Free resource 49 CFR §391.51

Driver qualification file checklist for 2026

Every item FMCSA expects in a driver qualification file, when it’s due and how long to keep it, with the regulation for each one.

LAST REVIEWED SEPTEMBER 24, 2026

What goes in a DQ file?

A driver qualification file holds the driver’s employment application, pre-employment and annual motor vehicle records, the annual review of the driving record, a road test certificate or equivalent, and the medical examiner’s certificate or, for CDL drivers, the state record of medical status. Carriers keep it for the length of employment plus three years (49 CFR §391.51).

Who this applies to. Part 391 covers drivers of commercial motor vehicles as defined in §390.5, which in interstate commerce includes many non-CDL trucks of 10,001 pounds or more. The drug and alcohol items apply to CDL drivers under Part 382. Check the definitions for your operation.

Before the driver’s first trip

At hire
  • Application for employment

    Signed application covering the past 3 years of employers. CDL drivers also list employers they drove a CMV for during the 7 years before that.

    §391.21
  • Pre-employment motor vehicle record

    An MVR from every state where the driver held a license or permit in the past 3 years. It must be in the DQ file within 30 days of hire.

    §391.23(a)(1)
  • Previous employer safety performance history

    Inquiries to DOT-regulated employers from the past 3 years, within 30 days of hire. For CDL drivers, the Clearinghouse full query covers drug and alcohol history with FMCSA-regulated employers; ask employers in other DOT modes directly. Keep the responses in the separate driver investigation history file (§391.53).

    §391.23(a)(2)
  • Road test certificate, or accepted equivalent

    A road test certificate, or a valid CDL or road test certificate accepted in its place under §391.33. A CDL does not replace the road test for double/triple trailer or tank vehicle work.

    §391.31
  • Medical examiner’s certificate

    The driver’s current medical certificate. For CDL drivers, get the CDLIS motor vehicle record, which shows medical certification status (§391.51(b)).

    §391.43
  • National Registry verification note (non-CDL drivers)

    A note showing you verified the medical examiner was listed on the National Registry of Certified Medical Examiners. Since June 23, 2025, this note is no longer needed for CDL drivers, whose medical status comes through the state record.

    §391.23(m)
  • Pre-employment drug test result (CDL drivers)

    A verified negative result before the driver performs any safety-sensitive function. Keep it with your drug and alcohol records.

    §382.301
  • Clearinghouse full query (CDL drivers)

    A full pre-employment query of the Drug and Alcohol Clearinghouse, with the driver’s electronic consent.

    §382.701(a)
  • Drug and alcohol policy receipt (CDL drivers)

    The driver’s signed statement that they received your drug and alcohol policy and educational materials.

    §382.601

Every year

Annual
  • Annual motor vehicle record

    An MVR from each state where the driver holds a license or permit, at least once every 12 months.

    §391.25(a)
  • Annual review of driving record

    A note with the reviewer’s name and the date, showing you reviewed the MVR and decided whether the driver meets your minimum requirements.

    §391.25(c)(2)
  • Clearinghouse annual query (CDL drivers)

    At least one query per year for every CDL driver you employ. A limited query needs the driver’s general consent.

    §382.701(b)

Every 24 months or sooner

Medical
  • New medical examiner’s certificate

    A medical certificate lasts up to 24 months. Examiners often issue shorter terms, so track the actual date on each certificate.

    §391.45

How long to keep it

Retention
  • Keep the whole DQ file for employment plus 3 years

    After the driver leaves, the file stays for three more years.

    §391.51(c)
  • Some items can be removed after 3 years

    Annual MVRs, annual review notes, medical certificates, medical variance or exemption documents and National Registry notes may be removed three years after the date they were created.

    §391.51(d)

A summary for reference, not legal advice. Check the current text at eCFR, 49 CFR §391.51.

Track this checklist automatically

Compliant Fleet tracks the core items above on one DQ file matrix for your whole roster, dates each one, warns you before annual and medical items come due, and builds an audit-ready DQ file report in one click.