New Entrant Safety Audit: What New Carriers Should Have Ready

CabFiles Compliance Team · March 11, 2026 · 2 min read

New authority comes with an audit. Here is what it reviews, what a first-year carrier should already be able to produce, and how to avoid the usual first-audit failures.

The first audit arrives while a new carrier is still building its habits, which is exactly why it catches people out. Nothing in it is unexpected — but a first-year fleet often has no filing system yet, only a growing pile of paperwork.

The record groups reviewed

A new entrant audit covers the same ground as a compliance review, in a narrower period:

  • Driver qualification — a complete file per driver, including the 30-day items.
  • Drug and alcohol testing program — policy, pre-employment results, random pool and selections, supervisor training, Clearinghouse queries.
  • Hours of service — ELD records, supporting documents, and evidence you reviewed logs and acted on violations.
  • Vehicle maintenance — annual inspections, periodic maintenance, DVIRs and the repair certifications.
  • Accident register — the register required under 390.15 with supporting reports.
  • Financial responsibility — proof of required insurance.

What trips first-year carriers

No safety performance history requests. New carriers often skip the previous-employer investigation entirely, because it feels like paperwork about a former job. It is a rule with a 30-day clock.

One folder for everything. Testing results filed with driver applications is both a confidentiality problem and an organisation problem.

No random testing evidence. Being enrolled in a consortium is not the same as holding the selection records.

Owner-operators treated as outside the system. If they drive under your authority, they need a qualification file.

Expired medical cards. The single most common finding, at every fleet size.

A 30-day readiness plan

  1. List every driver — including owner-operators — and every unit.
  2. Build one file per driver against the Part 391 checklist and mark each gap.
  3. Send outstanding previous-employer requests today, dated, and keep the proof.
  4. Pull missing MVRs and complete the annual reviews that are due.
  5. Record every medical certificate's expiry date and set warnings.
  6. Collect annual inspections for each unit and confirm each open DVIR defect has a repair certification.
  7. Confirm your testing program file holds the policy, pool records and supervisor training.
  8. Produce a full export and read it as an investigator would — is anything unexplained?

How CabFiles helps a new carrier start clean

CabFiles gives a new fleet the structure it does not have time to invent: a Part 391 checklist per driver, expiry and annual-review dates tracked from the day a document is filed, DVIR and maintenance records against each unit, restricted storage for testing records, and a one-download audit packet across all of it.

Next: the DOT audit preparation checklist and new driver onboarding checklist.

Audit scope and scheduling are set by FMCSA and its state partners. General guidance, not legal advice.

Frequently asked

When does a new entrant safety audit happen?
New carriers are subject to a safety audit during the new entrant safety assurance period that follows the grant of authority. Scheduling is handled by FMCSA or its state partner, and carriers receive a document request in advance.
What does a new entrant audit look at?
Driver qualification, drug and alcohol testing program compliance, hours-of-service records, vehicle maintenance and inspection records, accident register, and required financial responsibility.

Keep every file audit-ready

CabFiles tracks expiry and review dates, scores driver files against the Part 391 checklist, and exports a complete audit packet in one download.

Related reading