Driver Qualification File Checklist (Including the File on Yourself)
If you drive under your own authority, you are your own employee — and you owe yourself a complete DQ file.
By Day One Authority · Updated
The short answer
- The DQ file is required per driver, including an owner-operator driving their own authority.
- At hire: application, MVR, previous-employer safety performance inquiries, road test or equivalency, medical certificate.
- Annually: new MVR, documented annual review of driving record, and the driver certification of violations.
- Most common omissions: previous employer inquiries, the annual review memo, and the road test certificate.
Auditors do not ask whether your driver is qualified. They ask you to hand them the file that proves it. Part 391 is a list, and the file either matches the list or it does not.
Required at hire
| Document | Reg | Notes |
|---|---|---|
| Driver employment application | 391.21 | Must include 10 years of employment history for CDL drivers |
| MVR from each licensing state | 391.23 | Obtained within 30 days of hire, covering the prior 3 years |
| Previous employer safety performance inquiries | 391.23 | Sent to all DOT-regulated employers from the prior 3 years; document attempts even if no reply |
| Road test certificate or CDL equivalency | 391.31 / 391.33 | A valid CDL may substitute for the road test if documented |
| Medical examiner certificate | 391.43 | From a certified medical examiner on the national registry |
| Clearinghouse full query result | 382.701 | With the driver's specific written consent on file |
| Driver certification of violations (initial) | 391.27 | List of convictions in the prior 12 months, or a statement of none |
Required annually
- A fresh MVR from every state where the driver held a license during the year.
- A documented annual review of driving record — a dated, signed memo stating you reviewed the MVR and the driver remains qualified. This is the single most-missed document in the file.
- The driver's annual certification of violations.
- A limited Clearinghouse query.
Retention rules
| Record | Retention |
|---|---|
| DQ file for a current driver | Entire period of employment |
| DQ file after termination | 3 years |
| Annual MVR and review | 3 years |
| Records of duty status and supporting docs | 6 months |
| Drug and alcohol testing records (negatives) | 1 year |
| Positive results, refusals, SAP records | 5 years |
| Annual vehicle inspection report | 14 months |
| Accident register | 3 years |
Keeping the medical card from stopping your truck
Medical certificates commonly issue for one or two years and can be shortened for monitored conditions. If yours lapses, your state downgrades your CDL and you are no longer qualified to drive — which is an automatic-failure violation if you keep operating. Diary the expiration 60 days out and book the exam early. Under the electronic medical certification integration, certified examiners transmit results to the state, but you remain responsible for confirming your record is current.
Build a DQ file in 45 minutes
- 1
Create one folder per driver
Digital is fine and preferable — auditors accept uploads. Name files consistently so you can produce them quickly.
- 2
Complete a full application on yourself
Yes, on yourself. Ten years of employment history, addresses, license history, and accident history.
- 3
Order MVRs
From every state of licensure in the past three years.
- 4
Send previous employer inquiries
Written requests to each DOT-regulated employer from the prior three years. Keep copies and a log of attempts and non-responses.
- 5
Document CDL equivalency or run a road test
A one-page certificate referencing the CDL class and endorsements, signed and dated.
- 6
File the medical certificate and set the reminder
Copy in the file, expiration date on your compliance calendar.
- 7
Write the annual review memo now
Date it, reference the MVR reviewed, state the qualification determination, sign it. Repeat every 12 months.