Tax Reporting and IRP: IVDRs, Retention, and Audits

IRP recordkeeping requirements center on one document per truck: an Individual Vehicle Distance Record (IVDR) that logs every trip, with supporting monthly, quarterly, and annual summaries. You must keep these records for three years after the close of the registration year they supported, make them available to auditors on request, and produce them within 30 days of a written demand. Fall short, and the base jurisdiction can assess a penalty of 20, 50, or 100 percent of your apportionable fees depending on how many times it has happened before.¹

What an IVDR Has to Contain

Every apportioned renewal is built on the IVDRs generated during the reporting period. Each record must capture the starting and ending dates of the trip, the origin and destination, the route traveled (including highway numbers and the points where the vehicle crossed jurisdictional lines), and the beginning and ending odometer readings.² Those details are what let a carrier calculate miles driven in each jurisdiction, and they are what an auditor uses to verify the numbers on the registration application.

The reporting period runs July 1 through June 30 of the year immediately before the registration year. Distance from July 1, 2025 through June 30, 2026 feeds the 2027 renewal, and every mile accrued during that window must be captured. From the daily IVDRs, carriers build monthly and quarterly fleet summaries that aggregate miles by jurisdiction and by vehicle, then an annual summary that populates the jurisdictional mileage fields on the application.² All three layers are subject to retention.

The usual weak point is the jurisdictional border crossing. If an auditor can’t tell from the record where a vehicle entered or exited a state, they can reallocate the distance using methods unfavorable to the carrier. Reconciling total trip miles against odometer readings at the start and end of the reporting period catches most discrepancies before they reach the audit desk.

Vehicle Documents That Belong With the Mileage

Mileage data isn’t the only thing audited. The application itself requires the full 17-digit VIN for each vehicle, unladen weight, intended gross vehicle weight, original purchase price, and date of acquisition. Keep the titles, bills of sale, and weight documentation alongside the distance records so the figures on your application can be traced back to source documents.

Electronic Logging Devices and Audit-Acceptable Formats

ELD-generated records are accepted in place of handwritten trip sheets, but only if the system captures the right data in the right form. The device must record GPS coordinates (latitude and longitude to at least four decimal places), the date and time of each reading, the odometer reading pulled from the engine control module, and the vehicle identification number or unit number. Readings must occur at least every 15 minutes while the engine is running, which is the frequency needed to validate border crossings.

Format matters as much as content. Audit-acceptable records must be exportable as electronic spreadsheet files: CSV, XLS, or delimited text. PDFs, screenshots, and scanned images don’t count. Carriers who assume their ELD is quietly producing IRP-compliant data often find out during an audit that the GPS precision is too low or the export isn’t in a usable form. Verify the configuration before the reporting period closes, not after.

How Long You Actually Have to Keep Records

The IRP Agreement requires retention for three years after the close of the registration year the application pertains to.¹ The math is less obvious than the rule. Because the reporting period precedes the registration year it supports, a trip on July 2, 2025 feeds the 2027 registration year, and the retention clock doesn’t start until that registration year closes. In practice the underlying trip data may need to be held for up to six and a half years from the date of the trip. Carriers who purge records based on when the trip happened, rather than which registration year it supported, routinely destroy documents that are still inside the retention window.

If you also hold IFTA credentials, which almost every IRP carrier does, IFTA requires five years. The same IVDRs feed both programs, so the simplest practice is to retain everything for the longer period and stop worrying about which program applies to which document.

Penalties When Records Can’t Verify the Miles

If your records don’t let auditors verify reported distances, or if you fail to produce records within 30 calendar days of a written request, the base jurisdiction imposes a penalty calculated on the total apportionable fees for the audited registration year:¹

First offense: 20 percent of apportionable fees for the registration year in question.
Second offense: 50 percent of apportionable fees.
Third or subsequent offense: 100 percent of apportionable fees.

The penalty applies to the total fees you paid for the whole fleet in the audited year, not the fees tied to one vehicle. A carrier paying $15,000 in annual apportioned fees would owe $3,000 on a first offense and the full $15,000 on a third. Jurisdictions can also suspend IRP credentials when record-keeping failures persist, which stops the fleet from operating interstate until the carrier returns to compliance.²

The point worth internalizing: the audit isn’t testing whether you paid the correct amount. It’s testing whether you can prove you did. Accurate fee calculations with missing documentation still draw the penalty.

Where Records Must Be Kept and Who Reviews Them

Fleet records must be maintained at the carrier’s established place of business in the base jurisdiction unless alternative arrangements comply with the IRP’s provisions for off-site storage.¹ That place of business has to be a real physical structure, open during regular business hours, staffed by permanent employees who handle general management of the trucking operation. A P.O. box or virtual office won’t satisfy the recordkeeping requirement any more than it satisfies the base jurisdiction requirement.

Audits are conducted through the base jurisdiction. Each jurisdiction’s audit and administrative practices are reviewed by the IRP’s peer review program on a rotating basis, which is why audit methodology stays reasonably consistent across member jurisdictions.³

Audit Triggers Worth Knowing About

The most common red flag isn’t inside the IRP file at all. It’s a mismatch between the annual distance reported on the IRP renewal and the quarterly totals filed with IFTA. If you report 120,000 miles in a jurisdiction on your IRP application but your four IFTA quarters only add up to 95,000 for that same jurisdiction, expect questions. Because the same underlying IVDRs feed both programs, sourcing both from the same records is the cleanest way to prevent the mismatch.

Other common triggers show up inside the IVDRs themselves: trips where the sum of jurisdictional miles doesn’t match the total trip distance, routes that imply border crossings not recorded in the log, and odometer gaps between consecutive trips for the same vehicle. These are the first things auditors look for because they’re the fastest way to establish that the records can’t be relied on.

A Note for First-Time Registrants

Carriers with no prior IRP history don’t have IVDRs to report for their first registration year. The first application uses the base jurisdiction’s average per-vehicle distance chart to estimate the jurisdictional split, and actual and estimated mileage are never blended on a new fleet application. The recordkeeping obligation starts the day the fleet begins operating, though, because the next renewal will be based entirely on actual reported distance. Logging every trip from day one is what makes the first true-up renewal defensible if it later gets audited.

1
IRP, Inc. International Registration Plan Agreement
2
International Registration Plan, Inc. IRP Audit Reference and Best Practices Guide
3
International Registration Plan, Inc. Peer Review Program