What this is
What is an ELD malfunction record?
What is an ELD malfunction record?
It is the evidence trail for a period when a driver's hours were not captured electronically. It fixes the discovery time, records that the carrier was notified in writing, proves paper logs covered the current day and the previous seven, and shows the device was repaired inside the window. One is raised per malfunction event, not per vehicle or per month.
What counts as a malfunction rather than a data diagnostic event?
A malfunction is a failure of a required ELD function — power, engine synchronisation, timing, positioning, data recording or data transfer. A data diagnostic event flags data needing attention, most commonly unidentified driving, without the device having failed. Malfunctions start the repair clock and the paper log obligation; diagnostics generally do not. The Malfunction Type field in Discovery carries both families, because drivers cannot reliably tell them apart at the roadside.
Who owns the record once it is open?
The driver raises it and owns discovery. The carrier owns everything after notification: arranging repair, requesting an extension if the window will be missed, and transcribing paper back into the system. The two signature fields in Pattern make that handover explicit, so an audit can see which obligation sat with whom and when it passed over.
Scope
When is an eld malfunction record required?
This record covers one malfunction event on one device, from discovery to verified repair. It is not a review of the hours themselves, and it is not a general vehicle defect record. Raising it for the wrong thing makes repair-window reporting meaningless, because the clock only means something when every open record carries a real discovery time.
Use this template when
- A required logging function has failed on a vehicle in service and the driver has noticed it
- The device is throwing a malfunction code the driver cannot clear at the roadside
- Hours were driven on paper because the device was unavailable, whatever the cause
- A malfunction found at a roadside inspection needs a carrier-side record to attach to the report
- A device has been replaced and the old unit's failure period needs documenting
Do not use it for
- Hours of Service Log Review, which examines the hours themselves for driving and rest limit breaches rather than the device that recorded them
- Hours of Service Violation Record, which records a confirmed breach; a malfunction is not itself a violation unless the paper obligation was missed
- Vehicle Defect Report, which handles roadworthiness defects; a dead logging device rarely stops the vehicle and follows a different clock
- Telematics Performance Review, which reviews fleet telematics data quality on a periodic cycle, not a single device failure
- Roadside Inspection Record, which captures what the inspector found and issued; link the two rather than merging them
Compliance mapping
Which FMCSA 395.34 requirements does this satisfy?
The template is built against FMCSA 395.34, which sets out what a driver and carrier must do when an ELD malfunctions. The mapping below shows where each obligation is captured.
| Clause | Requirement | Where it lands |
|---|---|---|
| 49 CFR 395.34 | Driver notices a malfunction and must act on it immediately | Discovery |
| 49 CFR 395.34 | Written notice of the malfunction provided to the motor carrier within 24 hours | Discovery |
| 49 CFR 395.34 | Paper records of duty status kept for the current period until the device is serviceable | Interim compliance |
| 49 CFR 395.34 | Previous seven days reconstructed from records available to the driver | Interim compliance |
| 49 CFR 395.34 | Carrier repairs, replaces or services the device within eight days of being notified | Repair |
| 49 CFR 395.34(a)(2) | Extension to the repair period requested from the field administrator where more time is needed | Repair |
| 49 CFR 395.8 | Duty status records and supporting documents completed and retained for six months | Repair |
| 49 CFR 395.22 | Carrier ensures blank log sheets are carried and drivers are trained to use them | Interim compliance |
What it does not cover
- A repair booking with no discovery time, which leaves the window unmeasurable and invites the assumption it was missed.
- A verbal call to dispatch, which is not the written notice the regulation asks for and leaves nothing to produce at audit.
- Paper logs started at the next depot, which concedes a gap of unrecorded driving no later transcription can close.
- Blank log sheets in the office, which are no use to a driver four hundred miles away.
- A replaced unit with no data recovery attempt, which destroys the only record of the hours before the failure.
Global
ELD Malfunction Record requirements by country
Malfunction handling is one of the few areas where the substance is genuinely similar across regimes but the numbers are not. The repair window and the reconstruction period both change at the border, and a fleet running cross-border needs the record to carry which rule applied.
49 CFR Part 395, in particular 395.34
Prescriptive. Obligations, timings and malfunction code families are written into the rule text.
Eight days from carrier notification to repair, written driver notice within 24 hours, paper for the current day and previous seven. An extension must be requested, not assumed.
Commercial Vehicle Drivers Hours of Service Regulations (SOR/2005-313)
Modelled closely on the United States rule, but with its own timings and third-party certification of the devices themselves.
A longer repair period than the United States, so a cross-border fleet applying one number everywhere is either late in the south or over-cautious in the north. Record which regime the vehicle was operating under.
Regulation (EU) No 165/2014, Article 37, with Regulation (EC) No 561/2006
Written for tachographs rather than ELDs, but the same shape: manual records during the failure, repair without undue delay.
The driver marks up the record sheet or printout by hand with everything the tachograph would have captured. Repair happens on return to base, or en route if the vehicle cannot return within a week.
How to complete it
How to complete an eld malfunction record, step by step
Four decisions in this record decide whether it holds up. None of them is about typing faster.
Time Discovered anchors every other calculation, and it is the one field a driver has an incentive to move. Check it against the last electronic record the device produced. If logging stopped at 09:00 and discovery reads 16:00, either the driver did not look at the screen for seven hours or the time is wrong. Only one of those is a paperwork problem.
Partly is the correct answer far more often than it is used. Reconstruction means rebuilding the previous week from whatever exists — fuel receipts, gate times, delivery notes — not copying what the driver remembers. If the days were rebuilt from recollection alone, say Partly and record how many in Days Reconstructed, because an auditor comparing the paper against your own gate data will find the difference anyway.
Extension Requested scores Not needed and Granted equally, and Refused at zero, which is deliberate: the failure mode is not being refused, it is never asking. If a back-ordered part will push Days To Repair past the window, the request has to go in before the window closes. Within Regulatory Window marked Late with Extension Requested blank is an admission, not an explanation.
Recurring Malfunction This Device and Fleet Wide Issue turn a pile of records into a decision. Three failures on one unit is a replacement. The same malfunction type across twenty units in a month is a firmware or install problem, and Supplier Escalation Raised is how it leaves your organisation. Answering both No by reflex is how a systemic fault stays invisible for a year.
What auditors find
Most common eld malfunction record findings
The findings below are the ones that recur across fleets running this record, with the clause they touch and what actually fixes them.
| Finding | Clause | What fixes it |
|---|---|---|
| Written Notice Provided answered Yes, with no attached notice anywhere in the record | 49 CFR 395.34 | Treat the driver's own written note, photographed and attached, as the artefact. A carrier-generated summary written a week later is not the driver's notice and will not read as one. |
| Hours To Notification consistently entered as a round zero across the whole fleet | 49 CFR 395.34 | Zero is possible once and implausible fifty times. Derive it from Time Discovered and the record creation timestamp rather than asking for it, and let the driver override with a reason. |
| Days To Repair measured from the workshop booking rather than from carrier notification | 49 CFR 395.34 | The regulation counts from when the carrier was told. Calculate from the notification point and show the workshop date separately, so the two cannot be conflated. |
| Paper Records Transcribed To System left at No on closed records | 49 CFR 395.8 | Block closure while it is No. Paper that never reaches the system will not be findable in month five of a six-month retention period. |
| Driver Has Blank Log Sheets On Board answered No, repeatedly, with no action raised | 49 CFR 395.22 | This is a carrier failure, not a driver one. Route any No to a fleet-level action rather than a driver conversation, and check cab stock at the next scheduled inspection. |
| Roadside Inspection During Malfunction answered Yes with no linked inspection record | 49 CFR 395.34 | Use Related records to carry the inspection reference. An inspection during a malfunction period is the highest-consequence version of this record and should never sit alone. |
Case in point
Case in point: the eight days that were really nineteen
A regional carrier with sixty tractors ran a clean malfunction log for eighteen months. Every record showed Days To Repair between two and six, and the fleet manager reported it as a strength. The number was calculated from the date the workshop opened the job.
A compliance review compared last-transmission timestamps against record creation. The median gap between a device going silent and a record existing was eleven days. Drivers had reported malfunctions verbally at the next depot visit, dispatch had logged them as maintenance requests, and the record was being raised by the workshop at the point of repair. No paper logs existed for any of those periods. The repair itself was never late; the seven-day reconstruction was missed every single time, and the record as used hid exactly that.
The template
The template, field by field
The form exactly as it installs. Every field, option, score and conditional rule is editable, and the links to other templates come with it.
6 sections
- Reference
- FLT-022
- Archetype
- Record
- Record ID
- ELD-2026-000
- Scoring
- Not scored
- Direction
- n/a
- Singleton
- No
- Basis
- FMCSA 395.34
- Links
- Links Asset, Worker
- Tags
- Fleet, Compliance
- Sections
- 6
- Fields
- 49
- Follow up fields
- 3
- Repeating sections
- 0
- Links out
- 5
Header
16 fieldsRecord ID*
Auto sequence. Format ELD-2026-000.
The record's own ID. Other templates point at this value.
Status*
Drives who this goes to next.
- Planned2 pts
- In progress2 pts
- Complete3 pts
- Deferred0 pts
- Open0 pts
- Closed3 pts
- Overdue0 pts
Date and Time*
Completed By*
Site*
Site ID*
Format SITE-000.
Links to FDN-001 Site ID
Vehicle*
Asset ID*
Format AST-0000.
Links to FDN-002 Asset ID
Unit Number
The number painted on the door, which is what drivers actually use.
Driver*
Person ID*
Links to FDN-003 Person ID
Licence Class
The Clock Starts At Discovery
Most regulations give a fixed window to repair a malfunctioning device, and require paper records in the meantime. Both obligations start the moment the driver notices.
Device Type*
Device Serial Number
Malfunction Code
Discovery
6 fieldsTime Discovered*
Discovered By*
Malfunction Type*
Power failure, engine synchronisation, timing, positioning, data recording, data transfer or unidentified driving.
Driver Notified Carrier*
- Yes3 pts
- Late1 pt
- No0 pts
Hours To Notification*
Written Notice Provided*
- Yes3 pts
- No0 pts
Interim compliance
6 fieldsPaper Logs Started*
- Immediately3 pts
- Delayed1 pt
- No0 pts
Previous Days Reconstructed*
Regulations typically require reconstructing the previous week from any available records.
- Yes3 pts
- Partly1 pt
- No0 pts
Days Reconstructed
Driver Has Blank Log Sheets On Board*
- Yes3 pts
- No0 pts
Driver Trained On Paper Logs*
- Yes3 pts
- No0 pts
Roadside Inspection During Malfunction*
- No3 pts
- Yes1 pt
Repair
9 fieldsRepair Or Replacement Arranged*
- Yes3 pts
- No0 pts
Date Repaired
Days To Repair*
Within Regulatory Window*
- Yes3 pts
- Late0 pts
Extension Requested
- Not needed3 pts
- Granted2 pts
- Refused0 pts
Data Recovered From Device*
- Yes3 pts
- Partly1 pt
- No0 pts
Paper Records Transcribed To System*
- Yes3 pts
- No0 pts
Records Retained*
- Yes3 pts
- No0 pts
Device Verified Working*
- Yes3 pts
- No0 pts
Related records
1 fieldLog Review ID
The review affected by the malfunction.
Links to FLT-019 Review ID
Pattern
11 fieldsRecurring Malfunction This Device*
- No3 pts
- Yes0 pts
Fleet Wide Issue*
- No3 pts
- Yes0 pts
Supplier Escalation Raised
- Yes3 pts
- Not needed3 pts
- No0 pts
Action Required*
Raise the action record, then enter its reference here.
- No2 pts
- Yes0 pts
Priority
- High0 pts
- Medium1 pt
- Low3 pts
CAPA ID
Format CAPA-2026-00000.
Links to FDN-014 CAPA ID
Action Owner
Compliance*
Signature*
Fleet Manager*
Second Signature*
FLT-022 · record IDs look like ELD-2026-000 · Links Asset, Worker
Open in KnowellaRun it with agents
From a document you fill in to a programme that runs itself
The record itself takes a driver four minutes. What slips is everything around it: noticing the clock is running, chasing the repair before the window closes, spotting that the same device has failed three times.
Holds the malfunction records against the vehicle and driver registers, starts the repair clock at discovery rather than at booking, and escalates any record approaching its window.
Carries the repair side — work order, replacement unit, verification that the device records again — so Device Verified Working comes from a maintenance record, not from memory.
Keeps the retention clock on the paper logs and transcribed records, so a request for six months of duty status does not become a search.
Watches for the patterns nobody has time to look for — repeated malfunction types, notification gaps drifting upward, extensions never requested — and holds every write for approval before it touches a record.
This template lives in KnowFleet — fleet and transport. Drivers, vehicles, hours, cargo securement and operator licence compliance.
Meet KnowFleet→Glossary
ELD Malfunction Record definitions and key terms
- Electronic logging device
- Hardware synchronised to the engine that records driving time automatically. Certified and registered with the regulator, unlike a general telematics unit.
- Record of duty status
- The driver's log of driving, on-duty, off-duty and sleeper time for a 24-hour period. Electronic in normal operation, paper during a malfunction.
- Data diagnostic event
- A flag raised when data needs attention, most often unidentified driving, without a required function having failed.
- Unidentified driving
- Movement recorded by the device with no driver logged in. It must be reviewed and either claimed by a driver or annotated by the carrier.
- Repair window
- The fixed period to repair, replace or service a malfunctioning device, counted from carrier notification rather than from discovery.
FAQ
Frequently asked questions about eld malfunction record
Does a malfunction put the vehicle out of service?+
Not by itself. The vehicle can continue provided the driver switches to paper immediately and the carrier acts within the repair window. What puts a driver out of service at the roadside is being unable to produce the current period and the previous seven days in some form.
How many records should one malfunction generate?+
One, covering discovery through verified repair. If the same device fails again after being verified working, that is a second record and the Recurring Malfunction This Device field on it is what makes the pattern visible.
Who signs the record?+
Two people. Compliance signs that the interim obligations were met; the fleet manager signs that repair and data recovery were completed. Splitting it stops the person who arranged the repair certifying paperwork they never saw.
What if the driver cannot tell which malfunction type it is?+
Record the code if the device shows one and pick the closest type. Misclassification is recoverable; a missing record is not. The type matters for pattern analysis, not for the paper obligation, which applies regardless.
Is this record scored?+
Answers carry scores but the record is not banded pass or fail. The scored fields exist so weak points — late notification, delayed paper, missed windows — surface in reporting rather than being averaged into a percentage that hides them.
Can the template be changed?+
Yes. Every field, option, score and conditional rule is editable, and the links to the asset and worker registers come with it. Fleets outside the United States most often change the repair window wording and the reconstruction period, and leave the rest as it stands.
Keep going
Related templates and programmes
Industries this is written for
Programmes this belongs to
Used together in Fleet and Driver Compliance
Transport Provider Assessment
Assesses a haulier for licensing, driver management, vehicle standards, temperature capability and load security
Driver Vehicle Inspection Report
The pre-trip and post-trip inspection a driver completes on a commercial vehicle
Annual Vehicle Inspection
The yearly statutory inspection of a commercial vehicle
Trailer Inspection
Checks trailer coupling, brakes, lights, tyres, doors and structure
Reefer Unit Check
Checks refrigeration unit operation, fuel, temperature setpoint and alarm history
Vehicle Defect Report
Reports a defect found on a vehicle at any time, not just during a scheduled inspection
More in Hours of Service
Hours of Service Log Review
Reviews driver hours logs for compliance with driving and rest limits
Hours of Service Violation Record
Records a specific hours of service breach and what was done about it
Fatigue Risk Assessment
Assesses fatigue risk from schedules, night driving, trip length and rest quality
Written and reviewed by
Siddarth Singh
Founder & Chief Executive Officer, Knowella
Certified Safety Professional and industrial and systems engineer with more than a decade inside food supply chain, freight and manufacturing operations. This page was written against the current text of the standards it cites, not against secondary summaries of them.
- Certified Safety Professional (CSP), Board of Certified Safety Professionals
- MBA, University of Chicago Booth School of Business
- MS and BS, The Ohio State University, Industrial and Systems Engineering
- Six Sigma Black Belt
Sources and last review. Reviewed 16 August 2026 against:
- 49 CFR 395.34 — ELD malfunctions and data diagnostic events
- 49 CFR 395.8 — Driver's record of duty status
- 49 CFR 395.22 — Motor carrier responsibilities, general
- Commercial Vehicle Drivers Hours of Service Regulations (SOR/2005-313), Canada
- Regulation (EU) No 165/2014, Article 37 — Faulty tachograph equipment
This page is general guidance, not legal advice. Confirm requirements with your jurisdiction’s regulator.