1. IRP/IFTA Adequacy of Records IRP -1005 International Registration Plan IFTA - P530 IFTA Procedures Manual

2. IRP 1005 ADEQUACY OF RECORDS (a) The Records maintained by a Registrant under Section 1000 shall be adequate to enable the Base Jurisdiction to verify the distances reported in the Registrant’s application for apportioned registration and to evaluate the accuracy of the Registrant’s distance accounting system for its Fleet. (b) Provided a Registrant’s Records meet the criterion in subsection (a), the Records may be produced through any means, and retained in any format or medium available to the Registrant and accessible by the Base Jurisdiction.

3. IRP Official Commentary Subsection (a) defines the purpose for which Registrants are required to keep Records: to allow the Base Jurisdiction to (1) verify the distances a Registrant has reported on its application, and (2) evaluate the Registrant’s distance accounting system. If the Records made available by a Registrant for Audit are (a) sufficient and (b) appropriate for these purposes, they are deemed to be adequate. Subsection (b) is intended to make clear that if the Registrant’s Records are adequate under subsection (a), it does not matter how the Registrant has produced the Records or maintained them. However, the Records must meet the two conditions of sufficiency and appropriateness; there must be enough Records to substantially cover the operations of the Registrant’s Fleet, and the Records must contain the kind of information an auditor needs in order to audit the Records for purposes of the Plan. In addition, if Records are presented in a format or in a manner in which the Base Jurisdiction cannot audit them, they have not been “made available” as required.

4. IFTA P530 ADEQUACY OF RECORDS The records maintained by a licensee under this article shall be adequate to enable the base jurisdiction to verify the distances traveled and fuel purchased by the licensee for the period under audit and to evaluate the accuracy of the licensee’s distance and fuel accounting systems for its fleet. The adequacy of a licensee’s records is to be ascertained by the records’ sufficiency and appropriateness. Sufficiency is a measure of the quantity of records produced; that is, whether there are enough records to substantially document the operations of the licensee’s fleet. The appropriateness of the records is a measure of their quality; that is, whether the records contain the kind of information an auditor needs to audit the licensee for the purposes stated in the preceding paragraph. Records that are sufficient and appropriate are to be deemed adequate.

5. IFTA Provided a licensee’s records are adequate under this definition, the records may be produced through any means, and retained in any format or medium available to the licensee and accessible by the base jurisdiction. If records are presented in a format or in a manner in which the base jurisdiction cannot audit them, they have not been made available as required. Licensee records which do not contain all of the elements set out in P540, P550 and P560 may still, depending on the sufficiency and appropriateness of the records and of the licensee’s operations, be adequate for an audit. Please note: P540 – Distance Records; P550 – Fuel Records; P560 Summaries.

6. Application Examples - How we apply it How does your jurisdiction apply it?

7. Examples for Discussion Missing records – full units –Example: 1 unit missing in 5 unit fleet –What if 2 units? 3? 4? Partial records –No odometer readings –No routes –Other? Missing summaries