Driver Qualification File Checklist
Every motor carrier must keep a driver qualification (DQ) file for each driver it employs. This checklist walks through what 49 CFR 391.51 says goes in the file, what the job application must cover, and how long you have to keep each piece.
Updated September 28, 2026 · Checked against the federal regulations
The DQ file checklist
Section 391.51(a) requires a DQ file for each driver you employ. It may be combined with the driver's personnel file. Under 391.51(b), the file must include:
- The driver's application for employment, completed under 391.21.
- The motor vehicle record (MVR) from each state where the driver held a license in the last 3 years, obtained at hire under 391.23(a)(1).
- The certificate of driver's road test (391.31), or a copy of the license or certificate you accepted as equal to the road test (391.33).
- The MVR from each annual driving record inquiry (391.25(a)).
- A note about each annual review of the driving record (391.25(c)(2)).
- The medical examiner's certificate or a legible copy. For CDL holders, the CDLIS MVR from the current licensing state that shows medical certification status.
- Any medical variance, Skill Performance Evaluation Certificate (391.49), or federal Medical Exemption document.
- For drivers who do not need a CDL, a note showing you verified the medical examiner was on the National Registry of Certified Medical Examiners (391.23(m)(1)).
What the employment application must include
Section 391.21 says the application must be on a form you furnish, completed and signed by the applicant. It must include:
- Your company's name and address, and the applicant's name, address, date of birth, and Social Security number.
- Addresses where the applicant lived in the past 3 years, and the date of the application.
- Each unexpired CMV license or permit: issuing state, number, and expiration date.
- Driving experience and types of equipment operated.
- Accidents in the past 3 years, and traffic convictions or forfeited bonds (other than parking) in the past 3 years.
- Any license denial, revocation, or suspension, or a statement that none occurred.
- Employers in the past 3 years, with dates, reason for leaving, and whether the job was subject to the FMCSRs and DOT drug and alcohol testing.
- For CDL applicants, CMV driving employers for the 7 years before that 3-year period.
- The signed certification that the application is true and complete.
Road test or equivalent
Under 391.31, a driver must pass a road test and get a certificate before driving a CMV. Keep the original signed road test form and the original or a copy of the certificate in the DQ file. Give the driver a copy of the certificate.
Under 391.33, you may accept a valid CDL (not counting double/triple trailer or tank vehicle endorsements) or a road test certificate issued in the past 3 years instead. If you do, keep a legible copy in the DQ file. You may still require your own road test.
Keep these in separate files
The replies from previous employers about a driver's safety performance history go in a driver investigation history file under 391.53, not the DQ file. That file must be kept in a secure place with controlled access. Your insurer may see it, except the drug and alcohol data.
Drug and alcohol testing records, including Clearinghouse query results, are kept under Parts 382 and 40 with their own confidentiality and retention rules.
How long to keep DQ file records
Under 391.51(c), keep the DQ file for as long as the driver works for you and for three years after.
Under 391.51(d), some items may be removed three years after the date they were executed, even while the driver still works for you:
- Annual MVRs (391.25(a)).
- Annual review notes (391.25(c)(2)).
- Medical examiner's certificates, or for CDL drivers the CDLIS MVRs used as medical proof.
- Medical variances, SPE certificates, and Medical Exemption letters.
- National Registry verification notes (391.23(m)).
Yearly upkeep
At least once every 12 months, get an MVR for each driver from each state where they held a CMV license or permit, covering at least the prior 12 months (391.25(a)). Review it to decide whether the driver meets minimum safe driving requirements or is disqualified, and file a note with the reviewer's name and the review date (391.25(b) and (c)).
Pact Compliance pulls MVRs and keeps driver records organized for small fleets.
Common questions
Can the DQ file be part of the personnel file?
Yes. Section 391.51(a) says a driver's qualification file may be combined with the personnel file.
How long must I keep a DQ file after a driver leaves?
Three years after employment ends (391.51(c)).
Can I throw out old annual MVRs and medical cards?
Yes, once they are three years past their date of execution. Section 391.51(d) lists the items that may be removed: annual MVRs, annual review notes, medical certificates (or CDLIS MVRs), medical variances and SPE certificates, and National Registry verification notes.
Do previous employer replies go in the DQ file?
No. They go in the separate driver investigation history file under 391.53, which must be kept secure with limited access.
Does a CDL count as a road test?
It can. Under 391.33, you may accept a valid CDL as equal to the road test, except for double/triple trailer or tank vehicle endorsements. Keep a legible copy in the DQ file.
Sources
- 49 CFR 391.51 (eCFR)
- 49 CFR 391.21 (eCFR)
- 49 CFR 391.25 (eCFR)
- 49 CFR 391.31 (eCFR)
- 49 CFR 391.33 (eCFR)
- 49 CFR 391.53 (eCFR)
- 49 CFR 391.23 (eCFR)