Securing HVIP funding is a major milestone it places your fleet at the forefront of California’s clean transportation movement. But it also triggers three years of operational, reporting, and labor compliance to prove your vehicles are delivering real impact.
From operating primarily in-state to meeting quarterly OEM telematics deadlines, staying compliant keeps your investment protected and your fleet eligible for future incentives. Missed reports or documentation gaps can lead to penalties or even funding clawbacks.
At Leke Services, we handle every step of this process: managing scheduling, reporting, and coordination with manufacturers so you can stay focused on running your operations. Here’s where to focus to ensure you comply with HVIP.
- Telematics reporting
The good news for fleet managers is that all vehicles funded by the HVIP come equipped with an active telematics system managed directly by the original equipment manufacturer (OEM).
That means less paperwork and fewer administrative headaches—data on GPS location and mileage is automatically collected and transmitted to verify in-state use and track benefits in disadvantaged communities (DACs).
Still, it pays to stay vigilant. Even though the OEM handles reporting, fleet managers should regularly review their telematics data to spot any discrepancies early—before CARB does. A quick check now can save a lot of trouble later and keep your fleet’s compliance spotless.
Key Reporting Obligations (OEMs):
Submit quarterly reports for three years, including:
- Hours of operation.
- Total miles and % of miles in DACs.
- % of days vehicles end in DACs.
- Whether the vehicle is domiciled in a DAC.
CARB Oversight:
Vehicles showing zero miles for two consecutive quarters may be flagged.
CARB can request explanations or documentation to confirm vehicles are not idle or out of compliance.
- Operate in California
HVIP requires vehicles to operate in California for at least three years after voucher redemption, ensuring the state realizes the emissions benefits of its investment. While this is the default expectation, there are structured exceptions:
Despite these allowances, the majority of vehicle use must remain within California during the compliance period. Exceeding these limits risks non- compliance, clawback of voucher funds, and loss of eligibility for future incentives.
- AB 794 Labor Attestation
Fleets that receive HVIP vouchers are also required to complete an annual AB 794 labor law attestation for at least three years. This rule links clean-vehicle funding to fair employment practices ensuring accountability, transparency, and ethical operations across California’s green transition.
What the Attestation Confirms:
- The fleet has no outstanding labor violations at the time of application.
- The operator is not listed under Labor Code §2810.4, which identifies offenders with unpaid wages, taxes, or workers’ compensation.
- The company maintains ongoing compliance with all state labor laws, including:
- Fair wage and hour practices.
- Worker safety standards.
- Prevention of worker misclassification.
- Operational Responsibilities:
- Fleet operators must retain direct control over individuals driving HVIP-funded vehicles.
- This prevents outsourcing accountability for labor conditions through third parties.
- Submission and Enforcement:
- Attestations are submitted through the CARB online portal.
- Missing a renewal makes the fleet temporarily ineligible for future incentives until corrected.
- Complaints may trigger investigations or enforcement actions by CARB.
In short, AB 794 keeps the focus on responsible job practices rewarding fleets that uphold both environmental and labor integrity.
- Annual usage surveys
Under HVIP rules, fleets must complete an annual usage survey for three years after redeeming a voucher. These short surveys allow CARB to verify compliance and measure the real-world impact of zero-emission vehicles across California.
What the Survey Cover
- Total miles driven.
- Current operational status of each vehicle.
- Whether the vehicle is domiciled in California.
- Fleet experiences with vehicle integration and performance.
Why It Matters
Missing a survey can temporarily flag your fleet as ineligible for future vouchers. To stay compliant, set automated reminders and assign clear ownership within your team to ensure submissions are never missed.
Recordkeeping Requirements (3 Years)
- Purchase invoices and voucher redemption records.
- DMV registration documentation.
- Usage and maintenance logs confirming California operations.
Accuracy and Accountability
Survey responses must align with telematics data and internal logs. Discrepancies or inaccurate submissions can lead to voucher clawbacks, loss of eligibility, or enforcement actions.
If a zero-usage period occurs—such as during repairs or infrastructure delays—document the reason and notify CARB promptly.
Pro Tip
Keep your contact information updated with program administrators, so survey requests and compliance notices reach the right people, even during staff transitions.
By staying proactive and organized, fleets can easily maintain compliance and demonstrate the long-term success of their clean vehicle investments.
Quick HVIP Compliance Checklist
Use this checklist to stay compliant, unlock long-term funding eligibility, and maximize the value of your HVIP-funded vehicles.
- Setup (Day One)
- Activate and verify your vehicle’s telematics system immediately. Confirm that data transmission to the OEM is working and consistent with your internal logs.
- Begin mileage and route monitoring from day one.
- If you anticipate exceeding mileage thresholds, request written approval from CARB in advance to prevent violations.
- Ongoing Monitoring
- Use OEM dashboards to:
- Validate in-state mileage shares.
- Identify opportunities to route vehicles through Disadvantaged Communities (DACs).
- Review telematics and mileage reports quarterly to confirm accuracy and compliance with in-state operation limits (25% or 50% out-of-state cap depending on vehicle type).
- Align operations with both HVIP requirements and your organization’s ESG reporting goals.
- Monitor DAC performance metrics, watch for zero-mile flags, and optimize routes early.
- Annual Requirements
- Mark your voucher redemption date and schedule three annual survey deadlines aligned to it—don’t miss a reporting window.
- Complete the AB 794 labor attestation annually (for drayage and short-haul fleets). Confirm no outstanding judgments before submission.
- Recordkeeping (3 Years)
- Maintain a dedicated compliance folder with:
- Purchase invoices and voucher redemption records.
- DMV registration documents.
- Usage and maintenance logs verifying California operations.
- Keep program contact information up to date so survey links and notices always reach the correct compliance lead.
- Maintain a dedicated compliance folder with:
Pro Tip:
A few minutes each month spent reviewing data and documentation can save thousands in retained incentives and protect your eligibility for future HVIP funding.
Remember!
HVIP post-purchase compliance can be straightforward with proper scheduling, telematics, reporting, and annual attestations. Treat these steps as part of your routine
