Driver qualification files, complete at hire and current every year
Every driver, including the owner, needs a file that proves they are qualified: application, MVR, previous employers, road test, medical certificate, annual review, Clearinghouse queries. We build it for $49 per driver and keep it current for $9 per driver per month.
One file per driver, owner included
49 CFR 391.51 applies to every driver of a commercial motor vehicle. An owner-operator keeps a file on themselves. A missing file is treated as an unqualified driver at the new-entrant audit.
Dated at hire, refreshed each year
MVR and previous employer inquiries within 30 days of hire. New MVR, annual review and Clearinghouse limited query every 12 months. Medical certificate at most every 24 months.
Kept three years after separation
The file follows the driver for the whole employment and three years after. Old MVRs and medical certificates roll off after three years. Investigation records stay in a separate, restricted file.
What must be in the file, when, and how long it stays
| Document | Rule | When | Retention |
|---|---|---|---|
| Driver's application for employment | 391.21 | Before the driver starts | Employment plus 3 years |
| Motor vehicle record from each state or province, past 3 years | 391.23(a)(1) | Requested within 30 days of hire | 3 years from date |
| Previous employer safety performance history inquiries, 3 years | 391.23(a)(2), 391.53 | Requested within 30 days of hire | 3 years, separate investigation file |
| Clearinghouse pre-employment full query | 382.701(a) | Before first safety-sensitive function | 3 years |
| Road test certificate, or copy of CDL accepted in lieu | 391.31, 391.33 | Before the driver operates | Employment plus 3 years |
| Medical examiner's certificate, or MVR showing medical status for CDL drivers | 391.43(g), 391.51(b)(7) | At hire, then at each exam (24 months maximum) | 3 years from date |
| National Registry verification of the medical examiner | 391.51(b)(9) | Within 15 days of each exam | 3 years from date |
| Annual motor vehicle record | 391.25(a) | Every 12 months | 3 years from date |
| Annual review of driving record, signed by the reviewer | 391.25(b) | Every 12 months | 3 years from date |
| Clearinghouse annual limited query | 382.701(b) | Every 12 months | 3 years |
| Skill performance evaluation certificate, if applicable | 391.49 | At hire | Employment plus 3 years |
All citations are to 49 CFR. The former annual list of violations (391.27) was removed in 2022. Drug and alcohol test results are not kept in the DQ file; they go in a separate confidential file under 49 CFR 382.401.
Setup per driver, monitoring per month
Driver qualification file setup
Includes MVR and previous employer inquiries. State MVR fees, typically 5 to 25 USD per state, billed at cost.
Enroll nowDQ file monitoring and expiry alerts
Expiry alerts, annual MVR ordered, annual review prepared for your signature, annual Clearinghouse query run.
Start monitoringDriver qualification and related prices
| Service | Our fee | Billing |
|---|---|---|
| Driver qualification file setup | $49 | per driver |
| DQ file monitoring and expiry alerts | $9 | per driver per month |
| Pre-employment full query | $25 | per driver |
| Annual limited query | $15 | per driver |
| DOT pre-employment test | $79 | per test |
There is no government fee for DQ files. State MVR fees are set by each state and passed through at cost. DQ monitoring for all drivers is included in the Small Fleet Plan. See the plans.
How setup and monitoring work
- Send us the driver's details
Name, licence number and state or province, date of hire, previous employers for three years. We send the driver the application and consent forms electronically.
- We order and assemble
MVR from every state, previous employer inquiries, Clearinghouse full query, medical certificate verification against the National Registry, road test certificate or CDL equivalence. File complete in 5 to 10 business days.
- Monitoring and expiry alerts
We track the medical certificate, the CDL, the annual MVR, the annual review and the annual query for every driver and act 30 days before each expires.
The five DQ violations we see most, and the fix
- No annual MVR. The hire MVR is in the file, then nothing. Fix: order every driver's MVR on their anniversary month. Our monitoring does this without asking.
- Expired medical certificate. The driver renewed the card and kept it in the truck; the file has the old one, or the MVR was never pulled after the exam. Fix: alert 30 days before expiry, MVR pulled within 15 days after the exam.
- No previous employer inquiries. The carrier asked for references by phone and wrote nothing down. Fix: written requests to every DOT-regulated employer of the past three years, with the request and the response, or the documented good-faith effort, in the investigation file.
- Road test never done. For a CDL driver the CDL can be accepted in lieu of the road test, but the file needs a signed statement saying so, dated before the first trip. Fix: a one-page equivalence certificate, or a documented road test for non-CDL drivers.
- Owner-operator has no file on themselves. Fix: the same file, with a self-application. It takes an hour.
Every one of these is visible in a remote new-entrant audit and in a compliance review. A DQ violation on its own rarely ends a company; a missing file on the day of the audit, combined with a missing drug and alcohol program, does. See the audit checklist for the full picture.
Electronic files
FMCSA accepts electronic DQ files, including electronic signatures, provided the documents can be produced on request and cannot be altered without a trace. We keep your files in a system that produces a per-driver PDF with an index, which is exactly what a remote auditor asks you to upload.
Send us your driver list, get a gap report
Names and hire dates are enough to start. We tell you what each file is missing and what it costs to close the gaps. Written answer in one business day.
Online requests open soon. Call or email us and we answer the same business day.
Frequently asked questions
What is a driver qualification file?
A file every motor carrier must keep on every driver of a commercial motor vehicle, under 49 CFR 391.51. It proves the driver met the qualification standards of Part 391 when hired and continues to meet them: application, driving record, road test, medical certificate, annual review and, since 2020, Clearinghouse query records. The carrier keeps it at its principal place of business, on paper or electronically.
Do owner-operators need a DQ file on themselves?
Yes. The rule applies to every driver, including the owner. An owner-operator keeps the same file: an application (even if it is a one-page self-application), an MVR at start and annually, a road test or CDL equivalence, a medical certificate and the annual review. Auditors ask for it at the new-entrant audit and treat a missing file as an unqualified driver.
What goes in the file at hire?
The employment application (391.21), an MVR from every state where the driver held a licence in the past three years, requested within 30 days of hire (391.23), the previous employer safety performance history inquiries for three years (391.23), a pre-employment Clearinghouse full query (382.701), a road test certificate or a copy of the CDL accepted in its place (391.31, 391.33), and the medical examiner's certificate with the National Registry verification (391.43, 391.51).
What has to be done every year?
Two things, and one every two years. Annually: a new MVR from each state (391.25) and a written review of the driver's record signed by the person who did it (391.25). Annually as well: a Clearinghouse limited query. Every two years at most: a new medical certificate, unless the examiner issued it for a shorter period. Missing the annual MVR is the most common DQ violation in compliance reviews.
How long do I keep the file?
The whole file for as long as the driver works for you and for three years after they leave (391.51(c)). The MVRs, annual reviews, medical certificates and examiner verifications can be discarded three years after their date, so the file rolls over (391.51(d)). Previous employer inquiry responses are kept three years in a separate investigation history file with restricted access (391.53). Clearinghouse query records are kept three years (382.701(e)).
Is the annual list of violations still required?
No. FMCSA removed the driver's annual list of violations (former 49 CFR 391.27) in May 2022 because the annual MVR already captures the same information. If a checklist or a software product still asks for it, the checklist is out of date. The annual MVR and the annual review remain.
What about the medical certificate for CDL drivers?
Since June 23, 2025 medical examiners transmit CDL and CLP holders' results to FMCSA's National Registry, which forwards them to the state licensing agency. The driver no longer carries a paper certificate to the state. For the DQ file, the carrier obtains an MVR showing the driver's medical certification status within 15 days of the exam and keeps that in place of the paper card. Non-CDL drivers still hand you the paper certificate.
Do Canadian drivers need a DQ file?
Yes, if they drive for you in the United States. A Canadian driver's provincial licence and provincial medical are accepted under reciprocity, so the file holds the provincial abstract instead of a US MVR and the licence itself in place of a US medical certificate. Everything else, including the application, road test equivalence, annual review and Clearinghouse queries, is the same. We build these files for Quebec and Ontario carriers every week.
One driver or fifty, the file is the same. Let us keep it current.
Setup per driver, monitoring per month, alerts before anything expires. Bilingual for Quebec and Ontario carriers, Spanish for drivers who need it.