Checklist · verified against 49 CFR 391.51, July 2026
Driver Qualification File Checklist
These are the documents 49 CFR 391.51(b) requires in the file, in the order the regulation lists them. Print this page, or save it as a PDF from your browser, and walk one file at a time.
Before the driver starts
Motor vehicle record from each licensing authority
The inquiry required by § 391.23(a)(1) — every state where the driver held a CMV licence in the past 3 years.
49 CFR § 391.51(b)(2)Road test certificate — or an accepted equivalent
A certificate under § 391.31, a copy of the licence or certificate accepted in place of a road test under § 391.33, or the written statement covering an exemption.
49 CFR § 391.51(b)(3)Medical examiner's certificate — or the CDLIS MVR carrying medical certification status
For CDL and CLP holders the CDLIS motor vehicle record showing certification status is what belongs here.
49 CFR § 391.51(b)(6)Skill Performance Evaluation Certificate, if one was issued
Only where FMCSA issued one, or where the driver holds a medical exemption document.
49 CFR § 391.51(b)(7)Note verifying the medical examiner is on the National Registry
A note of the verification that the examiner who issued the certificate was listed on the National Registry of Certified Medical Examiners on the date of the exam.
49 CFR § 391.51(b)(8)
Every 12 months, for as long as the driver is employed
Annual motor vehicle record
The MVR received in response to the annual inquiry under § 391.25(a), from every state where the driver held a CMV licence.
49 CFR § 391.51(b)(4)Note of the annual review of the driving record
Required by § 391.25(c)(2). The note has to identify who did the review and when — a filed MVR with nobody named on it does not satisfy this.
49 CFR § 391.51(b)(5)
How long to keep it
Under 391.51(c), the qualification file is retained for as long as the driver is employed, and for three years after that.
Paragraph (d) then carves out the recurring documents: the annual MVR, the annual review note, the medical examiner's certificate, any medical variance and the National Registry verification note may be removed three years after the date each was executed. In practice that means the file thins as it ages rather than emptying all at once.
Three things that are commonly on this list and should not be
- Safety performance history from previous employers. The investigation under § 391.23(d)–(e) is required, but its records belong in the separate driver investigation history file (§ 391.53), which has its own access restrictions. Filing it in the DQ file puts alcohol and controlled substances information in front of people who are not permitted to see it.
- The annual certificate of violations. FMCSA removed § 391.27 on 9 May 2022 — the annual MVR already carries the same convictions. Checklists that still ask for it are out of date. Certificates collected before that date are kept three years from their own date.
- The ELDT training certificate. Entry-level driver training is verified through the Training Provider Registry; § 391.51(b) does not list a training certificate as a file item.
What a complete file still will not tell you
Every document above is a record of credentials and driving history. None of them describes what the driver was like to employ — whether he finished loads, gave notice, or left a truck somewhere. The § 391.23 investigation is supposed to reach that, and in practice previous employers confirm dates and stop.
Carrier-reported driver reviewsare what fills that in — as a layer on top of the required file, never as a replacement for any part of it. For how the two fit together, seeverifying the application andthe PSP report.