Truck Driver Qualification Files

We take care of your compliance needs, so you can keep your business growing

Get a Free Consultation

A driver qualification file (DQ file) is the record FMCSA requires a motor carrier to keep for every driver it employs. It proves the driver is qualified: the employment application, driving records, road test proof, the annual review, and medical certification. You keep it while the driver works for you and for three years after.

Our team builds and maintains these files for you.

What is a driver qualification file, and who needs one?

Every motor carrier keeps a driver qualification file for each driver it employs, under 49 CFR 391.51. It may be combined with the driver’s personnel file. The file is your proof that the driver meets the federal commercial driver qualification criteria.

  • Company drivers: one file per driver, started before the first trip and kept current for as long as they drive for you.
  • Leased owner-operators: FMCSA’s definition of employee includes an independent contractor while operating a commercial motor vehicle (49 CFR 390.5T), so the carrier they drive for keeps their file.
  • Owner-operators with their own authority: you are both the carrier and the driver, so you keep a file on yourself (49 CFR 391.1(b)).

Driver qualification is one of the record areas FMCSA reviews in a new entrant safety audit (49 CFR 385.311), and a compliance review examines it too. Our DOT safety compliance page covers the other record areas.

What goes in a DOT driver file?

Each file holds the items below. Some are created once at hiring; others renew on a schedule, which is where most files fall behind.

ItemWhen it is dueRule
Employment application, completed and signed by the driverBefore the driver drives391.21
Motor vehicle record from each licensing authority of the past 3 yearsWithin 30 days of hire391.23(a)(1), (b)
Road test certificate, or a copy of the CDL or road test certificate accepted insteadBefore the driver drives391.31, 391.33
Medical certification: the CDLIS driving record for CDL holders, the medical examiner’s certificate for other driversBefore the driver drives, then at least every 24 months (every 12 months for some conditions)391.23(m), 391.45
Note verifying the medical examiner’s National Registry listing (drivers without a CDL)Before the driver drives391.23(m)(1), 391.51(b)(8)
Motor vehicle record from each licensing authority covering the past 12 monthsAt least every 12 months391.25(a)
Note of the annual review, with the reviewer’s name and the dateAt least every 12 months391.25(c)(2)
Medical variance, Skill Performance Evaluation certificate, or federal medical exemption, if the driver has oneWith the medical certification391.51(b)(6)(iii), (b)(7)
Driver qualification file contents under 49 CFR 391.51(b)

For CDL holders, the file also documents the type of operation the driver self-certified to the state, verified on the same CDLIS record. The full checklist, with the retention period for each record, is in our DQF checklist.

Medical proof for CDL drivers has changed. Since June 23, 2025, medical examiners issue a paper certificate only to drivers who won’t need a CDL or learner’s permit, and the CDLIS record is the proof for CDL holders. A federal exemption that let carriers rely on a paper copy for up to 60 days after it was issued ended on October 11, 2026. FMCSA renewed it for Alaska only, the one state that hasn’t implemented the rule, through October 12, 2027.

Records that stay out of the DQ file

Two sets of driver records are required but must be kept in a secure location with controlled access, apart from the DQ file: the driver investigation history file with previous employers’ replies (49 CFR 391.53), and drug and alcohol testing records (49 CFR 382.401).

One item is no longer required: FMCSA eliminated the driver’s annual list of violations effective May 9, 2022, because the annual driving record already covers it.

How do you verify a truck driver’s previous employment?

You investigate the driver’s safety performance history with every DOT-regulated employer from the preceding three years, and file the replies, or your documented good-faith attempts, within 30 days of the date employment begins (49 CFR 391.23).

  • What you ask for: identification and employment verification, any accidents involving the driver in the three years before the application, and, for drivers who were drug and alcohol tested, any testing violations and return-to-duty history.
  • How you ask: any method works, including letters, phone calls, interviews, fax, or email. Keep a written record of each employer contacted: name, address, date, and what they told you.
  • What previous employers owe you: a response within 30 days of receiving your request, even when they have nothing to report.
  • Drug and alcohol history: since January 6, 2023, the pre-employment Clearinghouse query covers FMCSA-regulated employers. Employers regulated by other DOT agencies are still asked directly, with the driver’s written consent.
  • The driver’s rights: before you make a hiring decision, tell the driver in writing that they may review what previous employers send, ask for errors to be corrected, and attach a rebuttal.

Where these checks fall in a hiring workflow is covered in our truck driver onboarding guide, and the query types in our FMCSA Clearinghouse guide.

What happens when driver files are incomplete?

Incomplete driver files can lower your safety rating. In a compliance review, FMCSA scores them against the acute and critical regulations listed in Appendix B to Part 385:

  • Critical: no DQ file for a driver (391.51(a)); driving record inquiries missing from the file (391.51(b)(2)); medical certificate missing from the file (391.51(b)(6)); using a driver who is not medically certified, or not recertified within 24 months (391.45(a), (b)).
  • Acute: using a physically unqualified driver (391.11(b)(4)) or a disqualified driver (391.15(a)).

Each acute violation adds a point. A critical violation adds a point once it forms a pattern: more than one violation, and at least 10% of the records examined. Two missing medical certificates in a sample of 20 files meet that test. Driver files fall under the rating’s driver factor, which is rated Conditional at 1 point and Unsatisfactory at 2 or more.

For a new carrier, knowingly using a disqualified or physically unqualified driver means failing the new entrant safety audit automatically (49 CFR 385.321). Our new entrant safety audit support helps you get the files ready before the auditor asks. Files kept at a terminal or regional office must be produced within 48 hours of a request, not counting weekends and federal holidays (49 CFR 390.29).

Paper, forms, or software: how should you keep DQ files?

Any format works if the record holds up. Under 49 CFR 390.32, you can keep DQ files electronically and use electronic signatures, as long as the records can be retained and accurately reproduced when an authorized party asks for them.

  • Forms: no single federal form is required. The application must be on a form you furnish that contains everything 49 CFR 391.21 lists. FMCSA’s Motor Carrier Safety Planner forms library offers free samples, including a driver employment application and a Safety Performance History Records Request.
  • Driver file management software: a system can store documents and track due dates, but the rules still call for a person to review each annual driving record and sign the review note with their name and the date.
  • Electronic consent: electronically generated records must include proof of consent to use them, as federal e-signature law requires (390.32(d)).

FMCSA’s sample Safety Performance History Records Request predates the Clearinghouse requirement. For FMCSA-regulated previous employers, the Clearinghouse query now handles the drug and alcohol part; use the form’s drug and alcohol section for employers under other DOT agencies.

How our driver qualification file management works

We work with you and your drivers to build each file, keep it current, and have it ready when an auditor asks. Driver file work is part of our compliance programs for trucking companies.

  • Simplex Hub: driver and vehicle file monitoring and reports, DIY driver onboarding and processing, and portal access for you and your drivers. The SimplexHub portal and Simplex2Go app store your documents and send reminders for expiring documents and driver to-dos.
  • Essentials Program: everything in Simplex Hub, plus driver and vehicle file management, past employment history verification, CDL and medical exam verification, driver compliance reporting, and a DOT mock audit with a risk management plan.
  • Managed Program: everything in Essentials, plus a dedicated account manager and monthly safety reviews with action plans.

Use the form below with your USDOT number and how many drivers you run. Our team will review where your files stand and recommend the program that fits.

Frequently asked questions

What is a DQ file?

A DQ file, or driver qualification file, is the record a motor carrier must keep for each driver it employs under 49 CFR 391.51. It shows the driver is qualified to operate a commercial motor vehicle, and you keep it for the length of employment plus three years.

What should be in a driver qualification file?

The employment application, motor vehicle records from hiring and every 12 months, the annual review note, the road test certificate or accepted equivalent, and medical certification, plus any medical variance or SPE certificate. For drivers without a CDL, add a note verifying the medical examiner’s National Registry listing.

Can DQ files be electronic?

Yes. Since 2018, 49 CFR 390.32 has allowed FMCSA-required records and signatures to be electronic, as long as the records can be retained and accurately reproduced for FMCSA or another authorized party when requested.

Are there free driver qualification file forms?

Yes. FMCSA’s Motor Carrier Safety Planner has a free forms library with a sample driver employment application and a Safety Performance History Records Request. You don’t have to use FMCSA’s exact form, but your application must contain the information listed in 49 CFR 391.21.

What is a truck driver employment verification form?

It is the request you send previous employers for the driver’s safety performance history, which 49 CFR 391.23 requires for every DOT-regulated employer from the past three years. Previous employers must answer within 30 days, and the replies go in the driver investigation history file, not the DQ file.

How long do you keep a driver qualification file?

For as long as the driver works for you and three years after. Annual driving records, review notes, and medical records may be removed three years after their date.

Sources

The rules on this page come from these official sources, checked on October 5, 2026.

Guides

Tap to Call(888) 404-0125