Driver Qualification File Checklist
Use one checklist for each driver. It lists what a driver qualification (DQ) file contains under 49 CFR Part 391, the Clearinghouse records under 382.701, when each item is due and how long to keep it. Check the current rules at ecfr.gov.
Part 1 — What goes in each driver's file
| Document | Rule | When | Keep | Notes |
|---|---|---|---|---|
| Employment application | 391.21 | Before the driver starts | While employed + 3 years | Signed and dated. Covers 3 years of addresses and employers. CDL applicants also list commercial driving employers for the 7 years before that. |
| Motor vehicle record from each state where the driver held a license or permit in the past 3 years | 391.23(a)(1), (b) | Within 30 days of hire | While employed + 3 years | If a state does not respond, note your good-faith effort. |
| Road test certificate, or a copy of the accepted equivalent | 391.31, 391.33 | Before the driver operates a CMV | While employed + 3 years | Equivalents: a CDL for the vehicle type you assign (doubles/triples and tank endorsements excluded), or a road test certificate issued in the past 3 years. |
| Medical certification for CDL drivers | 391.51(b)(6)(ii), 391.23(m)(2) | After every exam | 3 years from when it was obtained | A motor vehicle record from the driver's licensing state (CDLIS) that shows the current medical certification. Since June 23, 2025, examiners send results to the state electronically. |
| Medical examiner's certificate for drivers without a CDL | 391.43, 391.51(b)(6)(i) | At hire and after every exam | 3 years from the exam | Certificates last at most 24 months, sometimes less. Add a note that you verified the examiner on the National Registry (391.23(m)(1)). |
| Medical variance documents, if any | 391.49, Part 381 | When issued | 3 years | Skill Performance Evaluation certificate or exemption letter. |
| Annual motor vehicle record | 391.25(a) | At least every 12 months | 3 years from when it was obtained | From each state where the driver held a license or permit in the past 12 months. |
| Annual review note | 391.25(b), (c)(2) | At least every 12 months | 3 years | Record who reviewed the driving record and the date. Consider violations and accidents. |
| Clearinghouse full query (CDL drivers) | 382.701(a) | Before the driver performs safety-sensitive functions | 3 years | The driver consents electronically in the Clearinghouse. |
| Clearinghouse annual query (CDL drivers) | 382.701(b) | At least once a year | 3 years | A limited query needs the driver's written general consent. If it shows information, run a full query within 24 hours. |
Kept in a separate, access-controlled file (391.53)
| Document | Rule | When | Keep | Notes |
|---|---|---|---|---|
| Previous employers' safety performance history | 391.23(c)–(e), 391.53 | Within 30 days of hire | While employed + 3 years | Responses from DOT-regulated employers of the past 3 years, or a record of your good-faith attempts with each employer's name, address and contact date. |
| Driver's written authorization to request drug and alcohol history | 391.23(f), 391.53(b)(1) | At hire | While employed + 3 years | Without it, the driver may not operate a CMV for you. |
Part 2 — Yearly calendar for each driver
| When | What to do | Rule |
|---|---|---|
| Before the driver starts | Application, road test or equivalent, medical certification, Clearinghouse full query, written notice of the driver's rights about previous-employer information | 391.21, 391.31, 391.33, 391.41, 382.701(a), 391.23(i) |
| Within 30 days of hire | Motor vehicle records from each state for the past 3 years and previous-employer inquiries | 391.23 |
| After every medical exam | CDL drivers: a new CDLIS motor vehicle record. Drivers without a CDL: a copy of the new certificate and a National Registry note | 391.51, 391.23(m) |
| Every 12 months | Motor vehicle record from each state, the review note, and a Clearinghouse query | 391.25, 382.701(b) |
| Before expiry dates | CDL renewal, medical certification, Skill Performance Evaluation certificate | 391.11, 391.45, 391.49 |
| When the driver leaves | Keep the whole file for 3 more years | 391.51(c) |
Frequently cited problems
- Previous-employer inquiries missing or not documented
- Annual review not done within 12 months, or no reviewer named
- Expired medical certification
- Incomplete or unsigned application
- Clearinghouse queries not documented
Exceptions to check
- Multiple-employer drivers have reduced requirements (391.63).
- Drivers furnished by another motor carrier can be covered by that carrier's certificate (391.65).
DQ Keeper is an iPhone and iPad app that keeps these files and reminds you of these dates. It is coming to the App Store: dqkeeper.com.
Not affiliated with FMCSA or USDOT. This is general information, not legal or regulatory advice. Free to copy and share.