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The Annual MVR Review Under 49 CFR 391.25

At least once a year, every motor carrier must pull and review each driver's motor vehicle record (MVR). It is a simple rule, but it is easy to miss a driver or forget the written note. Here is exactly what 391.25 requires.

Updated September 28, 2026 · Checked against the federal regulations

Step 1: Get the MVR at least every 12 months

At least once every 12 months, request the MVR for each driver you employ. It must cover at least the past 12 months.

Request it from each driver's licensing authority where the driver held a commercial motor vehicle license or permit during that time. If a driver moved and held a license in two states, you need both. Canadian and Mexican licensing authorities count too.

Step 2: Review the record

Also at least once every 12 months, review each MVR. Decide whether the driver meets the minimum requirements for safe driving or is disqualified under 391.15. When you review, you must:

• Consider any evidence the driver broke the Federal Motor Carrier Safety Regulations or Hazardous Materials Regulations
• Consider the driver's accident record
• Consider any evidence the driver broke laws on operating motor vehicles
• Give great weight to violations like speeding, reckless driving, and driving under the influence of alcohol or drugs

Step 3: Keep the MVR and a review note

Put a copy of each MVR in the driver qualification (DQ) file. Also add a note that shows who did the review and the date. Auditors look for both.

A simple note works: driver name, the states or authorities checked, the date of review, the reviewer's name, and the result.

The annual list of violations is gone

Carriers used to also make each driver fill out an annual list of traffic violations (the old 391.27 "record of violations"). FMCSA removed that rule effective May 9, 2022. Today 391.27 is reserved.

The annual MVR inquiry and review in 391.25 stayed in place. That same rule change is why 391.25 now says "licensing authority" instead of just "State."

How long to keep annual MVRs and notes

The annual MVR and the review note may be removed from the DQ file 3 years after the date they were executed. The DQ file itself must be kept while the driver works for you and for 3 years after.

The annual MVR is separate from the hiring MVR. At hire, you must request a 3-year MVR from each licensing authority within 30 days of the date employment begins.

Pact Compliance pulls MVRs and tracks medical card dates for small fleets.

Common questions

Sources

• 49 CFR 391.25 – Annual inquiry and review of driving record
• 49 CFR 391.27 – [Reserved]
• Federal Register: Record of Violations final rule (87 FR 13192)
• 49 CFR 391.23 – Investigation and inquiries
• 49 CFR 391.51 – Driver qualification files