Avoid this common error: HOS exemptions do not apply to IFTA or IRP

Logging mileage data can be a daunting task to begin with, and varying requirements under different regulatory programs can make it even more confusing.

Here’s an easy way to remember what you need to do: ALL miles of International Fuel Tax Agreement (IFTA) qualified vehicles and International Registration Plan (IRP) apportioned vehicles must be recorded. This includes:

  • Empty miles,
  • Miles accrued while the vehicle is operated for personal use, and
  • Miles accrued while the vehicle is sent for repairs.

Under these programs, personal use means times when a driver may be off duty and not required to log for hours of service (HOS) regulations, for example.

Both IFTA and IRP require you to report distance for:

  • Actual routes,
  • Each vehicle, and
  • Each trip.

IFTA mileage

Total distance under IFTA includes all miles or kilometers traveled during the tax reporting period by every qualified vehicle in your fleet, regardless of whether the miles or kilometers are considered taxable or nontaxable by a jurisdiction.

For quarterly fuel tax reporting, distance records must show:

  • Distance traveled for taxable and non-taxable use, and
  • Distance recaps for each vehicle for each jurisdiction in which the vehicle operated.

The supporting records must include the following mileage information for each vehicle and for each trip:

  • The beginning and ending reading from the odometer, hubodometer, engine control module (ECM), or any similar device;
  • Total trip distance; and
  • Distance traveled in each jurisdiction.

IFTA then uses the mileage information to distribute the fuel taxes collected to the jurisdiction where the travel actually occurred.

IRP mileage

Hours of Service ExemptionsTo substantiate their apportioned registration, IRP registrants must maintain operational records that support:

  • The total distance each vehicle traveled in each jurisdiction, and
  • Total distance traveled everywhere.

The source documents must contain sufficient detail that vehicle movement can be traced. When recording the mileage of an apportioned vehicle all movement (interstate and intrastate) must be included, as well as:

  • Loaded, empty, dead-head and/or bobtail miles or kilometers, and
  • All distance traveled while operating with trip permits.

IRP then distributes registration fees in proportion to the distance traveled in each jurisdiction.


Key to remember: ALL miles of IFTA qualified vehicles and IRP apportioned vehicles must be recorded, even if the driver is not required to record them under hours-of-service or other programs.

About the author
Corrina Peterson

Corrina is an editor on the Transportation publishing team. Her areas of expertise include fuel taxes, fleet taxes, vehicle registration, trip permitting, and the environmental impacts of transportation.

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