What goes in the DQ file
| Document | Rule |
|---|---|
| 1. Employment application Signed by the driver, with the information listed in §391.21. | §391.21 |
| 2. Pre-hire driving record (MVR) From every state where the driver held a license or permit in the last 3 years. Request it and put it in the file within 30 days of the start date. | §391.23(a)(1) |
| 3. Road test certificate Or a copy of the CDL or certificate you accepted instead of a road test. | §391.31(e), 391.33 |
| 4. Annual driving record (MVR) From every state where the driver held a license in the past year, at least once every 12 months. | §391.25(a) |
| 5. Annual review note Who reviewed the driving record and on what date, at least once every 12 months. | §391.25(c)(2) |
| 6. Proof of medical certification The medical examiner's certificate. For CDL drivers, the proof is the state driving record (CDLIS MVR) showing the driver is medically certified. What changed in 2025. | §391.51(b)(6) |
| 7. Medical variance, if any A skill performance evaluation certificate or a medical exemption letter. | §391.49 |
| 8. National Registry check A note that the medical examiner was listed on the National Registry of Certified Medical Examiners. Not needed for CDL drivers in states that receive medical results from the Registry directly. | §391.51(b)(8) |
The driver's annual list of violations (old §391.27) is no longer required. FMCSA removed it in 2022 because the annual driving record covers the same ground.
How long to keep it
- Keep the DQ file for as long as the driver works for you, and for 3 years after they leave.
- Annual driving records, annual review notes, medical certificates, medical variances and National Registry notes can be removed 3 years after the date they were made.
What goes in separate files
- Driver investigation history file (§391.53): the driver's written authorization and what previous DOT-regulated employers reported about the last 3 years. Request it within 30 days of the start date and limit access to the people making the hiring decision.
- Drug and alcohol records (Part 382): the negative pre-employment test result, received before the driver's first safety-sensitive work, and Clearinghouse queries: a full query before hire and at least one query every year after. These are confidential and are not kept in the DQ file.
The dates that slip
Most audit findings in DQ files are not missing paperwork at hire. They are the yearly items: an annual driving record that was never pulled, a review note nobody signed, a medical certificate that expired while the driver kept driving. Each has its own date for each driver, so they drift apart as the fleet grows.
We keep the DQ files for you
IFTAX holds every driver's file in one place, sees each expiry date ahead of time and reminds you before a driver goes out of compliance. Start with a free audit of your current files.
Source: 49 CFR 391.21–391.53 and Part 382. General information, not legal advice. IFTAX is not affiliated with FMCSA or any government agency.