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 costs up to $34,116 per day | 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.
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.