What is a driver qualification file?

A driver qualification file (DQF) is the set of records 49 CFR 391.51 requires a motor carrier to keep for every driver it employs to operate a commercial motor vehicle. It proves the driver was qualified on day one and that you have kept checking every year since.

What documents are required in a driver qualification file?

Eight, under 391.51(b): the employment application, the pre-hire MVR from each state, the road test certificate or equivalent, the annual MVR, the annual review note, the medical examiner’s certificate, any medical variance or SPE certificate, and (for non-CDL drivers) the National Registry verification note. Drug and alcohol records and previous-employer safety history are required too, but they belong in separate files.

How long do you have to keep a driver qualification file?

For as long as the driver works for you, plus three years after they leave (391.51(c)). Four types of record can come out sooner, three years after they were created: annual MVRs, annual review notes, medical certificates and variances, and National Registry verification notes (391.51(d)).

Do drug test results go in the driver qualification file?

No. Part 382 drug and alcohol records must be kept in a secure location with controlled access (382.401), on their own retention schedule: five years for positives and refusals, one year for negatives. Keeping them in the general DQF exposes them to everyone who handles that file.

Is the annual certification of violations still required?

No. 49 CFR 391.27, which required drivers to list their violations every year, is now marked [Reserved] in the regulation. The annual MVR and your written review of it (391.25) cover that ground.

Do non-CDL drivers need a driver qualification file?

Yes, if they operate a commercial motor vehicle as Part 390 defines it, which includes vehicles of 10,001 pounds or more in interstate commerce. Part 391 applies whether or not the vehicle requires a CDL.

Can the driver qualification file be kept electronically?

Yes. 391.51(a) also lets you combine the DQF with the driver’s personnel file. What matters in an audit is that you can produce every required record on request.

49 CFR Part 391 guide

The Driver Qualification File: 8 Records, Not 25

Most driver qualification file checklists run 18 to 25 lines. The regulation that defines the file, §391.51, lists eight. The rest is real, and an auditor will ask for it, but it belongs in two other files, each with its own rules. This guide sorts out which is which, with every deadline cited to the regulation.

The short version

The DQF (§391.51): 8 records proving the driver is qualified. Kept for employment plus 3 years.
The driver investigation history file (§391.53): what previous employers told you. Locked down, used only for the hiring decision.
The drug and alcohol file (§382.401): test results and Clearinghouse queries. Separate, access-controlled, on its own 1-to-5-year clock.

What goes in a driver qualification file

These are the records §391.51 paragraph (b) names, in the regulation’s own order. If it is not on this list, it does not have to be in the DQF.

#	Record	Rule	When it’s due	How long it stays
1	Application for employment	§391.21	Before the driver’s first trip	Employment + 3 years
2	Pre-hire motor vehicle record (MVR)	§391.23(a)(1)	Within 30 days of hire, from every state that licensed the driver in the past 3 years	Employment + 3 years
3	Road test certificate (or accepted equivalent)	§391.31(e) §391.33	Before the driver’s first trip	Employment + 3 years
4	Annual MVR	§391.25(a)	At least once every 12 months	May be removed 3 years after it was obtained
5	Annual review note	§391.25(c)(2)	At least once every 12 months, naming the reviewer and the date	May be removed 3 years after it was written
6	Medical examiner’s certificate	§391.43(g) §391.51(b)(6)	Before the first trip, and again before it expires (24 months at most)	May be removed 3 years after issue
7	Medical variance or SPE certificate	§391.49	Only for drivers certified under a variance or exemption	May be removed 3 years after issue
8	National Registry verification note	§391.23(m)	Non-CDL drivers: when you verify the examiner is on the National Registry	May be removed 3 years after it was written

CDL drivers: proof of medical certification is the CDLIS motor vehicle record from the current licensing state, when it shows medical status (§391.51(b)(6)(ii)). The 15-day window for using a paper copy and the National Registry note for CDL drivers both ended June 22, 2025.

The deadlines, in the order they hit

Hiring paperwork gets done because someone is waiting to put the driver on a load. The 12-month items are the ones that slip, because nothing reminds you.

Before the first trip

Signed application, with 3 years of employers (10 years for CDL drivers, per 391.21(b)(11))
Road test certificate or an accepted equivalent
Current medical examiner’s certificate
A verified negative pre-employment drug test (382.301)
A full pre-employment Clearinghouse query, with the driver’s consent (382.701(a))

Within 30 days of hire

MVR from every state that licensed the driver in the past 3 years, in the DQF (391.23(b))
Safety performance history from every DOT-regulated employer in the past 3 years, or documented good-faith attempts, in the driver investigation history file (391.23(c))

Every 12 months

A new MVR from each state that licensed the driver (391.25(a))
A written review of that MVR, signed off with the reviewer’s name and the date (391.25(c)(2))
A Clearinghouse query. A limited query satisfies it, but a hit means a full query within 24 hours (382.701(b))

When the medical card expires

A new medical examiner’s certificate. Certification is good for 24 months at most, and examiners often issue less (391.45)

The two files that are not the DQF

Driver investigation history file §391.53

This holds what previous employers told you: accident history from every DOT-regulated employer in the past three years, and their drug and alcohol violation history. It must be kept in a secure location with controlled access, seen only by people involved in the hiring decision, and used only for that decision. Your insurer may see it, except the drug and alcohol data. If a previous employer never answers, document the name, address, date contacted and what you tried. A documented good-faith attempt satisfies the rule; an empty folder does not. For a driver you hire, keep it for employment plus 3 years.

Drug and alcohol testing records §382.401

Pre-employment, random, post-accident and reasonable-suspicion records are required, but Part 382 puts them in their own secure, access-controlled file with their own retention clock: five years for positive results, refusals and alcohol results of 0.02 or higher; two years for collection-process records; one year for negative results. Mixing them into the DQF hands confidential results to everyone who pulls the file.

If you are an owner-operator or small fleet without an in-house program, a DOT drug and alcohol consortium runs the random pool and keeps these records for you.

Still on your checklist, but no longer required

The annual certification of violations. Section 391.27 used to make every driver list their violations once a year. It is now marked [Reserved] in the regulation. Plenty of templates still include the form. Your annual MVR and the signed review of it under §391.25 are what count now.

How long to keep a driver qualification file

The whole file stays for as long as the driver works for you, plus three years after they leave (§391.51, paragraph (c)). Paragraph (d) lets you purge four kinds of record three years after they were created, even while the driver is still employed:

Annual MVRs
Annual review notes
Medical examiner’s certificates, CDLIS MVRs used as proof, and medical variances
National Registry verification notes

A driver with you for ten years should have one application and one road test certificate, but only the last three years of MVRs, reviews and medical cards. Purging is optional. Keeping everything is not a violation, but losing a current record is.

Eight records per driver. Four of them expire.

FleetCollect reads the expiration date off each medical card and MVR, warns you before the 12-month clock runs out, and exports the file in the order an investigator reads it.

See the DQF software Or download the free template

Driver qualification file FAQ

What is a driver qualification file?: A driver qualification file (DQF) is the set of records 49 CFR 391.51 requires a motor carrier to keep for every driver it employs to operate a commercial motor vehicle. It proves the driver was qualified on day one and that you have kept checking every year since.
What documents are required in a driver qualification file?: Eight, under 391.51(b): the employment application, the pre-hire MVR from each state, the road test certificate or equivalent, the annual MVR, the annual review note, the medical examiner’s certificate, any medical variance or SPE certificate, and (for non-CDL drivers) the National Registry verification note. Drug and alcohol records and previous-employer safety history are required too, but they belong in separate files.
How long do you have to keep a driver qualification file?: For as long as the driver works for you, plus three years after they leave (391.51(c)). Four types of record can come out sooner, three years after they were created: annual MVRs, annual review notes, medical certificates and variances, and National Registry verification notes (391.51(d)).
Do drug test results go in the driver qualification file?: No. Part 382 drug and alcohol records must be kept in a secure location with controlled access (382.401), on their own retention schedule: five years for positives and refusals, one year for negatives. Keeping them in the general DQF exposes them to everyone who handles that file.
Is the annual certification of violations still required?: No. 49 CFR 391.27, which required drivers to list their violations every year, is now marked [Reserved] in the regulation. The annual MVR and your written review of it (391.25) cover that ground.
Do non-CDL drivers need a driver qualification file?: Yes, if they operate a commercial motor vehicle as Part 390 defines it, which includes vehicles of 10,001 pounds or more in interstate commerce. Part 391 applies whether or not the vehicle requires a CDL.
Can the driver qualification file be kept electronically?: Yes. 391.51(a) also lets you combine the DQF with the driver’s personnel file. What matters in an audit is that you can produce every required record on request.

A working summary, not legal advice. The controlling text is 49 CFR Part 391 and Part 382, checked October 2026.