Driver Qualification File Checklist

Quick checklist

Create a DQ file for each driver before dispatch.
Use 49 CFR 391.51 as the control list for core DQ file contents and retention.
Save the driver application and employment history items.
Keep required MVR and safety performance inquiries where applicable.
Track medical qualification documents.
Complete and save annual review materials.

Why this matters

A DQ file shows that the carrier checked whether the driver was qualified to operate. Under 49 CFR 391.51, the file also has specific retention expectations, so weak onboarding can become a records problem later.

What to prepare

Area	Records to gather
Onboarding records	Driver application Road test or equivalent record where required License information Previous employer and safety performance inquiries where applicable
Ongoing records	MVR checks Medical certification documentation Annual review notes Records of violations or driver certification where applicable

Common gaps

A file has the license and medical card but no application.
Annual review is skipped after the first year.
MVRs are downloaded but not tied to an annual review note.
Old drivers have no archive file.

Before / During / After audit

Before

Review every active and in-scope former driver.
Use the same order for each file.
Mark missing annual items separately from onboarding items.

During

Provide files driver by driver.
Keep notes when a record is stored in a state or vendor portal.

After

Schedule recurring annual reviews.
Archive former driver files in a consistent location.
Update the onboarding checklist.

Download

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Sources

eCFR · regulation

49 CFR 391.51 - General requirements for driver qualification files

Driver qualification file contents and retention requirements.

Last checked: 2026-05-12