What Goes In a Driver Qualification File?

A driver qualification file is one folder per driver, and 49 CFR 391.51 tells you exactly what belongs in it. Eight items. You can build the whole thing in an afternoon, and you need one on yourself if you drive your own truck.

Two of the eight changed in the last four years, so most DQ checklists still have you filling out a form that no longer exists and filing the wrong medical document on a CDL driver.

The eight items in 391.51(b)

• The employment application under 391.21, and it has 12 required elements: 3 years of addresses, accidents, violations and employers, 7 more years of employers for CMV drivers, and a signed certification.
• The motor vehicle record from each licensing authority, obtained under 391.23(a)(1).
• The road test certificate, or the equivalent accepted under 391.33, or the 391.44(d) certificate.
• The annual motor vehicle record from 391.25(a).
• The note of the annual driving record review required by 391.25(c)(2).
• The medical examiner's certificate under 391.43(g), or for a CDL holder the CDLIS motor vehicle record showing certification status, per 391.51(b)(6)(ii).
• A Skill Performance Evaluation certificate under 391.49, or a Federal medical exemption under part 381, if the driver has one.
• The National Registry verification note, for drivers not required to have a CDL, per 391.51(b)(8)(i).

The annual list of violations is gone

391.27 used to make every driver hand you a signed list of his traffic convictions once a year. It reads [Reserved] now. FMCSA removed it in the Record of Violations final rule, published March 9, 2022 at 87 FR 13197 and effective May 9, 2022, on the reasoning that it duplicated the annual motor vehicle record you already have to pull. If your folder still has a blank certification-of-violations form in it, that form has been dead for four years. 391.25 did not change, so you still pull the annual MVR yourself.

The medical card changed, and there is a clock running on it

Since June 23, 2025, medical examiners transmit CLP and CDL exam results electronically to the state licensing agency, and the state posts the certification status to the CDLIS driver record. So for a CDL holder, 391.51(b)(6)(ii) says you meet the medical certificate requirement by obtaining the CDLIS motor vehicle record from the current licensing state and putting that in the file. The 15-day paper allowance written into that same paragraph applied through June 22, 2025 and has expired.

391.51(b)(8) split the same way. Verifying your examiner was listed on the National Registry is now a non-CDL requirement under (b)(8)(i). The CDL half, (b)(8)(ii), ran through June 22, 2025 and is done. Non-CDL drivers still owe you both the paper certificate and that note.

Now the part with a date on it. Five states have not implemented the new system: Alaska, California, Kentucky, Louisiana and New Hampshire. So FMCSA granted a six-month exemption at 91 FR 19255 on April 14, 2026, letting carriers in every state rely on a paper certificate for up to 60 days after it was issued. It runs April 11, 2026 to October 11, 2026, and the agency said not to expect another nationwide one.

Read that as a deadline. If your file runs on a paper card, pull the CDLIS MVR before October 11 and confirm the state posted the certification. A driver who reads as not-certified is a truck sitting still.

The 30-day clock, and the second folder

391.23 starts a clock the day a driver starts. The MVR inquiry goes to each licensing authority within 30 days of the date employment begins, covering the preceding 3 years, and the record has to be in the file inside those same 30 days. The safety performance history investigation covers DOT-regulated employers for the same 3 years, and 391.23(g)(1) gives the old employer 30 days to answer. Send those requests the day you hire.

Those replies do not go in the DQ file. 391.53 puts them in a separate driver investigation history file with restricted access, kept for employment plus 3 years. Two folders per driver.

The road test, and the one place a CDL does not cover you

391.33 lets you accept a valid CDL instead of giving a road test, with an exception people miss: not for double and triple trailer or tank vehicle endorsements. If the driver is pulling doubles or a tanker for you, run the road test and file the certificate. You can also accept a copy of a 391.31 certificate issued within the preceding 3 years.

The annual review, and the note nobody writes

391.25 says at least once every 12 months you pull the driver's motor vehicle record covering at least the preceding 12 months and review it against the safety standards. Then 391.25(c)(2) asks for the part that gets skipped: a note in the file naming who did the review and the date. The MVR is usually there. The note usually is not. One line of handwriting, and missing it is a finding on a file that is otherwise clean.

How long it stays

391.51(c): kept as long as the driver is employed, and 3 years after. The folder for the driver who quit in 2024 stays in the cabinet until 2027. 391.51(d) lets five things come out 3 years after execution: the annual MVR, the review note, the medical certificate or CDLIS MVR, the variance or SPE certificate, and the registry note. The application, the original MVR and the road test certificate stay for the life of the file.

The afternoon

Do it in one sitting, per driver, yourself included. Fill the application out in full and sign it. Pull the MVR from every state that licensed the driver in the last 3 years. Send the safety history requests to every DOT-regulated employer from those 3 years and write down the date you sent each. Accept the CDL for the road test, or run one if doubles or a tanker are in play. Pull the CDLIS MVR for CDL holders, the paper certificate and registry note for everybody else. Then mark a calendar 12 months out.

Nothing in that folder carries a federal fee. You pay your state's motor vehicle record charge and a couple of hours. The expensive file is the one you do not have when the auditor asks.

The rest of what the auditor opens is at nrbcarriergroup.com/learn/new-entrant-safety-audit-what-they-ask-for, and the findings that fail you on a single occurrence are listed at nrbcarriergroup.com/learn/new-entrant-safety-audit-automatic-fails.

For your own dates instead of a general checklist, put your DOT number into the free checkup at nrbcarriergroup.com/checkup. It gives you the next 90 days for your operation, no signup, and the number never leaves your browser. If you would rather have the annual MVR and the medical card expiry tracked for you than redrawn on a calendar every year, that is what our app does. The basics are free.

Sources: 49 CFR 391.51, 391.21, 391.23, 391.25, 391.31, 391.33, 391.43(g) and 391.53. 391.27 is now Reserved, removed by the Record of Violations final rule, 87 FR 13197, March 9, 2022, effective May 9, 2022. The paper certificate exemption is 91 FR 19255, April 14, 2026, running April 11, 2026 through October 11, 2026. Regulation text read from the eCFR issue of 2026-08-01. This is preparation, not representation. NRB is not affiliated with FMCSA.