ELD Requirements for Small Fleets: Who Needs One?

The ELD rule doesn’t change how many hours a driver can work; it changes how those hours are recorded. FMCSA says an ELD synchronizes with a vehicle engine to automatically record driving time, that the rule was congressionally mandated as part of MAP-21, and that the ELD final rule doesn’t change any of the basic hours-of-service rules or exceptions (FMCSA: ELDs). So the first question is whether your drivers must keep logs at all.

Who must use an ELD?

Drivers who are required to keep records of duty status under 49 CFR 395.8 must use an ELD unless an exception applies (49 CFR 395.8). Those drivers operate commercial motor vehicles, which for property-carrying vehicles generally means a weight rating or weight of 10,001 pounds or more (see our USDOT guide for the tests).

What are the ELD exceptions?

The regulation lets these drivers keep records of duty status without an ELD. In the eCFR text, they include a driver who operates a commercial motor vehicle:

• in a manner requiring a record of duty status on “not more than 8 days within any 30-day period”;
• in a driveaway-towaway operation in which the “vehicle being driven is part of the shipment being delivered”;
• in a driveaway-towaway operation moving a motor home or a recreation vehicle trailer; or
• that was “manufactured before model year 2000, as reflected in the vehicle identification number as shown on the vehicle’s registration.”

Do short-haul drivers need an ELD?

Usually not. FMCSA says a driver is exempt from the record of duty status and ELD requirements (49 CFR 395.8 and 395.11) when the driver operates within a 150 air-mile radius of the normal work reporting location and doesn’t exceed a maximum duty period of 14 hours (FMCSA: HOS summary). The carrier keeps time records instead. If a driver can’t meet the exception, a record of duty status is needed for that day, and the 8-days-in-30 test above decides whether paper logs are still allowed. Our hours-of-service guide explains the short-haul conditions.

How do you pick a compliant ELD?

FMCSA publishes an official list of devices that have been registered with FMCSA and self-certified by providers as compliant with the ELD rule (FMCSA ELD website). Check that a device is on the list before you buy, and check again later, because devices can be removed. FMCSA’s ELD site says:

On August 6, 2026, FMCSA removed MOONLIGHT ELD, HGRS ELD, HIGHEST ELD, TRUCKFORD ELD, and Sparkle ELD from the list of registered ELDs due to the companies’ failure to meet the minimum requirements.

FMCSA said motor carriers using those ELDs must replace them with registered ELDs before October 6, 2026. Our telematics comparison guide covers questions to ask a vendor.

How long do you keep ELD records?

The regulation requires a motor carrier to keep records of duty status and supporting documents for each driver for at least 6 months, and a driver must have the records for the current day and the previous 7 consecutive days available when asked (49 CFR 395.8).

Can a driver turn an ELD off?

No. The regulation says a driver or motor carrier may not disable, deactivate, disengage, jam or otherwise tamper with an ELD so that the device doesn’t accurately record and retain required data.

Why did FMCSA require ELDs?

FMCSA’s ELD site says it estimates ELDs will result in 1,844 crashes avoided annually, 562 fewer injuries and 26 lives saved each year. Those are FMCSA’s national estimates, not a prediction for any one fleet.