---
title: Preparing for a DOT audit of driver files
description: Which qualification records federal rules require carriers to maintain and make available, and how location and copies work under 49 CFR Part 391 and Part 390.
date: 2026-10-21
lastReviewed: 2026-10-23
canonical: /resources/guides/preparing-for-a-dot-audit
---
When FMCSA or state enforcement requests driver qualification records, the rules define **what** each file must contain and **how** carriers must make records available—not a single checklist printed inside Part 391.

## Short answer



Maintain a § 391.51 qualification file for each employed driver with the application, MVRs, road test evidence, annual MVR and review note, medical certification, and related items listed in the rule. Keep investigation history separately under § 391.53. You may store records at your principal office or other locations, but must produce them within 48 hours at a place the investigator specifies. Legible copies satisfy § 390.31 unless a section requires originals. DQid organizes status and dates; carriers remain responsible for completeness and production.



## Records investigators expect in the qualification file



### 
  

### 
    Application (§ 391.21), initial MVRs (§ 391.23), road test certificate or
    accepted equivalent (§§ 391.31, 391.33), annual MVR and review note (§
    391.25), medical certification or CDLIS record (§§ 391.43, 391.23(m)), and
    variances or SPE documents when they apply.
  


  

### 
    Prior employer safety performance history and alcohol or drug consent belong
    in the secured investigation history file, available to authorized
    representatives on request.
  


  

### 
    Retain three years of query records for drivers subject to Part 382 testing.
  





## Location and production timing



### 
  

### 
    Multi-location carriers may keep subchapter records at the principal office,
    a regional office, or a driver work-reporting location unless another
    section specifies otherwise.
  


  

### 
    Records kept away from the principal office must be available for inspection
    at the principal office or another location the agent names within 48 hours
    (excluding Saturdays, Sundays, and Federal holidays).
  


  

### 
    Legible copies may be maintained instead of originals when the rule does not
    require the original document.
  





## Practical preparation carriers control

Index drivers by name and employment status, tie each checklist item to a dated document, and confirm annual MVR, Clearinghouse, and medical cycles before a request arrives. Internal sampling—opening files at random—surfaces gaps earlier than an external review.


  DQid shows missing items and review states; it does not predict enforcement
  outcomes or replace your retention policy.


## Sources

- [49 CFR 391.51 — Driver qualification files](https://www.ecfr.gov/current/title-49/section-391.51) (eCFR text reviewed 2026-10-20)
- [49 CFR 391.53 — Driver investigation history file](https://www.ecfr.gov/current/title-49/section-391.53) (eCFR text reviewed 2026-10-20)
- [49 CFR 390.29 — Location of records](https://www.ecfr.gov/current/title-49/section-390.29) (eCFR text reviewed 2026-10-20)
- [49 CFR 390.31 — Copies of records](https://www.ecfr.gov/current/title-49/section-390.31) (eCFR text reviewed 2026-10-20)
- [49 CFR 382.701 — Drug and Alcohol Clearinghouse](https://www.ecfr.gov/current/title-49/section-382.701) (eCFR text reviewed 2026-10-20)