The Ultimate IRP Checklist

The Ultimate IRP Checklist

The IRP – and where you may be leaving operational efficiency, tax savings, and fee savings on the table

We get it — the IRP is not a sexy place to look for efficiency. This probably fits into the bucket of “we’ve been doing things this way for a long time and it hasn’t been a big problem”. Here’s the catch – you are probably leaving money on the table. Registration fees, taxes, and speed to legalize equipment are big and real costs to your business.

The International Registration Plan (IRP) sits at the center of efficient fleet management for large motor carriers operating across state or provincial lines. IRP compliance isn’t just about paperwork—it’s about keeping your equipment moving, ensuring regulatory peace of mind, and safeguarding your business against significant operational and financial setbacks.

When was the last time you measured the average cost to register a tractor or trailer? What if you could reduce that by $500 per unit per year? Or even $100 per unit per year.

Have you accepted that it might take you days or weeks after equipment gets delivered for it to be tagged, permitted and ready to roll? This doesn’t need to happen.

Are you sure you are registering equipment in accordance with IRP and state-level standards? How do you know?

And – is ANY of this really your competency?

What if I told you that even the biggest fleets in the country have opportunities to save on licensing and registration?

If any of these questions have piqued your interest, you are not alone.

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What’s there to gain?

Hard dollar savings

Where you choose to register your equipment, how you register it, how you apply credits, where you title equipment all add up. Sometimes the right answer isn’t always obvious. As an example, we see carriers where Maine is the right place to register a trailer and other cases where it isn’t.

“We ‘ve unlocked efficiencies we couldn’t have imagined.” – Transport Topics Top 100 Carrier

Speed of legalization

Speed means everything. Many carriers don’t realize that equipment can be fully plated and permitted before it gets delivered. Yes, this is a reality, and yes this depends on the carrier scale and eligible states. What is this unlock worth to you? $800 per day per unit? That’s what most carriers tell us.

You might be eligible to IRP equipment that you don’t realize

The IRP comes with many advantages – namely operational simplicity. In some cases, an effective IRP strategy can also yield a cost effective fee structure and tax structure for newly purchased equipment. In some cases, carriers are “straight plating” equipment that otherwise qualifies for the IRP. Straight plating can be cumbersome, painful, and operationally complex – especially if equipment is moving around the country. We find carriers to misunderstand many requirements – including weight limitations of equipment, within the IRP.

Accurate, technology-driven recordkeeping.

The best carriers embrace electronic logging devices (ELDs), GPS programs, and mileage tracking/software to automate the collection, breakdown, and reporting of distances by jurisdiction. This is foundational to frictionless IRP and IFTA compliance, supporting fast audits and renewals, and dramatically reducing human error.​

Centralized process management.

Growing, multi-jurisdiction fleets use compliance management platforms or dedicated compliance staff—sometimes outsourcing to specialty providers—to ensure that IRP, IFTA, and associated filings are always completed on time and reconciled accurately.

Internal review routines.

The most compliant fleets run regular internal “mini-audits” to verify that reported mileage, equipment lists, and cab cards match both current operations and regulatory requirements, proactively resolving discrepancies before an audit or roadside check exposes an issue.

Calendar vigilance.

Missing renewal, amendment, or cab card deadlines is one of the fastest ways to incur downtime and penalties. High-performing fleets use digital reminders and workflow integrations to ensure every deadline is visible and met.​

      Questions to ask yourself:

      • Do your trucks have diesel-fired auxiliary power units installed?​
      • Can you track APU fuel consumption separately from main engine fuel?​
      • Do your APUs have telematics or hour meters to document runtime?
      • Do you operate refrigerated trailers with diesel-powered refrigeration units?​
      • Do you pump reefer fuel on separate receipts from your main fuel purchases?​
      • Can you document gallons consumed by the reefer unit versus the tractor?
      • Does your equipment use PTO systems like hydraulic pumps, cement mixers, or compressors?​
      • Can you measure or estimate the percentage of fuel consumed by PTO operations?​
      • Do you operate concrete trucks, waste haulers, dump trucks, or utility vehicles with bucket lifts?
      • Do your vehicles operate on private property, construction sites, or closed roads?​
      • Can you document miles driven off-highway versus on-highway?​
      • Is your equipment designated as off-highway transportation equipment?

      If the answer is yes to a few or all of these questions – it’s worth further investigation.

      Getting it wrong

      Falling short on IRP compliance exposes fleets to cascading costs.

      These risks range from the straightforward (unplanned downtime) to the existential (suspension of operating authority):

      Immediate operational downtime:

      Expired or suspended IRP credentials mean trucks are grounded—sometimes for days or weeks—until documentation and back fees are resolved. The opportunity cost of idle equipment in a large fleet runs into tens or hundreds of thousands of dollars.​

      Penalties and fines:

      States levy fines for late IRP filings or reporting inaccuracies; these can range from hundreds to potentially thousands of dollars per vehicle, compounded if the violation involves multiple trucks or repeated offenses. Texas allows fines up to $5,000 for certain registration violations, going up to $15,000 for willful violations—with the possibility to aggregate to $30,000 depending on severity and recurrence.​

      Vehicle impoundment or towing:

      In severe cases, operating without a valid IRP plate leads to vehicles being towed or impounded—triggering not just direct loss of use, but also additional fees and convoluted recovery processes.​

      Reputational and insurance impacts: Large carriers cite the risk that suspensions—publicly available on regulatory databases—can trigger negative insurance reviews, increased premiums, and lost contracts due to perceived compliance risk.​

      Audit headaches and future scrutiny: Failing an IRP audit (often triggered by inconsistent mileage reporting or documentation gaps) isn’t just costly in the moment; it also increases the likelihood of future audits, which can be disruptive to operations and time-consuming for compliance teams.​

      Loss of operating authority:

      The most serious violations—chronic non-compliance or safety violations tied to registration—can lead regulators to suspend or revoke IRP credentials for all vehicles in the fleet under PRISM and FMCSA programs. This “out of service” designation effectively shuts down interstate operations and can be business-ending if not resolved promptly.​

      Real-World Crackdowns and Enforcement Action

      PRISM and the FMCSA now link carrier safety data to IRP renewals and issue “out of service” orders for unsafe or non-compliant fleets. These designations trigger automatic IRP suspension notifications to states, resulting in the loss of registration credentials for affected fleets. During pilot phases, multiple carriers have faced suspension for unresolved safety issues, and these enforcement programs continue to be strengthened.​

      Audits are routine, not rare.

      Base jurisdictions, such as Texas, audit at least 3% of fleets annually for IRP mileage and recordkeeping accuracy. If issues are found, penalties and back taxes can be assessed for up to four years, and suspensions are possible for serious or repeated non-compliance.​

      State-level task forces target habitual violators.

      In recent years, states have announced periodic enforcement blitzes focused on carriers—especially larger ones—with repeated late filings, underreported mileage, or unpaid apportioned fees.

      Enforcement escalates quickly for incomplete records or missing filings.

      Incomplete or inconsistent mileage logs, missing cab cards, or paying IRP renewal fees past the deadline have resulted in large national and regional carriers experiencing short-term equipment suspensions, sometimes resulting in loss of key client contracts.

      Conclusion

      For large motor carriers, IRP registration is not an annual paperwork chore. It’s a strategic function essential to business continuity and profitability. Top fleets invest in proactive compliance, leverage digital tools, and establish routine, organization-wide checks to stay ahead—and avoid the significant (and very real) costs of “getting it wrong.”​

      If your fleet is growing, now is the time to review IRP management practices, invest in compliance technology, and ensure every member of your team is trained and accountable for accurate reporting and on-time renewals. This is how the best carriers minimize risk—and keep their wheels reliably in motion.

      Let’s Talk About Your Fleet’s Compliance Process
      We’ll show you what we did — and how we can do it for your team