ELD compliance is not static. The FMCSA updates enforcement guidance, adjusts exemption categories, and clarifies hours-of-service edge cases on a rolling basis, and operations teams that treated ELD implementation as a one-time event in 2020 are frequently operating with outdated interpretations of the rules. 2026 brings specific updates to the short-haul exemption, the personal conveyance policy, and the FMCSA's enforcement posture on ELD malfunction documentation that every CMV operator subject to the mandate should review.
Short-haul exemption updates
The short-haul exemption allows drivers to use paper logs instead of an ELD when they operate within a 150 air-mile radius of their reporting location and return to that location within 14 hours. The exemption was expanded by the FMCSA in 2020 from 100 to 150 air miles, and many operators are still applying the older radius to their short-haul determinations. Using the 100-mile radius means some drivers who qualify for the exemption are maintaining ELD records unnecessarily, while a miscalculation in the other direction creates a compliance gap.
The 14-hour return requirement has also generated enforcement activity. FMCSA inspectors are increasingly checking dispatch records to verify that drivers claiming the short-haul exemption are genuinely returning to their reporting location within 14 hours, not using the exemption to avoid ELD documentation on runs that extend past that window. Fleets should audit their dispatch records quarterly to confirm that short-haul-exempt drivers consistently satisfy both the radius and the return-time criteria.
Personal conveyance: the gray area that generates violations
Personal conveyance (PC) — the use of a CMV for personal use while off duty — allows driving time logged as off-duty, which does not count against hours-of-service limits. The FMCSA's guidance on what qualifies as personal conveyance has been clarified several times, and the current standard requires that the use be genuinely personal (not in the interest of the motor carrier) and that the destination not be a location where the driver will immediately begin work-related activity.
Common PC violations caught at inspection include drivers logging the final miles of a delivery run as personal conveyance after dropping a load, and drivers using PC to move a vehicle to a more convenient overnight location that turns out to be a terminal or customer facility. Samsara's ELD platform allows carriers to configure PC rules that limit or require manager approval for PC time entries — a configuration step that Vidmatics recommends for any fleet that has received PC-related violations or that operates in high-inspection states.
ELD malfunction documentation requirements
When an ELD malfunctions, the FMCSA requires specific actions: the driver must note the malfunction in the daily log, begin reconstructing records on paper within 24 hours, and the motor carrier must correct or replace the malfunctioning device within 8 days. The documentation requirements for the malfunction period — what records must be kept, in what format, and for how long — are frequently misunderstood, and FMCSA audit findings frequently include deficiencies in malfunction documentation rather than the malfunction itself.
Samsara's ELD system generates malfunction logs automatically and maintains them in the platform. Vidmatics recommends that fleet managers review the malfunction log quarterly even if no driver-reported malfunctions have occurred — automated logs sometimes capture ELD connectivity interruptions that were not escalated by drivers but that could create documentation gaps in an audit. If you have not reviewed your ELD malfunction log in the past quarter, that review should be on your compliance calendar for this month.
What your fleet needs now
The records that matter most in an FMCSA compliance review are: complete ELD files for all CMV operators subject to the mandate (kept for 6 months), driver qualification files, inspection reports (kept for 12 months), and accident registers (kept for 3 years). Vidmatics clients have access to Samsara's compliance dashboard, which surfaces missing or expiring documents and generates alerts before they become violations. If you are managing these records in spreadsheets or paper files, a consultation with Vidmatics on the Samsara compliance module is a worthwhile investment before your next audit cycle.