Driver qualification file: what goes in it and how to keep it current
Checked against official sources · Last reviewed October 6, 2026
A motor carrier must keep a driver qualification (DQ) file for every driver it employs. It can be combined with the driver's personnel file. Driver qualification records are one of the areas checked in the new entrant safety audit. [1][4]
On this page
DQ file checklist
The DQ file must hold these documents:
| Document | Rule |
|---|---|
| Employment application | 391.21 |
| Pre-employment MVR from each licensing state | 391.23(a)(1) |
| Road test certificate, or an accepted equivalent license or certificate | 391.31 / 391.33 |
| Annual MVR | 391.25(a) |
| Note of the annual driving record review | 391.25(c)(2) |
| Medical examiner's certificate or a copy; for CDL holders, the CDLIS MVR showing medical status | 391.51 |
| Any SPE certificate or medical exemption document | 391.51 |
| For non-CDL drivers, a note verifying the medical examiner is on the National Registry | 391.51 |
Sources: [1]
Checks when you hire
Within 30 days after a driver starts, ask every state where the driver held a license or permit in the past 3 years for the driver's 3-year driving record (MVR).
You must also look into the driver's safety performance history with DOT-regulated employers over the past 3 years. Within 30 days of hire, put the replies, or a record of your good-faith efforts to get them, in the driver investigation history file. [2]
Annual MVR and review
At least once every 12 months, get an MVR from each state where the driver held a CMV license or permit, covering at least the past 12 months.
Also at least once every 12 months, review each driver's record to decide whether the driver meets minimum safe-driving requirements or is disqualified. Put a note in the DQ file with the reviewer's name and the review date. [3]
Medical certification in the file
For CDL holders, you meet the medical-certificate requirement by getting the CDLIS motor vehicle record from the current licensing state and placing it in the DQ file. For non-CDL drivers, the file keeps the medical examiner's certificate (or a copy) and a note verifying the examiner is on the National Registry. [1]
Basic driver qualifications
Under Part 391, a driver must be at least 21 years old to drive a CMV, unless an exception applies. A driver must also read and speak English well enough to talk with the public, understand road signs, answer official questions, and fill in reports and records. [6]
How long to keep it
Keep the DQ file for as long as the driver works for you and 3 years after. Annual MVRs, review notes, medical certificates and medical variances may be removed 3 years after they were made. [1]
Why it matters in your first audit
Knowingly using a physically unqualified driver, or a disqualified driver, is an automatic failure of the new entrant safety audit. [4][5]
Common questions
How often do I need a new MVR for each driver?
At least once every 12 months, from each state where the driver held a CMV license or permit, covering at least the past 12 months. [3]
How long do I keep a DQ file after a driver leaves?
3 years after the driver stops working for you. [1]
Can the DQ file be part of the personnel file?
Yes. The regulation allows the DQ file to be combined with the driver's personnel file. [1]
Do I need a paper medical card in the file for a CDL driver?
For CDL holders, you meet the requirement by getting the CDLIS motor vehicle record from the current licensing state and placing it in the DQ file. [1]
Sources (6)
- eCFR - 49 CFR 391.51 General requirements for driver qualification files (via eCFR versioner API) (accessed Oct 6, 2026)
- eCFR - 49 CFR 391.23 Investigation and inquiries (via eCFR versioner API) (accessed Oct 6, 2026)
- eCFR - 49 CFR 391.25 Annual inquiry and review of driving record (via eCFR versioner API) (accessed Oct 6, 2026)
- eCFR - 49 CFR Part 385 Subpart D, New Entrant Safety Assurance Program (sections 385.301-385.337; via eCFR versioner API, current as of 2026-10-02) (accessed Oct 6, 2026)
- eCFR - 49 CFR 385.321 Safety audit: Failure (via eCFR versioner API) (accessed Oct 6, 2026)
- eCFR - 49 CFR 391.11 General qualifications of drivers (via eCFR versioner API) (accessed Oct 6, 2026)