Driver Qualification File Checklist (49 CFR Part 391)

Everything a motor carrier must keep in each CDL driver's qualification file under 49 CFR §391.51 — application, MVRs, road test, medical certificate, Clearinghouse queries — and how long to keep it.

6 min read · Updated October 2026

Every motor carrier must keep a driver qualification (DQ) file for each driver it employs (49 CFR §391.51). Missing DQ documents are among the most common findings in FMCSA compliance reviews and audits.

What goes in the DQ file

  1. Employment application with the required 3-year (or 10-year for CDL) employment history (§391.21).
  2. Motor vehicle record (MVR) from each state where the driver held a license in the past 3 years, obtained at hire (§391.23).
  3. Safety performance history inquiries to previous DOT employers from the past 3 years (§391.23).
  4. Road test certificate or an acceptable equivalent such as a CDL (§391.31 and §391.33).
  5. Medical examiner's certificate from a National Registry examiner, or for CDL drivers, the CDLIS MVR showing medical status (§391.43 and §391.51(b)(7)).
  6. Note verifying the medical examiner is listed on the National Registry.
  7. Annual MVR review (§391.25), at least once every 12 months.
  8. Drug & Alcohol Clearinghouse queries: a full query at hire and at least annual queries (Part 382).
  9. Any medical variance or skill performance evaluation certificates, if applicable.

Medical certificate basics

A DOT medical certificate is valid for up to 24 months. An examiner may issue a shorter certificate for monitored conditions such as hypertension or diabetes. An expired medical card is a driver violation and can lead to an out-of-service order.

Retention

Keep the DQ file for the whole time the driver works for you, plus 3 years after they leave. Some documents, such as old MVRs and annual reviews, may be removed 3 years after their date of execution (§391.51(d)).

Track expirations automatically

DotCheck's driver registry tracks CDL and medical certificate expiration dates for each driver. Fleet managers can see what's coming due before it turns into a violation.

FREQUENTLY ASKED QUESTIONS

How long is a DOT medical card good for?

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A DOT medical examiner's certificate is valid for up to 24 months, though examiners may issue shorter certificates for drivers with conditions that require monitoring.

How often must a carrier review a driver's MVR?

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Motor carriers must obtain and review each driver's motor vehicle record at least once every 12 months under 49 CFR §391.25.

How long must a driver qualification file be kept?

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For the duration of employment plus three years after the driver leaves the company.

This guide is for general information and pre-inspection preparation only. It is not legal advice. Always check the current text of 49 CFR at ecfr.gov and the current CVSA OOS Criteria.

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