Guide · FMCSA Part 391
DQ file checklist: every document FMCSA expects, and when it's due
A driver qualification (DQ) file is the record FMCSA requires a motor carrier to keep for each driver it employs (49 CFR 391.51). It holds the driver's application, driving records, road test, medical certification and annual reviews, and you keep it for as long as the driver works for you plus three years. This checklist groups every item by when it's due, so you can see at a glance what's missing.
This is a summary of the federal rules for general guidance, not legal advice. Check the current regulation text on eCFR for your operation.
Start 30-day free trial · Book a 15-minute demo
The DQ file checklist at a glance
| Document | Rule | When it's due | How long to keep it |
|---|---|---|---|
| Employment application | 391.21 | Before the driver drives | Employment + 3 years |
| Road test certificate, or an accepted equivalent | 391.31, 391.33 | Before the driver drives | Employment + 3 years |
| Motor vehicle record (MVR) from each state where the driver held a licence or permit in the past 3 years | 391.23(a)(1) | Within 30 days of the start of employment | Employment + 3 years |
| Medical examiner's certificate (non-CDL drivers), or the CDLIS MVR showing medical certification status (CDL and CLP holders) | 391.43(g), 391.51(b)(6) | Before the driver drives, then again before it expires | Can be removed 3 years after it was issued |
| Note verifying the medical examiner is on the National Registry (non-CDL drivers) | 391.23(m)(1) | With each new medical certificate | Can be removed 3 years after it was made |
| Medical variance or Skill Performance Evaluation certificate, if the driver has one | 391.49, 391.51(b)(6)-(7) | When issued | Can be removed 3 years after it was issued |
| Annual MVR from each licensing state | 391.25(a) | At least every 12 months | Can be removed 3 years after it was obtained |
| Annual review note with the reviewer's name and the date | 391.25(c)(2) | At least every 12 months | Can be removed 3 years after it was made |
Before the driver drives
Hiring now? Follow the DOT pre-employment checklist.
Employment application (391.21)
The driver completes and signs an application on a form you provide. Section 391.21 lists what it must include, such as licence details, driving experience, accidents and traffic convictions in the past 3 years, and employers for the past 3 years. CDL applicants also list commercial driving employers for the 7 years before that. FMCSA publishes a sample application form.
Building or checking your form? See the DOT driver application guide.
Road test, or an accepted equivalent (391.31 and 391.33)
Keep the road test certificate in the file. In place of a road test, you may accept a valid CDL (with the limits in 391.33) or a copy of a road test certificate issued within the past 3 years, and keep a copy of whichever you accept.
Medical certification (391.41 to 391.45)
Every driver must be medically qualified. For non-CDL drivers, keep a copy of the medical examiner's certificate plus a note that you verified the examiner is on FMCSA's National Registry. For CDL and CLP holders, keep the CDLIS motor vehicle record from the state that shows the driver's medical certification status. A medical certificate lasts up to 24 months, and the examiner can set a shorter period.
CDL drivers: Clearinghouse query and pre-employment drug test
Before a CDL driver performs safety-sensitive functions, you need a pre-employment full query of the Drug and Alcohol Clearinghouse (382.701) and a verified negative pre-employment drug test (382.301). These are Part 382 records rather than items in the 391.51 list, but many carriers keep them next to the DQ file. Part 382 applies to CDL drivers only.
Within 30 days of hire
MVRs from every state of licensure (391.23(a)(1))
Within 30 days of the date employment begins, get a motor vehicle record covering the past 3 years from every state where the driver held a licence or permit, and put it in the DQ file.
Safety performance history from previous employers (391.23(a)(2))
In the same 30 days, investigate the driver's safety performance history with DOT-regulated employers from the past 3 years. Those responses go in a separate driver investigation history file (391.53), not in the DQ file itself.
Every 12 months
At least once every 12 months, get a new MVR from each state where the driver held a licence or permit and review it (391.25). The review checks whether the driver still meets the minimum requirements for safe driving or is disqualified. File the MVR and a note with the name of the person who did the review and the date. CDL drivers also need at least one limited Clearinghouse query a year (382.701(b)).
Whenever something expires
- Medical certificate: up to 24 months, often less. Track the actual expiry date on each certificate rather than assuming two years.
- Medical variance or Skill Performance Evaluation certificate: track its own dates.
- A driver can't drive once their medical certification lapses, so set reminders well ahead of the date.
How long to keep a DQ file
Keep the whole file for as long as the driver works for you and for 3 years after they leave (391.51(c)). Some items can be removed 3 years after they were created (391.51(d)), including annual MVRs, annual review notes, medical certificates or CDLIS MVRs, medical variance documents and National Registry notes. The application and road test stay for the full period.
Common gaps to check for
Use this list for a quick self-audit of your files:
- An application that is unsigned or missing employment history
- No MVR from a state where the driver was licensed in the past 3 years
- MVRs pulled more than 30 days after hire
- An expired medical certificate, or no National Registry note for a non-CDL driver
- An annual review with no reviewer name or date
- A CDL driver with no pre-employment Clearinghouse query or drug test result on record
If you're preparing for an audit, see what happens in a DOT audit.
Keeping DQ files current with Orange Fleet
- Applicants fill in Orange Fleet's online driver application. It moves through application review, HR approval, road test, medical and background check, and becomes the driver's DQ file once they're hired.
- Orange Fleet tracks the road test, medical and background check stages; you complete them with your usual providers.
- Automatic reminders go to both the driver and the fleet manager before DQ documents expire.
- Vehicle files and maintenance tracking live in the same app, so driver and vehicle records sit side by side.
DQ file management software, driver hiring software, fleet maintenance software, see pricing.
Running in Canada too?
Orange Fleet also supports fleets that run under Canada's National Safety Code. This checklist covers the US federal rules only. Check your province's requirements for Canadian drivers.
DQ file checklist FAQ
What documents go in a driver qualification file?
Under 49 CFR 391.51, a DQ file holds the driver's employment application, MVRs from each state where they were licensed in the past 3 years, a road test certificate or accepted equivalent, medical certification, annual MVRs, notes of each annual review, and where relevant a medical variance, Skill Performance Evaluation certificate and National Registry verification note.
What has to be in the DQ file before a driver can drive?
A completed and signed application, a road test certificate or accepted equivalent, and proof of medical certification. CDL drivers also need a pre-employment Clearinghouse full query and a negative pre-employment drug test before performing safety-sensitive functions.
What's due within 30 days of hiring a driver?
MVRs covering the past 3 years from every state where the driver held a licence or permit, and the investigation of their safety performance history with previous DOT-regulated employers.
How often do I need a new MVR and annual review?
At least once every 12 months. File the MVR and a note with the reviewer's name and the review date (391.25).
How long do I keep a DQ file?
For the length of employment plus 3 years. Annual MVRs, review notes, medical certificates and some other items can be removed 3 years after they were created.
Is the Clearinghouse query part of the DQ file?
Clearinghouse queries are Part 382 records for CDL drivers, not items in the 391.51 list, but many carriers keep them alongside the DQ file.
Where do previous employers' safety performance records go?
In the driver investigation history file required by 391.53, which is kept separately from the DQ file.
Do non-CDL drivers need a DQ file?
Usually yes, if they drive a commercial motor vehicle in interstate commerce, which starts at 10,001 lb. See who needs a DQ file.
Who gets reminded before a DQ document expires in Orange Fleet?
Both the driver and the fleet manager get automatic reminders.