IFTA Ballot Proposals Comments

IFTA Ballot Comments

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1st Period Comments on FTPBP #4 - 2026

Jurisdiction Position Comments
Support: 15
Oppose: 1
Undecided: 1

CALIFORNIA		 Undecided The Jurisdiction of California is Undecided with this ballot.  We are concerned with possible unintended consequences by making this section so specific that it will limit acceptable records.

ILLINOIS		 Support

INDIANA		 Support Indiana supports but additional language should be included with examples that would be considered verification of the transaction listing generated by a third-party fuel card system involved in the original transaction.

Industry Advisory Committee		 Oppose – The IAC, considering the input of other industry stakeholders, formally oppose the proposed amendment to IFTA Procedures Manual Section P550.220.015, which would restrict acceptable fuel records to transaction listings generated exclusively by the "third party fuel card system involved in the original transaction". While we appreciate the sponsor's intent to improve the consistency and reliability of fuel purchase documentation, we believe the proposed language may have the unintended consequence of reducing audit efficiency and limiting the ability of carriers to present complete and accurate fuel records. Additionally, we wonder if the ballot is attempting to solve a problem that doesn’t exist. Auditors already have the ability to request original fuel card records when necessary.

This ballot should be opposed for the following reasons:

1. Data Accuracy and Auditor Burden

The proposal appears to assume that the raw data generated by the original fuel card transaction is always the most accurate representation of the purchase. In practice, this data frequently contains human errors—such as incorrect or transposed unit numbers entered by drivers, or fuel assigned to the wrong vehicle at the point of sale. Currently, it is standard practice for service providers and carriers to correct these errors within their systems to ensure accurate reporting. Fuel card providers, however, will not correct them after the transaction has occurred. If auditors are restricted to viewing only the original fuel card provider's listing, they will be forced to spend significantly more time manually identifying and reconciling correct unit numbers. The objective of the audit should be to verify tax-paid fuel and fleet activity as accurately as possible, not simply verify the original transaction record.

2. Fragmentation of Transaction Data

Many carriers utilize multiple fuel card vendors, cash purchases, onsite bulk fuel, cardlock systems, and emergency purchases during a reporting period. A comprehensive transaction file that consolidates all fuel activity provides auditors with a more complete and efficient audit record than multiple disconnected reports generated by separate vendors.

3. Misunderstanding of Modern Data Transfer (APIs)

Modern recordkeeping systems frequently import transaction data directly from the original fuel card provider through automated data transfers. The resulting reports are often generated from the same underlying transaction data supplied by the card vendor. The proposed language creates uncertainty regarding whether these reports remain acceptable even when they are derived directly from original source data.

The original data from API typically results in a flat text file output. There is concern that some jurisdictions may not be able to translate that flat text file to an excel or csv format.

4. Ambiguity and Inconsistent Interpretation

The proposed language creates uncertainty regarding what constitutes a "third-party fuel card system involved in the original transaction." It is unclear whether reports generated from API-fed systems, carrier fuel management platforms, or third-party compliance systems would remain acceptable when they are derived directly from original source data. This ambiguity could result in inconsistent interpretation among jurisdictions and create unnecessary disputes during audits.

5. Impact on Service Providers

The proposal may unintentionally limit the use of established recordkeeping systems that carriers rely upon to organize, validate, and retain fuel purchase information. These systems often provide important audit functions, including error correction documentation, reconciliation records, exception tracking, and consolidated reporting. Restricting their use may reduce audit efficiency without improving the reliability of the underlying transaction data. It is well known that original transaction data often includes data entry errors that the fuel card provider will not correct. Allowing auditors access to both allows for greater efficiency in auditing and verification that proper taxes have been paid. Summary

Rather than limiting the source of the records to the original card provider, we believe the Procedures Manual should focus on the reliability, traceability and auditability of the records presented. Auditors should have access to the original fuel card data as well as any supporting records that demonstrate how the reported fuel data was compiled, reconciled, and corrected. Maintaining both elements of the audit trail promotes accuracy, preserves flexibility for carriers and jurisdictions, and supports a more efficient audit process.

Additionally, Audit Procedures Manual A320 refers to the licencee’s internal controls. The corrective measures taken by service providers and carriers show internal controls of data prior to filing any returns.

For these reasons, we strongly oppose Ballot Proposal #04-2026 as currently written.

KANSAS		 Support Kansas does support this ballot, 

Updating the language would help to eliminate any confusion on accepting the documentation of 3rd party fuel receipts. I also agree that all records produced by a licensee should provide the essential information required by the Agreement and Procedures Manual. 

KENTUCKY		 Support

MANITOBA		 Support

MARYLAND		 Support This clarification would eliminate confusion regarding the documentation required for third party fuel card receipts. Additional language should be included to explicitly define the criteria for acceptable third‑party fuel receipt documentation.

MICHIGAN		 Support

NEVADA		 Support NV supports and agrees with Indiana's comment.

NEW BRUNSWICK		 Support

NORTH CAROLINA		 Support North Carolina supports this ballot as it agrees with the sponsor that clear, consistent, and reliable records provided in accordance P550 are critical to administering the fuel tax.
 
However, North Carolina has concerns regarding the phrase "fuel card system." This phrase may be unnecessary, vague, and potentially limits solutions in an ever-evolving technology driven market.
 
North Carolina suggests the following changes (underlines and strikethroughs are not applied):
 
.015      a transaction listing generated by a third party involved in the original fuel purchase transaction, or

 

ONTARIO		 Support

PENNSYLVANIA		 Support

QUEBEC		 Support The jurisdiction of Quebec agrees with the ballot, which aligns with the relevant audit practices.

SASKATCHEWAN		 Support The proposed amendment provides additional clarity regarding the nature and source of acceptable transaction listings used to substantiate tax-paid fuel credits. By limiting acceptable records to those generated by the original fuel card processing system, the amendment promotes greater consistency between jurisdictions and reinforces reliance on primary source documentation. The proposal does not significantly alter existing documentation requirements but rather strengthens audit standards by clarifying the reliability expectations associated with electronic fuel transaction records. The amendment may also reduce disagreements during audits by providing more direction on what is considered acceptable supporting documentation.

WASHINGTON		 Support
Support: 15
Oppose: 1
Undecided: 1

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