AFAXLEFILE

The Driver Qualification File checklist

49 CFR 391.51 · Applies to CDL and non-CDL drivers of vehicles over 10,000 lbs in interstate commerce · Updated September 2026

Every motor carrier must keep a qualification file on every driver — including owner-operators driving their own truck, and including non-CDL drivers of vehicles over 10,000 lbs. Here is everything the file must contain, when each item renews, and how long it's kept.

The checklist

DocumentCiteWhen
Employment application391.21At hire
Safety performance history from prior DOT employers (3 yrs)391.23(d)–(e)Within 30 days of hire
Initial driving record (MVR) from every state licensed, prior 3 yrs391.23(a)Within 30 days of hire
Road test certificate — or a valid CDL accepted as equivalent391.31 / 391.33Once
Medical examiner's certificate391.43 / 391.45Renews up to every 24 months — sooner if the examiner says so
Annual MVR391.25(a)Every 12 months
Annual review of driving record (a written note, not just the MVR)391.25(c)Every 12 months

CDL drivers add three more under part 382: a pre-employment drug test result, a pre-employment Clearinghouse query, and a Clearinghouse annual query every 12 months — plus enrollment in a random-testing program or consortium at the company level.

Retention

The file is kept for the whole employment plus three years after the driver leaves (391.51(c)). A handful of items — old medical certificates, old annual MVRs and reviews — may be purged three years after they were created. The safety-performance-history records live in a separate, limited-access file (391.53): the regs themselves expect you to control who can see them.

The three things auditors flag most

AxleFile keeps this checklist automatically. Drivers text in their documents, every renewal date is watched, and the CDL-only items switch on or off per driver — so your file always matches your actual obligation. Join the early-access waitlist →

General information, not legal advice. Interstate rules shown; intrastate-only carriers follow their state's adopted version.