Support:
Updated Driver Files

Driver Qualification File Checklist Update for 2026

DQ file requirements under 49 CFR Part 391 for 2026: a pre-employment Clearinghouse query and current medical certification are required before a driver operates, and the pre-employment MVR must be in the file within 30 days of hire.

The required documents

A driver-qualification (DQ) file under 49 CFR §391.51 must contain: (1) the driver's application for employment (§391.21), (2) the pre-employment MVR from each state that licensed the driver in the prior 3 years (§391.23(a)(1)), (3) the road test certificate or accepted equivalent (§391.31, §391.33), (4) each annual MVR (§391.25(a)), (5) a note of the annual driving-record review with the reviewer's name and date (§391.25(c)(2)), (6) the medical examiner's certificate - for CDL holders, the CDLIS MVR showing medical certification status, and (7) any medical variance or SPE certificate. Safety performance history inquiries to prior DOT-regulated employers covering the prior three years (§391.23(a)(2)) go in the driver investigation history file.

Drivers hauling placardable hazmat need a hazardous materials (H) endorsement on their CDL; a state may not issue it until TSA determines the driver does not pose a security risk (49 CFR §383.141).

Auditor focus areas

Common DQ file gaps in audits include: missing pre-employment Clearinghouse query (required before the driver performs safety-sensitive functions under §382.701(a)), 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).

Under §391.23(c)(2), the carrier must make a written record for each previous employer contacted, or good-faith efforts to do so, including the previous employer's name and address, the date contacted or the attempts made, and the information received. A bare "we asked, no answer" note is not sufficient.

Going digital

DQ files may be kept electronically under 49 CFR §390.32. Electronic records must accurately reflect the required information and be capable of being retained and accurately reproduced within required timeframes for anyone entitled to access them.

Many fleet management systems support electronic DQ files. Smaller carriers using local storage should ensure backups exist; records kept at a regional office or driver work-reporting location must be produced within 48 hours of an FMCSA request, excluding weekends and federal holidays (§390.29(b)).

Read more

DOT Compliance Handbook

More recent updates

All trucking compliance news →