R1220 and R1230).

Two things this is not. It is not a DOT audit: FMCSA investigators check the safety regulations, and that process is covered in the guide to DOT audit types. And it does not touch your CSA percentiles: the Safety Measurement System is built from roadside inspections, crashes and investigations across seven BASICs (csa.fmcsa.dot.gov), not from state tax audits. The damage comes from a different direction. In New Jersey, not filing the fourth-quarter IFTA return suspends both your IFTA and your IRP credentials (NJ MVC); in New York the DMV will not re-register your vehicles while the IFTA license is suspended (NYS Tax Publication 536). A truck without credentials collects violations at the scale house, and those do reach CSA.

Why was my company selected for an IRP or IFTA audit?

Usually because of nothing you did. Both agreements set a quota. The Plan requires each base jurisdiction to audit an average of three percent per year of the fleets whose registration it renews (Plan, Section 1025(a)). The IFTA Audit Manual sets the same 3 percent of the state's IFTA accounts, excluding new licensees, and requires each audit to cover a full license year or at least four consecutive quarters (Audit Manual, A250). The number has to be met every year, so a share of fleets get the letter for no reason beyond arithmetic.

The quota is not blind to fleet size. Under A260.100 at least 15 percent of a state's IFTA audits must involve low-distance accounts, the bottom 25 percent by miles reported the previous year, and at least 25 percent must involve high-distance accounts, the top 25 percent. A one-truck company is inside the audit plan by design, not by exception.

The other half of selection is the desk review. Since January 1, 2026, the auditor must analyze the licensee's returns before the audit and note unusual trends or variances (A310.300, amended by Ballot 9-2025): fleet MPG that jumps between quarters, a zero-mile quarter while the IRP application shows the truck running, fuel bought in a state with no miles reported there, IFTA totals that do not add up to the IRP distance for the same months. If you file the quarterlies yourself, the IFTA quarterly filing guide walks through the numbers the auditor compares.

There is a softer version of the visit. A Records Review looks only at your recordkeeping system and internal controls. On the IRP side it may come before your first renewal and does not result in any fee adjustment (IRP Audit Procedures Manual, 701); on the IFTA side it cannot result in a tax assessment, and once completed it precludes an audit for 180 days so you can fix what was found (A500.100.030, A510.400). Three Records Reviews count as one audit toward the quota, up to 25 percent of it (Plan 1025(d), A250). If the letter says "records review", read it as a free warning.

How far back can the auditor go?

The two agreements give two different answers, and your base state may add a third.

• IRP: 3 years. Plan Section 1000(a) requires you to retain the records on which your application for apportioned registration is based for three years following the close of the registration year. The distance behind a registration year comes from the reporting period, July 1 to June 30 (NY IRP-8), so a 2026 registration year rests on July 2024 through June 2025 distance, and those records stay with you for three years after the 2026 registration year closes.
• IFTA: 4 years. Procedures Manual P510 sets four years following the date the IFTA return for those operations was due or was filed, whichever is later. Periods covered by a waiver or a jeopardy assessment are added on. Records for periods under audit stay until the audit is finished, and a refund request extends retention for the periods involved.
• Nothing beyond that, in either direction. Both texts say the same thing: no assessment for deficiency and no refund may be made for any period for which you are not required to retain records, unless you signed a waiver of the limitation period (Plan 1000(b), P510). An auditor cannot reach into year five of IFTA records unless you agreed to it in writing.

Now the state layer. New Jersey MVC's IRP FAQ states that IRP records must be maintained on file for five years (NJ MVC IRP FAQs), and the NJ IRP Carrier Guide (section 15.0) spells it out: all operational and mileage records that support the application and supplements are kept for five years after the close of the registration year, with the example that registration year 2022 records are kept until December 2026. New York goes further. The DMV's IRP-8 manual (section 14.0) makes the registrant responsible for maintaining distance records for six years from the date of the trip, so a June 2023 trip is kept until June 2029, and driver logs used as trip records fall under the same six years.

The practical rule that removes every question: keep everything for six years, in a folder per registration year and per IFTA quarter, and never let a fuel card statement or an ELD export expire before that.

IRP audit vs IFTA audit: what is checked and by whom

One state does the checking for all of them. An IRP audit is conducted on behalf of all member jurisdictions, and the base jurisdiction may make assessments and collections of fees based on it (Plan 1020). The IFTA Articles of Agreement say the same: the base jurisdiction audits its licensees on behalf of all member jurisdictions (R1310), and another state may run its own audit of you only at its own expense. Both agreements allow joint audits with other states (Plan 1030), and both give the other states 45 calendar days after they receive the findings to demand a re-examination limited to the same sample (Plan 1040, Articles R1360).

In New Jersey the two audits arrive together. The NJ IRP Carrier Guide (section 16.0) states that New Jersey will perform IFTA audits in conjunction with IRP audits if applicable and where reasonable, and the auditors come from MVC. In New York the pairing is different: the IRP audit comes from the DMV, while the IFTA audit comes from the Department of Taxation and Finance, and Publication 536 says that in addition to the IFTA audit the department will audit your New York State highway use tax at the same visit. How the four programs fit together, and which miles feed which return, is laid out in IRP vs IFTA vs NY HUT vs 2290.

Which records count as acceptable distance records?

The test is not "did you keep something", it is "can the state verify it". Plan Section 1005(a) requires records adequate to enable the base jurisdiction to verify the distances reported and to evaluate the accuracy of your distance accounting system; IFTA P530 uses the words sufficient and appropriate. Both accept any medium and any format the state can audit, and both carry the same sting: records presented in a format or a manner the state cannot audit have not been made available at all (Plan 1005(b) and its commentary, P530).

For a trip that is not captured by a vehicle tracking system, Plan 1010(a) and IFTA P540.100 list the same seven elements. New Jersey's Carrier Guide builds them into its Individual Vehicle Mileage Record (IVMR) with eleven fields, adding the registrant's name, tractor and trailer unit numbers, fleet number, driver's name and signature, and any trip permits; the MVC's IRP page adds that the most common IVMRs are the driver's trip sheets and driver's log (NJ MVC, IRP). New York's IRP-8 adds two rules of its own: every stop is recorded as city and state, and total trip mileage includes loaded, unloaded, bobtail, deadhead, yard and non-business miles.

On top of the trip records come the summaries: a monthly summary of the fleet's operations per vehicle and per jurisdiction, a quarterly summary for the fleet, and a summary of the quarterly summaries (Plan 1010(c)); IFTA asks for a monthly fleet summary of distance and fuel per vehicle, in total and by jurisdiction (P560). The summaries are not a substitute. New York says it in one line: summary reports such as IFTA filings and spreadsheet totals are just recaps and are not acceptable by themselves, and mileage software can only support trip records, not replace them (IRP-8, 14.0).

What fuel documentation does IFTA require?

IFTA asks two fuel questions and scores them differently. The first is total fuel consumed, which drives your fleet MPG. The second is tax-paid fuel, which is credited against the tax you owe each state. You need complete records of all fuel purchased, received and used, by fuel type (Procedures Manual P550.100). But you only get the credit for tax-paid fuel if you can show one of the documents in P550.220: a receipt, invoice or transaction listing from the seller, a credit-card receipt, a transaction listing generated by a third party, or an electronic or digital record of an original receipt.

Whatever the document is, P550.300 wants these elements on it: the date of purchase, the seller's name and address (a vendor code is accepted), the quantity, the fuel type, the price per unit or the total amount, the identification of the vehicle into which the fuel was placed, and the name of the purchaser (under a lease, the lessor or the lessee). New Jersey's IFTA Manual adds the vehicle's unit or plate number and the purchaser's signature to its receipt requirements. A receipt that has been altered, shows erasures or is illegible is refused unless you can prove it is valid (P550.200), and fuel placed into anything other than a qualified motor vehicle earns no credit (P550.210). Bulk fuel is its own file: delivery receipts, quarterly inventory reconciliations for each tank, tank capacities, and a withdrawal record for every fill with location, date, quantity, fuel type and vehicle (P550.400, P550.600).

One point in your favor that auditors know and carriers do not: missing receipts do not shrink your fuel. Audit Manual A360 states that the absence of tax-paid fuel receipts, and the resulting denial of the credit, does not in and of itself warrant a reduction to the reported total volume. Your MPG stays where the fuel card statement puts it; you lose the credit, not the gallons.

How does ELD data hold up in an audit?

It holds up when the export meets four requirements, and most exports do not. Both agreements accept records from a vehicle tracking system, with one difference in sampling rate: the Plan wants a record created and maintained at least every 15 minutes when the engine is on (Section 1010(b)); IFTA wants one at least every 10 minutes (P540.200). Each record must carry the VIN or unit number, the date and time, the latitude and longitude to four decimal places (0.0001), and the ECM odometer reading; if the vehicle has no ECM, the odometer at the beginning and end of each trip.

Then the format. Since January 1, 2024, both texts say tracking data must be delivered as an XLS, XLSX, CSV or delimited text file, and that formats providing a static image, such as PDF, JPEG, PNG or Word, are not considered accessible (Plan 1010 commentary, Ballot 446; IFTA P540.200, Ballot 1-2023). A PDF print of your ELD miles-by-state report is not a record made available, and the assessment for unavailable records stays on the table.

What happens when the device fails on the road is a separate rulebook, covered in the ELD malfunction and 8-day rule guide. For audit purposes the fix is boring: download the IFTA-format CSV from the provider portal every quarter, save it with the quarter's fuel statement, and check that the unit numbers in the file match the unit numbers on the cab cards.

What happens if records are missing?

Two different mechanisms, and it matters which one you are under.

IRP: a percentage of your fees. Plan Section 1015 applies when the records for the fleet as a whole are inadequate, or when you fail to make records available within 30 calendar days of a written request. The assessment is 20 percent of the apportionable fees paid or payable for the registration year in question; 50 percent for a second such offense known to the base jurisdiction; 100 percent for a third and every one after that. The official commentary narrows it in two useful ways: the assessment is not imposed where the records, even if of poor or inconsistent quality, can still be audited, and it is not imposed for gaps on individual vehicles when the fleet overall is auditable. If a vehicle in the fleet turns out not to be apportionable, its distance is removed from the application and full (100%) fees are calculated for that vehicle in the state where it ran (APM 504(e)). New York's IRP-8 repeats the 20/50/100 schedule and adds a lock: assessments must be paid, or an appeal won, before any subsequent IRP transaction is processed for the account.

IFTA: your MPG. Procedures Manual P570.100 gives the base state two options when fleet records are inadequate or were not produced after a written demand: reduce the reported fleet MPG to 4.00 (1.70 KPL), or reduce the reported average fuel consumption by 20 percent; for jurisdictions that tax by the mile, the distance in that jurisdiction is increased by 20 percent. On top of that the state may deny tax-paid credit for undocumented fuel, assess by the best information available, and suspend, revoke or cancel the license (P570.200, Articles R1210). New Jersey's IFTA Manual states it flatly: an assessment of four miles per gallon will be applied for records not properly maintained. Where the gap is limited to particular vehicles or months, the Audit Manual tells the auditor to estimate from your own prior experience, similar operations, industry averages and fuel supplier data before falling back on 4 MPG (A350.200). That is why a partial gap, shown honestly, ends very differently from a fleet with nothing.

Then the money that follows. Any IFTA assessment carries a penalty of $50 or 10 percent of the delinquent tax, whichever is greater (Articles R1220), and interest at two percentage points above the federal underpayment rate under IRC 6621(a)(2), reset each January 1, accrued monthly at one-twelfth of the annual rate and computed on each state's net balance (R1230). The assessment is presumed correct, and the burden of proving it wrong is on you (R1210.300, P520). If the debt stays unpaid and no written appeal is filed within 30 days of the notice, a notice of revocation follows (R1270). And in New Jersey, not filing the fourth-quarter IFTA return by itself suspends both your IFTA and your IRP credentials (NJ MVC).

What are the deadlines to respond?

Can you reschedule? Neither agreement gives you a right to. The IRP Audit Procedures Manual (401(c)) notes that any waiver of the notification requirement or postponement must be documented in the audit file, and the IFTA Audit Manual (A420.200) allows a start earlier than 30 days only with your consent or for just cause. So a postponement is a request, made in writing, on the day the letter arrives, with a date on which the records will be ready. Silence for 30 days after a written request for records is already a failure to make them available, and that failure is what triggers Plan 1015 and P570.

How the audit ends: report, netting, the bill

You get a report, and so does every state. Plan 1055 requires the audit report to include a narrative of the audit, summary descriptions of your recordkeeping and internal controls, and a billing summary; the appeal and re-examination clocks run from the date the report is sent to you. The IFTA billing summary is laid out by quarter in Audit Manual A460.700: distance adjustments, fuel adjustments, MPG as reported and as audited, tax by jurisdiction, penalty, interest by jurisdiction and the total. The schedules and worksheets behind the findings must be given to you on request (Articles R1370.300).

The bill is netted. Under Plan 1050, additional fees owed to some states are offset against fees overpaid to others, and only the net amount is collected from you or refunded to you. New York's IRP-8 describes the mechanics: the DMV bills any underpayment, refunds are processed automatically, and other jurisdictions may assess their own penalties and interest on their share. IFTA interest runs separately on each jurisdiction's net balance (R1230.300), and a state may use its lien provisions once IFTA tax is more than 30 days delinquent (R1240.300).

Two costs that surprise carriers. If your records are kept outside the base state and the auditors have to travel, both agreements let the state bill you for the auditors' per diem and travel expenses (Plan 1035, P510), and New York's Publication 536 tells you to bring out-of-state records to New York or pay the auditors' transportation and lodging. And once the appeal period and the 45-day re-examination window have both run, the findings are final as to all member jurisdictions and to you, except in cases of fraud (Plan 1070).

Can I appeal the assessment?

Yes, and the clock is short. The Plan gives the registrant at least 30 calendar days from notification of the audit findings to file a written appeal with the base jurisdiction under its procedures (Section 1065); the IFTA Articles give the licensee the same 30 calendar days (R1390). Where the base state has no procedure of its own, the Articles supply one: a written request for a hearing within 30 days after service of the notice, otherwise the finding is final; at least 20 days' notice of the hearing; the right to appear with counsel; and, if you still disagree, the right to ask any other member jurisdiction to audit its own share (R1400 to R1450).

The state procedures on top of that:

• New York, IRP: an appeal form, with an appeal fee, within 30 days after the date of the audit letter; the Appeals Board is at (518) 474-1052 (IRP-8, 15.0). Until the assessment is paid or the appeal is won, no other IRP transaction on the account is processed.
• New York, IFTA: 30 days from the postmark date of the written notification to file a petition with the Division of Tax Appeals or with the Bureau of Conciliation and Mediation Services; otherwise the determination is final (Publication 536).
• New Jersey, IFTA: a written request for a hearing within 30 days after service of the notice, otherwise the finding is final (NJ IFTA Manual).

Two more rules shape what an appeal can achieve. Penalties may be waived by the base state's commissioner for reasonable cause; interest may be waived only where the base state's own law allows it and the other jurisdictions consent in writing (R1260). And after the appeal and re-examination periods expire, nothing reopens except fraud (Plan 1070). Whether an appeal is worth filing, and on what grounds, is a question for your accountant or attorney. What we do is put the records in order and sit next to you at the opening and closing conferences; that service is described at audit representation and quoted on request.

New Jersey and New York: what the base state adds on top of the Plan

The Plan and the IFTA agreements set the floor. Your base state writes the procedure, the phone number and, in these two states, a longer retention period. Which state is your base, and what "established place of business" means for a small carrier, is the subject of the base jurisdiction guide; the registration itself is in IRP registration step by step.

A monthly routine that makes the audit boring

1. Export the IFTA-format CSV from your ELD provider every quarter: 10-minute interval, ECM odometer, unit number. File it with the quarter. Never rely on the provider to keep it.
2. Build a monthly summary per vehicle and per state from that export, and check it against the odometer readings on the first and last day of the month.
3. Put the unit number on every fuel purchase, on the card profile and on the receipt itself, and keep the fuel card transaction listing for every quarter.
4. Reconcile the IFTA return to the IRP distance: the same trucks, the same months, the same miles. Where they differ, write down why (a non-apportioned truck, a trip permit, yard moves).
5. Keep bobtail, deadhead and yard miles in total distance. They belong there, and their absence shows up as an odometer gap.
6. Photograph or scan every handwritten trip sheet in the month it is written, and keep the paper.
7. Keep purchase agreements, weight certificates and lease agreements for each truck for the whole retention period; the lease should say who is responsible for IFTA.
8. File trip permits and temporary registrations in the same folder as the trip they covered.
9. One folder per registration year and one per IFTA quarter, retained for six years, somewhere that survives a dead laptop.
10. Once a year, run the reconciliation yourself the way the auditor will, before the desk review does it for you.

The safety side of the same cabinet, driver qualification files and everything an FMCSA investigator asks for, is listed in the DOT audit document checklist. If you would rather have someone else keep both cabinets, that is what Safety Compliance is.

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