The required documents
A driver-qualification (DQ) file under 49 CFR Part 391 must contain: (1) a copy of the CDL or commercial driving record, (2) the most recent MVR (pulled annually), (3) the current DOT medical examination certificate, (4) the driver's application for employment, (5) a road test record (or substituted equivalent), (6) the annual driver review document, and (7) prior-employer verifications under §391.23 covering the prior three years.
For drivers operating in interstate hazmat carriage, additional H-endorsement TSA Threat Assessment documentation must be on file.
Auditor focus areas
In compliance-review and new-entrant audits in 2025, the most-cited DQ file gaps were: missing pre-employment Clearinghouse query, missing annual MVR pull, expired medical certificate not refreshed, and missing prior-employer verification under §391.23. Many carriers think they completed the prior-employer verification but only documented the request, not the response (or non-response after a documented good-faith effort).
The §391.23(d) good-faith documentation must include: date of inquiry, method (fax / email / phone), addressee, and documented receipt of response or documented non-response. A bare "we asked, no answer" note is not sufficient.
Going digital
DQ files may be stored electronically per 49 CFR §390.31. Electronic storage requires a system that maintains the integrity of the records (no tampering), allows retrieval upon demand, and supports printout in human-readable format.
Most fleet management systems (TenStreet, Drive4Schneider, McLeod, etc.) support DQ file electronic storage. Smaller carriers using local storage should ensure backups exist and that an auditor request can be answered in the 48-hour window typical for a Compliance Review document request.