The Ultimate Guide to DOT Driver Qualification Files [2025 Update]
Are you keeping up with your driver qualification files?
Over the past five years, FMCSA investigators have issued more than 62,000 violations related to driver files. That’s nearly 17% of all violations recorded—making DQF issues one of the most common (and most preventable) problems carriers face. And in most cases, the problem is simple: missing paperwork that should have been collected on day one or refreshed each year.
With penalties now averaging over $7,000 per violation, even small oversights can come with a big price tag. In this guide, we’ll walk through what DQFs are, what goes in them, how to keep them up to date, and why more carriers are turning to digital solutions to take the guesswork out of staying compliant.
What are Driver Qualification Files?
Driver Qualification Files—commonly known as DQ files or DQFs—are a federally mandated requirement under 49 CFR Part 391 of the Federal Motor Carrier Safety Regulations (FMCSRs). These files serve as a comprehensive record that verifies whether a commercial motor vehicle (CMV) driver is legally and medically qualified to operate.
At their core, FMCSA DQF requirements are designed to promote safety on public roads by documenting a driver’s physical fitness, driving history, and professional background—including their past employment, training, and drug and alcohol testing history.
The regulation applies to any interstate motor carrier, regardless of size, that operates vehicles meeting at least one of the following criteria:
- Has a gross vehicle weight rating (GVWR) or gross combination weight of 10,001 pounds or more
- Is designed or used to transport more than 8 passengers (including the driver) for compensation
- Is designed or used to transport more than 15 passengers, whether for compensation or not
- Transports hazardous materials in a quantity that requires placarding under the Hazardous Materials Transportation Act
That means whether you manage a 50-truck fleet or run your own one-person operation, you're expected to build and maintain a driver file for every CMV operator under your authority—including yourself.
How to Create a Driver Qualification File
A DOT driver qualification file is only compliant if it’s complete—and that starts with collecting the right documents during onboarding.
Over the past five years, investigators cited carriers more than 6,400 times for failing to include a driver’s motor vehicle record (MVR) in the file. Another 5,100+ violations were written for missing or incomplete applications. In total, file-creation issues accounted for nearly 12% of all FMCSA violations, making them one of the most common and easily avoidable compliance breakdowns.
Here’s how to do it right from the start.
1. Start with a DOT-Compliant Driver Application
Regulation: § 391.21
Every DQF begins with a properly completed application for employment. This application must include details such as the driver’s work history, accident record, and license information. All DOT-regulated drivers must fill out an application–whether you’re hiring someone new or filing as an owner-operator.
Violation spotlight:
The DOT issued more than 5,100 citations for missing or incomplete applications. They issued an additional 4,268 violations for failing to store the application in the file.
Best practice:
Use a standardized form built to DOT requirements and store it digitally in a central, secure location.
2. Obtain a Motor Vehicle Record (MVR)
Regulation: § 391.23(a), § 391.51(b)(2)
Before you allow a driver behind the wheel, you must obtain an MVR from each state where they held a license during the past three years. You must then store this record in their driver qualification file.
Violation spotlight:
Missing MVRs are the single most common DQF error, with more than 6,400 violations cited in the past five years.
Best practice:
Use a monitoring service or digital DOT compliance software that pulls and stores MVRs automatically and flags missing records.
3. Verify Previous Employment
Regulation: § 391.23(a)(2)
You are required to investigate a driver’s DOT-regulated employment history from the past three years. This includes safety performance and any drug and alcohol testing violations. You must also retain a record of your outreach to their prior employers—even if they don’t respond.
Violation spotlight:
Failure to conduct these checks led to 2,442 FMCSA violations in the past five years.
Best practice:
Have the driver sign a release form early in the hiring process and retain all emails, letters, or phone logs related to your attempts.
4. Add a Road Test Certificate or CDL Copy
Regulation: § 391.31, § 391.33, § 391.51(b)(9)
Every driver must demonstrate the ability to operate the type of vehicle assigned. You can document this with a road test certificate or a valid CDL that matches the vehicle’s class and use.
Best practice:
Always retain a copy of the driver’s current CDL in the file, regardless of whether a road test was completed. If the driver will be handling specialized cargo—such as hazardous materials or double/triple trailers—make sure the CDL includes the correct endorsements. If it doesn’t, you must administer a road test.
5. Include a Valid Medical Examiner’s Certificate (MEC)
Regulation: § 391.43
Each driver must be medically certified to operate a CMV, which includes passing a physical exam from a provider listed on the National Registry of Certified Medical Examiners. Employers must file this certificate in the driver’s DQF and monitor it for expiration.
Best practice:
Beginning June 23, 2025, paper medical cards will no longer be issued for CDL holders. Instead, medical examiners will transmit results directly to state licensing agencies. Carriers must still track expiration dates and confirm that drivers remain medically qualified to operate a commercial motor vehicle.
6. Check the FMCSA Drug & Alcohol Clearinghouse
Regulation: § 382.701(a)
Before hiring a CDL or CLP driver, you must conduct a full pre-employment query in the FMCSA Drug & Alcohol Clearinghouse. The driver must provide electronic consent, and you must document and retain the query results.
Best practice:
Save both the consent and the Clearinghouse query results in the driver’s DQF or a secure digital compliance system.
7. Gather Safety Performance History (SPH) Documents
Regulation: § 391.23(d)–(e)
In addition to verifying previous employment, you must collect the driver’s Safety Performance History (SPH) from DOT-regulated employers they’ve worked for in the past three years. This includes:
- Crash history
- Safety violations not related to controlled substances or alcohol
- The driver’s written release to contact previous employers
- All attempts to gather this information—even if no response is received
Important Update:
As of January 6, 2023, the FMCSA Drug & Alcohol Clearinghouse became the primary repository for drug and alcohol violation history required under § 391.23(e). Employers no longer need to request this information from previous FMCSA-regulated employers—but you must still contact prior employers to collect general employment details and crash history under § 391.23(d). Drivers who worked under other DOT modes (e.g., PHMSA) may still require separate verification.
Best practice:
Store SPH documents in a secure, limited-access folder separate from the main DQF to protect sensitive personal information. Keep your Clearinghouse queries and SPH contact logs clearly documented in the event of an audit.
8. Include Special Certificates (If Applicable)
Depending on the driver’s role and the type of equipment they’ll operate, you may need to include additional documentation in the driver’s qualification file:
- Entry-Level Driver Training (ELDT) Certificate: Required for CDL holders who obtained their license after February 7, 2022, and have less than one year of experience
- Longer Combination Vehicle (LCV) Driver Certificate: Required for drivers operating double or triple trailers
- Skill Performance Evaluation (SPE) Certificate: Required for drivers with qualifying physical impairments, such as loss of a limb or diabetes treated with insulin
Best practice:
Use a role-specific checklist during onboarding to ensure you include all required certificates based on the driver’s qualifications, experience, and assigned vehicle type.
Final Step: Assemble and Secure the File
Once you’ve gathered all required documentation, store it in a single, well-organized location—either digitally or in hard copy. The file must be completed within 30 days of employment and retained for the duration of the driver’s employment plus three years.
Pro tip:
Use DOT compliance software to keep everything organized and audit-ready. A digital system can separate pre-hire, post-hire, and annual update documents while also sending automatic reminders when deadlines—like medical renewals or annual MVRs—are coming up.
How to Maintain a Driver Qualification File
Creating a complete driver qualification file is just the first step. The FMCSA requires regular updates and reviews for specific documents, and if you don’t stay on top of those timelines, your DQ files can fall out of compliance—fast.
Over the past five years, FMCSA investigators have issued more than 15,000 violations tied to file maintenance issues. These routine lapses show up in fleets of every size, from one-person operations to national carriers.
Here’s what you need to update, how often to do it, and what can happen if you don’t keep up.
1. Conduct an Annual Review of the Driving Record
Regulation: § 391.25(a), § 391.25(c)
Each year, you must request a new Motor Vehicle Record (MVR) for every driver from all states where they hold a license. After receiving the report, someone in your safety department—or whoever is responsible for compliance—must review it and document whether the driver still meets your qualification standards.
2019-2024 Violation spotlight:
- § 391.25(a): Failing to conduct the annual review resulted in 1,848 violations
- § 391.51(b)(4): Not filing the updated MVR led to 3,829 violations
- §391.51(b)(5): Notation of the review was missing in 3,806 cases
Best practice:
Use compliance software that automatically pulls annual MVRs and prompts your team to review and document the outcome.
2. Update the Driver’s Annual List of Violations
Regulation: § 391.27, § 391.51(b)(6)
Once per year, each driver must submit a signed and dated list of all traffic violations they were convicted of in the past 12 months—or certify that they had none. You must compare this list against the updated MVR as part of the annual review process and include it in the driver’s file.
Violation spotlight:
§ 391.51(b)(6): FMCSA issued more than 2,900 violations for failing to include this signed list in the DQF.
Best practice:
Pair this step with your annual MVR pull and review. Use DOT compliance software to automate reminders so the process isn’t overlooked.
3. Monitor Medical Certificate Expiration
Regulation: § 391.45(b), § 391.51(b)(7), § 391.51(b)(8)
Drivers must maintain a valid and current Medical Examiner’s Certificate (MEC) at all times. Most medical certificates are valid for 24 months, but some may expire sooner depending on the driver’s health. If a driver has a medical exemption—such as for insulin-treated diabetes or a limb impairment—you must retain a copy of the applicable waiver or Skill Performance Evaluation (SPE) certificate in the DQF.
Violation spotlight:
§ 391.51(b)(8): FMCSA cited more than 2,800 violations for missing documentation related to medical waivers.
Best practice: Even with digital medical cards on the horizon, carriers must still confirm that each driver’s certification is current. Use compliance software to track expiration dates, retrieve updated MVRs that reflect medical status, and store any required medical waivers or exemption letters in the DQF.
4. Run the Annual Clearinghouse Query
Regulation: § 382.701(b)(1)
Each CDL driver must undergo a limited query in the FMCSA Drug & Alcohol Clearinghouse at least once every 12 months. This check verifies whether the driver has any new violations or unresolved testing issues on record.
Best practice:
Keep proof of each query and any necessary follow-up in the SPH or your compliance log. Use DOT compliance software that integrates with the Clearinghouse to automate queries, manage consent, and avoid missed deadlines.
Digital Driver Qualification Files Keep You Compliant and Ahead of the Curve
Driver file compliance is more than a one-time process. To stay compliant, employers must keep every driver’s DQ file updated and have it readily accessible when the FMCSA comes calling. As enforcement evolves, that’s getting harder to do with paper files and manual checklists.
Today, more audits are happening remotely, and carriers often have just 48 hours to submit complete driver files. The most common violations—missing documents, expired forms, and incomplete reviews—are almost always preventable with the right system in place.
This move away from paper has been building for years. It started with offsite audits, and on June 23, 2025, the FMCSA takes another step forward when the new digital medical card ruling goes into effect. If you're still scanning and filing paper forms, that change alone could leave gaps in your files.
Let Us Help You Stay Compliant
At US Compliance Services, we make it easy to stay on top of your driver qualification file requirements. Our DOT compliance platform keeps everything in one place, with automated alerts and real-time support from a team that understands DOT compliance.
We help you:
- Track MVR reviews, medical renewals, and Clearinghouse queries
- Store driver records securely and organize them for quick access
- Manage sensitive files like SPH documents with proper access controls
- Export complete files on demand for audits, inspections, or roadside stops
Whether you manage one driver or an entire fleet, we’ll help you stay organized, stay compliant, and stay focused on the road ahead.
Are you ready for a simpler way to manage your driver qualification files? Reach out today.