The DQF checklist: what goes in, and how long it stays
A driver qualification file is checked against a short, fixed list. Most findings come from items that were never renewed, filed in the wrong place, or kept on an old rule.
Written by Inely Baez
Driver files in numbers
A DQF checklist follows 49 CFR 391.51: the employment application, driving records from hiring and every 12 months, the annual review note, the road test certificate or accepted equivalent, and medical certification, plus any variance or Registry note. Keep the file while the driver works for you and 3 years after.
Auditors don't read a driver qualification file as a story about the driver. They check it against a short list in the regulations, and the same gap repeated across enough files becomes a finding.
I lead operations at Simplex, and I treat each DQF as a system with three clocks: what is collected at hiring, what renews every 12 months, and how long each record is kept after that.
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Key takeaways
The contents are a fixed list
49 CFR 391.51 names what goes in: the application, driving records, road test proof, the annual review note, and medical certification.
The annual violations list is gone
Drivers no longer furnish a yearly list of traffic convictions. FMCSA removed that requirement effective May 9, 2022; the annual driving record and review remain.
CDL medical proof is the state record
For CDL holders, the CDLIS driving record showing medical status is the proof. An exemption allowing recent paper copies ends October 11, 2026.
Some records stay out of the DQF
Previous-employer investigations and drug and alcohol records go in separate, secure files with controlled access.
Retention runs on two clocks
Keep the file for employment plus 3 years. Annual and medical records inside it may be removed 3 years after their date.
In this articleContents
What is a DQF, and who needs one?
A DQF, or driver qualification file, is the record a motor carrier keeps to show that each driver it employs is qualified to drive a commercial motor vehicle. Under 49 CFR 391.51(a), every carrier keeps one per driver, and it may be combined with the personnel file.
The rule covers drivers of commercial motor vehicles in interstate commerce: generally vehicles rated at 10,001 pounds or more, certain passenger vehicles, and vehicles hauling placarded hazardous materials. The driver must also meet the basic commercial driver qualification criteria the file documents.
- Leased owner-operators need a file. FMCSA's definition of employee includes an independent contractor while operating a commercial motor vehicle.
- Owner-operators with their own authority keep a file on themselves: a person who is both the carrier and its driver must meet both sets of duties (49 CFR 391.1(b)).
- Drivers furnished by another carrier can run on that carrier's signed certificate that they are qualified. Verify it with the issuing carrier and keep a copy for 3 years (49 CFR 391.65).
- Multiple-employer drivers skip the application, pre-hire investigations, and annual record review, but the rest of Part 391 applies. Record their name, Social Security number, and license details before they drive (49 CFR 391.63).
A freight broker that only arranges transportation has no drivers to qualify: Part 391 sets duties for motor carriers. If the broker also runs trucks under its own carrier authority, each of those drivers needs a file.
The DQF checklist: what goes in every driver qualification file
Under 49 CFR 391.51(b), the file holds the items below. Some are created at hiring; others renew on a schedule.
| Item | Rule | When |
|---|---|---|
| Employment application | 391.21 | Before the driver drives |
| Driving record from each licensing authority, past 3 years | 391.23(a)(1) | Within 30 days of hire |
| Road test certificate, or the CDL or certificate accepted instead | 391.31, 391.33 | Before the driver drives |
| Driving record from each licensing authority, past 12 months | 391.25(a) | Every 12 months |
| Annual review note with the reviewer's name and date | 391.25(c)(2) | Every 12 months |
| Medical certification: CDLIS record for CDL holders, examiner's certificate for others | 391.51(b)(6) | Before driving, and at each renewal |
| Medical variance, SPE certificate, or federal medical exemption | 391.51(b)(6)(iii), (b)(7) | If the driver has one |
| Note verifying the examiner is on the National Registry | 391.51(b)(8)(i) | Drivers who don't need a CDL |
Two more items apply to some drivers only: for CDL drivers, a documented check of the operation type they self-certified to their state (391.23(m)(2)); for longer combination vehicle drivers, the LCV driver-training certificate or Certificate of Grandfathering (49 CFR 380.401 and 380.111).
How does medical proof work for CDL drivers now?
Since June 23, 2025, medical examiners issue a paper certificate only to drivers who won't operate a vehicle requiring a CDL or learner's permit. For CDL holders, the file's proof is the CDLIS driving record from the current licensing state showing medical certification status.
An FMCSA exemption still lets carriers file a paper copy of a certificate issued within the previous 60 days while the last states finish connecting to the system. It expires October 11, 2026, and FMCSA has said it does not expect to grant another nationwide one.
What is no longer required?
- The driver's annual list of violations. FMCSA removed the old 49 CFR 391.27 effective May 9, 2022, because the annual driving record duplicates it. You may still require one as company policy.
- A National Registry note for CDL drivers. That requirement ended June 22, 2025; the CDLIS check replaces it.
- A copy of the CDL, unless you accepted it in place of the road test. Then 391.33(b) requires a legible copy in the file.
Which records stay out of the DQ file?
Three sets of driver records are required but kept apart from the DQ file, because the rules limit who may see them or where they live.
- Driver investigation history file. Previous employers' safety performance replies, the driver's authorization, and your log of contact attempts. Keep it in a secure location with controlled access, and use it only for the hiring decision (49 CFR 391.53).
- Drug and alcohol program records. Test results, refusals, SAP evaluations, and the driver's signed receipt of your policy, also in a secure, controlled-access location (49 CFR 382.401).
- Clearinghouse query records. Keep a record of each query and its results for 3 years. Since January 6, 2023, a valid Clearinghouse registration meets that requirement (49 CFR 382.701(e)).
The order in which hiring creates these records is covered in our truck driver onboarding guide, and query types in our FMCSA Clearinghouse guide.
DQF retention requirements: how long do you keep each record?
Keep the DQ file for as long as the driver works for you and 3 years after. Some records inside it may be removed earlier, 3 years after the date they were completed (391.51(d)).
| Record | Keep for | Rule |
|---|---|---|
| The DQ file as a whole | Employment + 3 years | 391.51(c) |
| Annual driving records, review notes, and medical records | 3 years from each record's date | 391.51(d) |
| Previous-employer safety history, hired drivers | Employment + 3 years | 391.53(c) |
| Clearinghouse query records | 3 years | 382.701(e) |
| Positive tests, refusals, SAP evaluations and referrals | 5 years | 382.401(b)(1) |
| Collection-process records | 2 years | 382.401(b)(2) |
| Negative or canceled drug results; alcohol results below 0.02 | 1 year | 382.401(b)(3) |
| Drug and alcohol training records, including policy receipts | While in the role + 2 years | 382.401(b)(4) |
| Hazmat training record covering the past 3 years | Employment + 90 days | 172.704(d) |
How do auditors judge a DQF?
In a compliance review, FMCSA checks driver files against the acute and critical regulations listed in Appendix B to Part 385. The driver-file items on that list are:
- No DQ file for a driver (391.51(a)), critical
- Driving record inquiries missing from the file (391.51(b)(2)), critical
- Medical certificate missing from the file (391.51(b)(6)), critical
- Using a driver not medically certified, or not recertified within 24 months (391.45(a), (b)), critical
- Using a disqualified or physically unqualified driver (391.15(a), 391.11(b)(4)), acute
A single acute violation counts. A critical violation counts as a pattern: more than one violation, and at least 10% of the records examined. Two files missing a medical certificate out of 20 examined meet that test. Each one adds a point against the factor ratings behind your DOT safety rating.
New carriers face driver-file checks in the new entrant safety audit, where knowingly using a disqualified or physically unqualified driver is an automatic failure; see our new entrant safety audit checklist.
Digital files are fine. Under 49 CFR 390.32, records may be kept electronically if they can be retained and accurately reproduced when an authorized party asks. Files kept at a terminal must be produced within 48 hours of a request, excluding weekends and federal holidays (390.29).
How to keep every DQF audit-ready
Each step turns part of the checklist into a routine with an owner.
Step 1: Use one file order for every driver
Same sections, same sequence: hiring, annual, medical, exceptions. A standard order makes a missing item visible at a glance.
Step 2: Calendar the renewal clocks
Track each driver's 12-month driving record and review, each medical certification expiry, and the annual Clearinghouse query. Set reminders weeks ahead, because records and exams take time to arrive.
Step 3: File the right medical proof
For CDL drivers, pull the CDLIS record after each recertification and file it. After October 11, 2026, a paper copy no longer stands in for it.
Step 4: Keep restricted records apart
Investigation history and drug and alcohol records belong in secure, controlled-access files, not in a DQ file that dispatch or HR can open.
Step 5: Purge on schedule
Remove annual and medical records once they pass 3 years, if you choose, and keep a departed driver's file for 3 years after the last day of employment.
Step 6: Self-audit a sample every month
Check a few files a month against the table above. Because a pattern starts at 10% of files examined, a gap that repeats across the fleet matters more than one missing page. Our driver qualification file service can run that check with you.
How Simplex helps you keep driver files complete
Every file needs someone collecting, renewing, and checking it. We can take on each part.
Driver qualification files
Our driver qualification file service works with you and your drivers to keep each file complete, documented, and audit-ready.
Audit guidance and support
Facing a new entrant audit or a compliance review? Our audit guidance and support helps you prepare the documentation and navigate the process.
A program that keeps checking
Our compliance programs include driver qualification file management, CSA monitoring, and mock audits.
Frequently asked questions
What does DQF mean in trucking?+
What is on a DQF checklist?+
How long do you keep a driver qualification file?+
Do freight brokers need a DQF checklist?+
Can driver qualification files be digital?+
Do owner-operators need a DQ file?+
Where this information comes from
The requirements below come from federal regulation and the Federal Register, checked on September 24, 2026.
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1
eCFR — 49 CFR 391.51
What the driver qualification file must contain, and how long to keep it.
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2
eCFR — 49 CFR 391.25
The annual driving record inquiry and the reviewer's note.
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3
eCFR — 49 CFR 391.53
The separate driver investigation history file and its retention.
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4
eCFR — 49 CFR 382.401
Retention periods for drug and alcohol program records.
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5
eCFR — 49 CFR 382.701
Clearinghouse queries and the 3-year query record.
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6
eCFR — Appendix B to 49 CFR Part 385
Acute and critical driver-file violations, and the 10% pattern rule.
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7
Federal Register — Record of Violations (March 9, 2022)
Removal of the driver's annual list of violations, effective May 9, 2022.
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8
Federal Register — Paper medical certificate exemption (April 14, 2026)
Paper copies accepted for 60 days, through October 11, 2026.
Written by
Inely Baez
Chief Operating Officer, Simplex Group
Chief Operating Officer at Simplex Group, with nearly eight years at the company leading operational strategy and execution across compliance, technology, logistics, and performance systems. She is a Certified Public Accountant with a background spanning operations and finance, including leadership roles within Simplex's Freight 4 U division and Velox Transport Solutions. Her work focuses on building scalable, disciplined systems that support long-term performance and growth.
Published · Updated
Related articles and services
A complete file is one somebody keeps checking
The checklist is short. What breaks it is time: a record that was never renewed, a medical copy that stopped counting, a file kept past the rule or purged too early.
If you want help reviewing your driver files against the checklist, or taking over the renewals, talk to our team.