The Driver Qualification File checklist
49 CFR 391.51 · Applies to CDL and non-CDL drivers of vehicles over 10,000 lbs in interstate commerce · Updated September 2026
Every motor carrier must keep a qualification file on every driver — including owner-operators driving their own truck, and including non-CDL drivers of vehicles over 10,000 lbs. Here is everything the file must contain, when each item renews, and how long it's kept.
The checklist
| Document | Cite | When |
|---|---|---|
| Employment application | 391.21 | At hire |
| Safety performance history from prior DOT employers (3 yrs) | 391.23(d)–(e) | Within 30 days of hire |
| Initial driving record (MVR) from every state licensed, prior 3 yrs | 391.23(a) | Within 30 days of hire |
| Road test certificate — or a valid CDL accepted as equivalent | 391.31 / 391.33 | Once |
| Medical examiner's certificate | 391.43 / 391.45 | Renews up to every 24 months — sooner if the examiner says so |
| Annual MVR | 391.25(a) | Every 12 months |
| Annual review of driving record (a written note, not just the MVR) | 391.25(c) | Every 12 months |
CDL drivers add three more under part 382: a pre-employment drug test result, a pre-employment Clearinghouse query, and a Clearinghouse annual query every 12 months — plus enrollment in a random-testing program or consortium at the company level.
Retention
The file is kept for the whole employment plus three years after the driver leaves (391.51(c)). A handful of items — old medical certificates, old annual MVRs and reviews — may be purged three years after they were created. The safety-performance-history records live in a separate, limited-access file (391.53): the regs themselves expect you to control who can see them.
The three things auditors flag most
- The annual review note is missing. Carriers pull the MVR but skip the written review of it — two separate requirements, same deadline.
- The med card lapsed. An expired certificate means the driver is not qualified to operate — it's one of the audit's automatic failures.
- Non-CDL drivers have no file at all. "No CDL" does not mean "no file." See our guide to non-CDL box truck rules.
General information, not legal advice. Interstate rules shown; intrastate-only carriers follow their state's adopted version.