DQ File Checklist (49 CFR 391.51)

What's inside

A. Required at hire

Employment application (391.21), previous DOT employer inquiries within 30 days (391.23), MVR from each licensing authority, road test certificate or accepted CDL.

B. Required and renewed

Annual MVR (391.25(a)), documented annual review, current medical certification, National Registry examiner verification (391.51(b)(9)), MVR medical status for CDL drivers.

C. Only when it applies

ELDT completion (Part 380), LCV training, SPE certificate, medical exemptions, multiple-employer drivers, return-to-duty documentation.

Retention and self-audit

Retain-until date (separation + 3 years) and a quarterly self-audit block.

Sample items

Employment application, complete and signed (391.21)
Inquiry to every previous DOT employer, past 3 years, within 30 days of hire
MVR from each licensing authority, requested by the carrier
Annual review note: reviewer, date, "driver remains qualified"
Examiner verified on the National Registry, screenshot kept
CDL drivers: MVR showing the current medical status (paper not accepted since June 23, 2025)

How to use it

Print one copy per driver and put it on top of the DQ file.
Tick each document as you verify it and write the date.
Write the "retain until" date when the driver leaves.
Every quarter, pull 5 files at random and check them against the list.

Who it's for

Safety specialists and compliance managers
Small carriers preparing for the New Entrant Safety Audit
Owner-operators with their own authority
Office staff who took over DQ files without training

Questions

What is a DQ file?

The Driver Qualification file is the record a motor carrier must keep for every driver of a commercial motor vehicle under 49 CFR 391.51, including leased owner-operators. It proves the driver was qualified when hired and stays qualified.

How long do you keep a DQ file?

For the whole employment plus 3 years after the driver leaves. Documents that are renewed, such as the annual MVR and the annual review, are kept 3 years from their date.

Is the paper medical card still enough for CDL drivers?

No. Since June 23, 2025, for CDL drivers the medical status shown on the MVR is the proof; a paper certificate is no longer accepted on its own. Non-CDL drivers still use the certificate.

Do drug and alcohol records go in the DQ file?

No. Drug and alcohol records are kept in a separate, secured file under 49 CFR 382.401. The DQ file and the drug and alcohol file are different files.

Educational resource, not legal advice. Confirm every item in the current 49 CFR (ecfr.gov) and with FMCSA before acting.

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