What belongs in a driver qualification file?
The records a carrier keeps for each driver under 49 CFR 391.51, what lives in separate files, how long to keep them, and the 2025–2026 medical certification changes.
- Published
- Published 2026-02-10
- Reading time
- 5 min read
A driver qualification file (DQF) is the set of records a motor carrier must keep for each driver it employs. 49 CFR 391.51 lists what the file must include, and it can be combined with the personnel file.
Short answer
The file holds the signed employment application, the motor vehicle records and the annual review note, proof of the road test, and proof of medical certification. Records about a driver’s previous employers and drug and alcohol history are kept in separate files. DQid organizes these items on one digital file with review status and dates.
What carriers file
Employment application
49 CFR 391.21On the carrier’s form and signed by the driver: three years of addresses, licenses, experience, accidents and convictions, plus employer history.
Motor vehicle records
49 CFR 391.23A three-year record from each licensing state, requested within 30 days of the start date and filed within those 30 days.
Road test evidence
49 CFR 391.31The road test certificate, a copy of the license or certificate accepted as its equivalent, or the written statement when no road test is required.
Annual record and review note
49 CFR 391.25A new motor vehicle record at least every 12 months, and a note naming who reviewed it and when.
Medical certification
49 CFR 391.43CDL drivers: the CDLIS record with medical status. Other drivers: the examiner’s certificate and a National Registry verification note.
Variances and exemptions
49 CFR 391.49Only when they apply: an FMCSA medical variance, a Skill Performance Evaluation certificate or a federal medical program exemption.
Medical certification: what changed
Since June 23, 2025, medical examiners no longer issue a paper certificate to CDL and permit holders. FMCSA sends the results to the state, and the state posts the driver’s medical status on the CDLIS motor vehicle record. A carrier gets that record from the driver’s current licensing state and files it.
FMCSA allowed paper copies for up to 60 days through a series of waivers while states finished the change. A Federal Register notice published October 8, 2026 (2026-20649) states that as of October 12, 2026, drivers licensed outside Alaska—and motor carriers that employ them—may no longer rely on a paper copy of the medical examiner’s certificate. The notice renews the exemption for Alaska-licensed drivers for one year. Drivers who do not need a CDL still get a paper certificate, and the carrier files a copy.
The old annual list of violations (§ 391.27) is now reserved. The annual record and the review note remain required.
Kept in separate files
Two kinds of records sit outside the qualification file. Replies from previous employers go in the driver investigation history file (§ 391.53), in a secure place open only to people involved in the hiring decision. Drug and alcohol testing records are kept under Part 382. Records of Clearinghouse queries are retained for 3 years.
How long to keep records
Keep the file for as long as the driver is employed and for 3 years afterward. Three years after they were made, you may remove the annual record, the review note, the medical certificate or CDLIS record, any variance or exemption, and the National Registry note.
Example in DQid
When a document is missing or past its review window, the file shows Not submitted or Under review until your team records the update.
- Not submitted
- Under review
- Compliant
Expiration alerts surface dates your carrier tracks; they do not replace your review process.
Sources
Keep reading
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