Driver Qualification File Checklist: What Every DQ File Needs

What goes in a driver qualification file?

49 CFR 391.51 lists what each DQ file must contain. Use this checklist for every driver:

• Employment application (391.21), signed and dated, with 3 years of addresses and employers, plus 7 more years of employers for drivers who drove a CMV.
• MVR from every state where the driver held a license or permit in the past 3 years, requested within 30 days of hire (391.23).
• Road test certificate (391.31), or an accepted equivalent such as a valid CDL or a road test certificate from the last 3 years (391.33).
• Annual MVR from each licensing state, at least once every 12 months (391.25).
• Annual review note with the reviewer's name and date (391.25).
• Medical examiner's certificate (391.43), and for CDL drivers, the CDLIS MVR showing medical status. Add any medical variance or Skill Performance Evaluation Certificate.
• For non-CDL drivers, a National Registry verification note showing the medical examiner was listed on the National Registry of Certified Medical Examiners.

How do I verify the medical certificate?

The driver must have a current medical examiner's certificate before driving. For non-CDL drivers, you check that the examiner is listed on the National Registry and keep a note in the DQ file.

For CDL drivers, FMCSA moved to an electronic system (National Registry II) with a June 23, 2025 compliance date. Examiners now send results to FMCSA, which passes them to the state. You confirm medical status on the driver's CDLIS MVR from the current licensing state. Keep that record in the file.

What is the previous employer safety performance history check?

Within 30 days of hire, you must check the driver's safety performance with DOT-regulated employers from the past 3 years (391.23). This covers basic employment verification and accident history.

You also must check drug and alcohol history. For prior FMCSA-regulated employers, this is done through the Clearinghouse. Since January 6, 2023, the full pre-employment Clearinghouse query (382.701) takes the place of contacting those employers for drug and alcohol records. For employers regulated by other DOT agencies, such as the FAA or FTA, you still request records directly under 49 CFR 40.25, with the driver's written consent.

These responses, or notes showing your good-faith attempts, go in a separate driver investigation history file (391.53). It must be kept in a secure place with limited access.

Do Clearinghouse queries belong in the DQ file?

Clearinghouse queries are a drug and alcohol requirement under Part 382, not a 391.51 item. Still, an auditor reviewing a driver will often ask to see them. Keep proof of the pre-employment full query and each annual query where you can find it fast, either with the DQ file or your drug and alcohol records.

How long do I keep DQ files?

Keep the whole DQ file while the driver works for you and for 3 years after they leave (391.51(c)). The driver investigation history file has the same rule (391.53).

Some items can be removed 3 years after the date they were made (391.51(d)): annual MVRs, annual review notes, medical certificates and CDLIS MVRs, medical variances and SPE certificates, and National Registry verification notes.

Which DQ file mistakes can fail an audit?

Under 49 CFR 385.321, a new entrant automatically fails its safety audit for knowingly using a driver without a valid CDL, a disqualified driver, or a physically unqualified driver. A driver without a valid medical certificate is not physically qualified.

Smaller gaps, like a missing annual review or a late MVR, may not fail an audit by themselves, but they add up. We check every file against the list above so these gaps get closed early.