What is a driver qualification file?FMCSA DQF requirements, 49 CFR 391.51

What must a driver qualification file contain?

A driver qualification file must contain the eight kinds of records listed in 49 CFR 391.51(b): the employment application, the pre-hire MVR, the road test certificate or its equivalent, the annual MVR, the annual review note, proof of medical certification, any SPE certificate or medical exemption, and (for non-CDL drivers) a National Registry check.

• § 391.51(b)(1) Employment application The driver’s application for employment, completed and signed under § 391.21. See § 391.21.
• § 391.51(b)(2) Pre-hire driving record (MVR) A copy of the motor vehicle record from each state that licensed the driver in the past 3 years, from the inquiry required by § 391.23(a)(1). See § 391.23.
• § 391.51(b)(3) Road test certificate or its equivalent The certificate of driver’s road test (§ 391.31(e)), or a copy of the CDL or road test certificate you accepted as equivalent (§ 391.33). For a driver covered by the vision standard in § 391.44, the written statement that no road test is required plus the driver’s certification. See § 391.31, § 391.33, § 391.44.
• § 391.51(b)(4) Annual driving record (MVR) The motor vehicle record from each licensing state for the annual inquiry required by § 391.25(a). See § 391.25.
• § 391.51(b)(5) Annual review note A note on your annual review of the driver’s record, with the name of the person who reviewed it and the date (§ 391.25(c)(2)). See § 391.25.
• § 391.51(b)(6) Proof of medical certification The medical examiner’s certificate (§ 391.43(g)) or a legible copy. For CDL holders, the driving record from the current licensing state that shows medical certification status (the rule calls it the CDLIS motor vehicle record), plus any FMCSA medical variance. See § 391.43.
• § 391.51(b)(7) SPE certificate or medical exemption A Skill Performance Evaluation Certificate (§ 391.49) or a Medical Exemption document from a Federal medical program (Part 381), when the driver has one. See § 391.49.
• § 391.51(b)(8) National Registry check (non-CDL drivers) For drivers who do not need a CDL, a note that you verified the medical examiner was listed on the National Registry of Certified Medical Examiners (§ 391.23(m)(1)). See § 391.23.

Source: eCFR, 49 CFR 391.51, read October 14, 2026. Paraphrased; the regulation text controls. A § 391.51(b)(8)(ii) note for CDL drivers applied only through June 22, 2025.

When must each record be in the file, and how long do you keep it?

Most records must be in place before the driver drives for you; the pre-hire MVR is due within 30 days of the date employment begins; the MVR and review repeat at least every 12 months. Keep the file while the driver works for you and for three years after (§ 391.51(c)). Annual and medical records may be removed three years after the date they were made (§ 391.51(d)).

"Employment + 3 years" = § 391.51(c). Previous-employer safety performance history is due in the separate investigation history file within 30 days of the date employment begins (§ 391.23(c)(1)) and kept for employment + 3 years (§ 391.53(c)). Read on eCFR October 14, 2026.

How do I build and keep a driver qualification file?

You build it yourself — FMCSA does not issue a DQF. Collect the hiring records before the driver drives, add the pre-hire MVR within 30 days, then renew the MVR and review note every 12 months for as long as the driver works for you. Full checklist: driver qualification file checklist.

1. Get a signed employment application on your form, with the information § 391.21(b) lists, before the driver drives (§ 391.21).
2. Order the pre-hire MVR from every state that licensed the driver in the past 3 years, and put it in the file within 30 days of the date employment begins (§ 391.23(a)(1), (b)). Order an MVR →
3. Check safety performance history with the driver's DOT-regulated employers from the past 3 years (§ 391.23(a)(2)). For drivers subject to Part 382, run a pre-employment Clearinghouse full query (§ 382.701(a)) and get a verified negative pre-employment drug test result before the first safety-sensitive function (§ 382.301(a)). Keep these in the investigation history file and drug and alcohol records, not the DQF.
4. Give a road test, or accept a valid CDL (or a road test certificate from the past 3 years) as the equivalent and keep a copy (§ 391.31, § 391.33).
5. Get proof of medical certification before the driver operates: the medical examiner's certificate, plus the National Registry check for non-CDL drivers; for CDL holders, the driving record from the current licensing state showing medical certification status (§ 391.23(m)).
6. Run the recommended checksRecommended, not required — the PSP report, a CDLIS report (licenses held in other states) and a criminal background check. Vertical Identity members order these in the same portal; see CDL driver onboarding.
7. Every 12 months, pull a new MVR and write a review note with the reviewer's name and the date (§ 391.25), and keep the medical certification current.
8. Keep the file while the driver works for you and for three years after; annual and medical records may be removed three years after the date they were made (§ 391.51(c), (d)).