A driver qualification file can be 100% compliant the day you hire a driver—and completely out of compliance a year later if you don’t maintain it. That’s where many carriers run into preventable violations. The problem usually isn’t how the file was built, but what happens after the driver hits the road: updates slip, deadlines get missed, and compliance gaps start to form.
Driver files aren’t one-and-done. They must reflect each driver’s current qualification for as long as they operate under your DOT number and remain on file for a period of three years after employment ends. FMCSA investigators routinely cite carriers for missing annual MVRs, expired medical certificates, and missing violation certifications—all issues that develop long after the initial hire.
This checklist outlines every required maintenance step to keep your driver qualification files accurate, current, and audit-ready.
Your Driver File Maintenance Requirements
Under 49 CFR § 391.51, FMCSA mandates six specific maintenance requirements for driver qualification files. The rules themselves are straightforward. What becomes challenging, however, is tracking every requirement for every driver, every year, without fail. Scale this process across 20, 50, or 100 drivers, and it’s easy to see why file maintenance is one of the most common DOT violation categories.
1. Annual Motor Vehicle Record (§ 391.25(a), § 391.23)
Once every 12 months, you must obtain a current MVR from every state where the driver holds or has held a license. This annual MVR pull is the most commonly missed deadline and one of the top violations auditors cite.
The requirement: Pull MVRs at least once every 12 months—not 13 months, or not when you get around to it. Set the date based on when you first obtained the MVR and stick to that schedule.
How to stay compliant: If a driver was hired in March, pull their MVR every March. Mark it on your calendar immediately. And if they hold licenses in multiple states, you need current records from each state, not just their home state.
2. Annual Review of Driving Record (§ 391.25(c), § 391.51(b)(5))
Getting the MVR is only half the job. You must also review the driver’s record and document that they still meet your minimum safety requirements. This written review proves you’re actively monitoring driver performance, not just filing paperwork.
The requirement: After receiving the annual MVR, create a written notation that includes the reviewer’s name, the date of review, and confirmation that the driver remains qualified to operate.
What auditors check: They want evidence that someone actually reviewed the MVR and made a decision about the driver’s continued qualification. A brief note works fine, but it has to be documented.
3. Annual List of Violations (§ 391.27, § 391.51(b)(6))
Every year, drivers must provide a signed statement listing all traffic violations from the past 12 months, or certifying they had none. This requirement stands even if the MVR shows a clean record.
The requirement: Obtain this signed certification once every 12 months. Most carriers coordinate this with their annual MVR pull to keep things simple.
Watch out for this mistake: Many carriers think the MVR replaces this requirement. It doesn’t. Drivers must separately certify their violations in writing, and you must keep that certification on file.
4. Medical Examiner’s Certificate (§ 391.45(b), § 391.51(b)(7)-(8))
Medical certificates typically expire every two years, though some drivers require more frequent exams. An expired medical card makes the driver immediately unqualified to operate, and having one in the file is a serious violation.
The requirement: Make sure drivers maintain a current medical certificate at all times. Track expiration dates closely and obtain renewed certificates before the old ones expire.
Recent change: Although some waivers have been issued to push back the compliance deadline, paper medical cards are being phased out for CDL holders. Medical examiners now transmit results electronically to state agencies in most cases. You’ll still need to verify medical qualifications and track expiration dates, but the process is shifting to electronic verification. Check with your state agency about their specific implementation timeline.
5. Commercial Driver’s License (§ 391.31, § 391.33, § 391.51(b)(9))
A driver’s CDL must remain valid and carry the proper endorsements for the equipment they operate. When licenses renew or endorsements change, the file needs to be updated immediately.
The requirement: Keep a current copy of the CDL showing all endorsements. If a driver loses an endorsement or adds new qualifications, update the file right away.
Common oversight: Hazmat endorsements require background checks and can expire even when the CDL itself remains valid. Track these expiration dates separately to avoid surprises.
Building a Maintenance System That Works
Carriers who consistently pass audits don’t have more time or bigger compliance teams—they have better systems. While others scramble to update files before inspections, organized carriers stay current year-round.
Here’s what their maintenance systems have in common.
Start With Clear Ownership
File maintenance fails when it’s everyone’s job and no one’s responsibility. Designate a specific person or team as your compliance owner. Give them the authority to chase down documents, set deadlines, and hold people accountable. Without clear ownership, even well-intentioned teams end up with expired medical cards and overdue MVRs.
Create Predictable Cycles
Tracking 50 different expiration dates across 20 drivers is a recipe for missed deadlines. Smart carriers group their maintenance tasks. All January hires get reviewed in January. All Q1 MVRs get pulled the first week of the quarter. When you batch similar tasks, you transform random deadlines into predictable workflows.
Use Technology Wisely
The manual systems that work for five drivers often break down at twenty. Spreadsheets become error-prone, calendar reminders get overlooked, and email alerts get buried. Digital compliance software eliminates these failure points by automating the tracking process, sending alerts weeks in advance of deadlines, and flagging gaps before auditors discover them.
Protect Sensitive Information
Safety Performance History records contain drug and alcohol testing information that requires restricted access under federal law. Store these files separately, limit access to them, and never mix them with general driver documents. One mishandled SPH record can trigger privacy concerns beyond standard DOT violations, since these files contain sensitive drug and alcohol testing history.
How US Compliance Services Simplifies File Maintenance
Over the past five years, driver qualification file violations have consistently ranked among FMCSA’s most cited infractions. With penalties averaging over $7,000 per violation, a few missed updates can quickly become expensive.
US Compliance Services simplifies the entire process. Our platform automatically tracks renewal dates, sends alerts before deadlines, and stores all documents in one secure location. Whether you manage five drivers or 500, we help you maintain compliant files without the constant worry about missed deadlines.
If you’re ready to simplify DQF maintenance and stop chasing expiration dates, we’re here to help. Contact us today to get started.
