As of October 14, 2026, an FMCSA driver qualification file (DQF) must hold eight kinds of records listed in 49 CFR 391.51(b): the application, the pre-hire MVR, the road test certificate or its equivalent, each annual MVR, each annual review note, the medical certificate (or the CDLIS MVR for CDL holders), any medical variance or SPE certificate, and, for non-CDL drivers, the National Registry check. You keep the file for as long as the driver works for you and three years after (391.51(c)), and some recurring records may come out three years after they were made (391.51(d)). Drug and alcohol records and the previous-employer investigation file are kept separately.
New to driver files? Start with our full guide, The Driver Qualification File (DQF): What Goes In It and How to Keep It, then use this page as your working checklist.
What must be in an FMCSA driver qualification file?
Every motor carrier must keep a qualification file for each driver it employs (391.51(a)), including an owner-operator who drives for their own authority. The rule allows the DQF to be combined with the driver’s personnel file. Here is every item in 391.51(b), when it is due, and how long you keep it.
| # | Record (49 CFR 391.51(b)) | When it is due | How long to keep it |
|---|---|---|---|
| 1 | Employment application | Before the driver operates a CMV (391.21(a)) | Employment + 3 years |
| 2 | Pre-hire MVR from each licensing state | Inquiry made and copy in the file within 30 days of the start of employment (391.23(a)(1), (b)) | Employment + 3 years |
| 3 | Road test certificate, accepted equivalent, or 391.44(d) statement | Before the driver operates a CMV (391.31(a)) | Employment + 3 years |
| 4 | Annual MVR from each licensing state | At least once every 12 months (391.25(a)) | May be removed 3 years after it was made |
| 5 | Annual review note (reviewer’s name and date) | At least once every 12 months (391.25(b), (c)(2)) | May be removed 3 years after it was made |
| 6 | Medical examiner’s certificate, or the CDLIS MVR for CDL holders, plus any medical variance | Before the driver operates a CMV (391.23(m)); new exam at least every 24 months, or every 12 months in the cases in 391.45 | May be removed 3 years after it was made |
| 7 | Skill Performance Evaluation certificate or federal medical exemption, if the driver has one | When the driver’s qualification relies on it | May be removed 3 years after it was made |
| 8 | National Registry verification note (non-CDL drivers) | Before the driver operates a CMV (391.23(m)(1)) | May be removed 3 years after it was made |
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What does each DQF item require?
Each item below links to the rule on eCFR. The wording is a plain-English summary; the regulation controls.
1. Employment application (391.51(b)(1))
The driver’s application, completed under 391.21. The applicant must complete and sign it, on a form the carrier furnishes, before driving a CMV for you. It asks for, among other things, three years of addresses, every unexpired CMV license or permit, driving experience, and three years of accidents. Blank fields are a common audit finding.
2. Pre-hire motor vehicle record (391.51(b)(2))
Within 30 days of the date employment begins, you must ask every state where the driver held a license or permit in the past three years for an MVR covering three years, and place the copies in the DQF within that same 30 days (391.23(a)(1), (b)). If a state does not answer, document your good-faith effort. You can order MVRs in the Vertical Identity portal.
3. Road test certificate or equivalent (391.51(b)(3))
One of three things:
- The certificate of road test under 391.31(e). The carrier also keeps the original signed road test form (391.31(g)).
- A copy of the license or certificate you accepted as an equivalent under 391.33: a valid CDL (not counting double/triple trailer or tank vehicle endorsements) issued after a road test in the type of vehicle you will assign, or a road test certificate issued within the preceding three years.
- For a driver covered by 391.44(d), your original written statement that no road test is required plus the driver’s certification.
4. Annual MVR (391.51(b)(4))
At least once every 12 months, request the MVR from each state where the driver held a CMV license or permit during the period, covering at least the preceding 12 months (391.25(a)). A copy goes in the DQF (391.25(c)(1)).
5. Annual review note (391.51(b)(5))
Pulling the record is not enough. At least once every 12 months you must review it to decide whether the driver meets the minimum requirements for safe driving or is disqualified, giving great weight to violations such as speeding, reckless driving and operating under the influence (391.25(b)). The note in the file must include the name of the person who did the review and the date (391.25(c)(2)).
6. Medical certificate, or CDLIS MVR for CDL holders (391.51(b)(6))
- Non-CDL drivers: the medical examiner’s certificate issued under 391.43(g), or a legible copy.
- CDL holders: the CDLIS motor vehicle record from the driver’s current licensing state, which carries the medical certification status (391.51(b)(6)(ii)). The rule’s allowance to use a paper certificate copy for up to 15 days applied only through June 22, 2025.
- Medical variance: if the certification relies on an FMCSA medical variance, a copy of the variance goes in the file too (391.51(b)(6)(iii)).
All of this must be in the file before the driver operates a CMV (391.23(m)). Drivers need a new exam at least every 24 months, or every 12 months for some drivers, including insulin-treated diabetes under 391.46, the vision standard under 391.44, and exempt intracity zone drivers (391.45). A driver whose ability to do the job has been impaired by an injury or illness must be re-examined (391.45(g)). Need an exam? See DOT physicals.
7. Skill Performance Evaluation or medical exemption (391.51(b)(7))
If the driver has one: the SPE certificate issued by FMCSA under 391.49, or the medical exemption document from a federal medical program under part 381.
8. National Registry verification note (391.51(b)(8))
For drivers who do not need a CDL, a note showing you verified that the medical examiner was on the National Registry of Certified Medical Examiners on the date the certificate was issued (391.51(b)(8)(i), 391.23(m)(1)). The matching note for CDL drivers applied only through June 22, 2025 (391.51(b)(8)(ii)).
How is a CDL driver’s DQF different from a non-CDL driver’s?
The list is the same eight items. The medical proof is what changes.
| CDL holder | Non-CDL driver | |
|---|---|---|
| Medical proof in the DQF | CDLIS MVR from the current licensing state showing medical certification status (391.51(b)(6)(ii)) | Medical examiner’s certificate or a legible copy (391.51(b)(6)(i)) |
| National Registry note | Not listed for CDL drivers after June 22, 2025 (391.51(b)(8)(ii)) | Required (391.51(b)(8)(i)) |
| Also verify before driving | Using the CDLIS MVR: the type of operation the driver self-certified, and, for interstate drivers, a valid medical certificate and any required variance (391.23(m)(2)) | The certificate, any variance, and the National Registry check (391.23(m)(1)) |
| Road test equivalent | A valid CDL can stand in for the road test under the conditions in 391.33 | Road test certificate, or a road test certificate issued in the past three years (391.33(a)(2)) |
Commercial learner’s permit holders have their own CDLIS verification steps in 391.23(m)(3).
How long do you keep a driver qualification file?
For as long as the driver works for you and three years after that (391.51(c)). While the driver is still employed, 391.51(d) lets you remove these records three years after the date they were made:
- the annual MVRs,
- the annual review notes,
- the medical examiner’s certificate (or, for CDL drivers, the CDLIS MVR),
- any medical variance, SPE certificate or medical exemption letter, and
- the National Registry verification notes.
The application, the pre-hire MVR and the road test record stay for the whole employment plus three years.
What does NOT go in the DQF?
Two sets of records have their own rules and should be kept apart from the qualification file.
Drug and alcohol testing records. Part 382 records (test results, chain of custody forms, MRO documents, refusals, SAP evaluations, random selection documents, training records) must be kept “in a secure location with controlled access” with their own retention schedule: five years for positive results, refusals and violations, two years for collection-process records, and one year for negative and canceled results (382.401). Keep them in a separate, locked drug and alcohol file.
The driver investigation history file. The previous-employer safety performance history you gather under 391.23(d) and (e) (including the driver’s written consent, each employer’s response, and your good-faith efforts) goes in a separate driver investigation history file under 391.53. Access is limited to people involved in the hiring decision, the data may be used only for that decision, and your insurer may see it except for the drug and alcohol information. Replies are due in that file within 30 days of the start of employment (391.23(c)). For a driver you hire, keep the histories for the length of employment plus three years (391.53(c)). Since January 6, 2023, carriers subject to the Clearinghouse must use it for the drug and alcohol part of this check (391.23(e)(4)); see our Clearinghouse services.
Which extra checks are recommended but not required?
These are not on the 391.51(b) list. They are recommended pre-hire checks that many carriers add:
- PSP report (Pre-Employment Screening Program): crash and inspection history. Recommended, not required.
- CDLIS report: shows licenses the driver has held in other states, which helps you make sure you asked every state for an MVR. Recommended, not required.
- Criminal background check: recommended, not required.
The MVR is the required record. All of these are ordered in the same Vertical Identity portal.
Watch: how to start and keep a DQF for a new CDL driver
Our video lesson walks through building the file for a new hire step by step: How to Start and Keep a Driver Qualification File (DQF) for a New CDL Driver (YouTube).
What do auditors check first?
Investigators often go straight to the records that are easiest to miss:
- The annual review note, because carriers pull the MVR and never write down who reviewed it and when.
- The medical certificate date, because a lapsed certificate means the driver was not medically qualified on the days they drove.
- The National Registry note for non-CDL drivers, because it is a separate note many carriers do not know about.
- A complete, signed application.
Frequently Asked Questions
What documents are required in a driver qualification file?
Under 49 CFR 391.51(b): the employment application, the pre-hire MVR from each licensing state, the road test certificate or accepted equivalent, each annual MVR, each annual review note, the medical examiner’s certificate (or the CDLIS MVR for CDL holders) and any medical variance, any SPE certificate or medical exemption, and, for non-CDL drivers, the National Registry verification note.
How long must a carrier keep a driver qualification file?
For as long as the driver is employed and three years after (49 CFR 391.51(c)). Annual MVRs, annual review notes, medical certificates or CDLIS MVRs, medical variances and National Registry notes may be removed three years after the date they were made (391.51(d)).
Is the checklist different for CDL and non-CDL drivers?
Yes, mainly for medical records. For CDL holders, the CDLIS MVR from the current licensing state is the medical proof (391.51(b)(6)(ii)). For non-CDL drivers, you keep the medical examiner’s certificate and a note verifying the examiner was on the National Registry (391.51(b)(8)(i)).
How soon after hire must the MVR be in the DQF?
The inquiry to each state where the driver held a license in the past three years must be made, and the copies placed in the DQF, within 30 days of the date employment begins (49 CFR 391.23(a)(1) and (b)).
Do drug and alcohol test results go in the DQF?
No. Part 382 records must be kept in a secure location with controlled access under their own retention schedule (49 CFR 382.401). Previous-employer drug and alcohol history goes in the separate driver investigation history file (391.53).
Do owner-operators need a driver qualification file?
Yes. Each motor carrier must keep a DQF for each driver it employs (391.51(a)). An owner-operator who drives under their own authority keeps a file on themselves.
Is the annual MVR the same as the annual review?
No. 391.25(a) requires you to get the record at least every 12 months. 391.25(b) and (c)(2) require you to review it and keep a note with the reviewer’s name and the date. Both go in the file.
Is there a DQF checklist PDF?
You can print this page or save it as a PDF from your browser. Members also track every item in DQF Pro, which shows what is due for each driver.
Keep every DQF current with DQF Pro
A checklist tells you what belongs in the file. The hard part is keeping it current: annual MVRs come due, medical certificates expire and nobody owns the calendar.
DQF Pro is included in the Vertical Identity membership, $85/year for the first driver, with no add-on fee. It keeps each driver’s records in one place and tracks what is due, and you order MVRs, the recommended PSP, CDLIS and criminal background checks, and DOT drug tests from the same portal. See DQF Pro driver file management or read the full DQF guide.
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