FreightVerdict

Driver qualification file checklist

One file per driver, eight pieces, named in §391.51. Most files that fail an auditor are not missing the famous pieces — they are missing the small dated ones, or carrying a dead form in place of a living duty. Here is the file, piece by piece.

Rules checked October 2026 · 49 CFR 391.51

The eight pieces (§391.51(b)(1)–(8))

  1. The employment application (§391.21). The full application — addresses, employers, accidents, violations, license history — signed by the driver, certifying it is true. A one-page contact form is not this.
  2. The initial driving record (§391.23(a)(1)). The MVR you pulled from his licensing state when he started. File the record itself.
  3. The road test certificate (§391.31(e)). Proof he passed a road test in the kind of vehicle he drives for you — or the copy of the license or certificate you accepted as the equivalent (§391.33).
  4. The annual driving record (§391.25(a)). A fresh MVR, pulled every year, for every year he drives.
  5. The note on the annual review (§391.25(c)(2)). A dated note saying who reviewed the record, when, and what they found. Pulling the record without the note is half the duty — and the half auditors find missing.
  6. The medical proof (§391.43(g)). For a CDL driver, this is now the CDLIS driving record showing his medical status — the paper card alone has not satisfied this piece since June 2025, when the National Registry integration completed. For a non-CDL driver, it is the medical examiner's certificate itself.
  7. Any medical variance. A federal medical exemption or Skill Performance Evaluation certificate, if he drives under one. If he does not, the file should say “none” — an asked question, not an empty space.
  8. The National Registry note (non-CDL drivers, §391.23(m)). A note verifying his medical examiner was on the National Registry when the certificate was issued.

Trap one — the form that is no longer required

Older checklists and older kits include an annual “list of violations” the driver signs, listing his year's tickets. That certification was removed from the required contents of this file — the old §391.27 duty no longer exists. Keeping the form harms nothing. Believing it replaces pieces 4 and 5 fails audits: the living duty is the annual MVR pull and the reviewer's note.

Trap two — the file that must stay separate

The previous-employer safety-history checks — the driver's authorization, your inquiries to his driving employers of the last 3 years, their answers or your documented attempts — do not belong in this file. They live in a separate, access-limited investigation-history file (§391.53). Auditors ask for both files. Folding them together mis-teaches the structure and exposes history answers to people the rule keeps them from.

How long the file lives

The DQ file is kept for the driver's whole employment plus 3 years (§391.51(c)). The dated pieces — annual records, review notes, medical proof, registry notes — may be removed 3 years after they were made (§391.51(d)). Keep the pieces in date order and both rules become a filing habit instead of a project.

The file is half of a bigger read

The DQ file is the most-sampled file in the audit, but it is one sample among several. The free New Entrant Audit Verdict scores the file alongside the 16 automatic-failure lines and every other sampled file. The fillable packet itself — application, road test certificate, review note, trackers — is §2 and §3 of the Audit & DQ Kit.

Federal sources: 49 CFR 391.21, 391.23, 391.25, 391.31, 391.43, 391.51, 391.53 · Rules checked October 2026