For owner-operators and small carriers
Updated September 28, 2026
A driver qualification file (DQ file) is the set of records a motor carrier must keep for every driver it uses, as 49 CFR 391.51 requires. It holds the driver’s application, driving records, road test certificate, annual review and medical records.
If you run your own authority, you are the carrier. That means you keep a DQ file on yourself, even as a one-truck operation.
This checklist gives each record, the rule behind it, when it is due and how long to keep it. It comes from a car-haul carrier that works with sub-haulers running their own authority.
What Is a Driver Qualification File?
Every motor carrier must keep a qualification file for each driver it employs. The file can be combined with the driver’s personnel file. FMCSA’s Motor Carrier Safety Planner says every driver needs an application on file, including owner-operators.
The file is your proof that each driver meets the federal driver rules. Under 49 CFR 391.11, a qualified driver:
- Is at least 21 years old
- Reads and speaks English well enough to talk with the public, read road signs, answer officials and fill out reports
- Can safely drive the type of truck through experience, training or both
- Is physically qualified under the federal medical rules
- Holds a valid commercial license from one state only
- Is not disqualified from driving a commercial vehicle
- Has passed a road test, or has a license or certificate the carrier accepts in its place
Some drivers and operations have exceptions under the rules, such as the ones in Subpart G of Part 391. If you think one applies, read the rule itself.
The Driver Qualification File Checklist
This is what 49 CFR 391.51 requires in the file for a CDL driver:
| Record | Rule | When | Keep it |
|---|---|---|---|
| Signed driver application | 391.21 | Before the first trip | While employed, plus 3 years |
| Driving record (MVR) from each state that licensed the driver in the past 3 years | 391.23(a)(1) | Within 30 days of hire | While employed, plus 3 years |
| Road test certificate, or a copy of the CDL or road test certificate you accept in its place | 391.31 391.33 | Before the first trip | While employed, plus 3 years |
| Annual driving record from each state | 391.25 | At least every 12 months | 3 years from the date |
| Note of the annual review, with the reviewer’s name and the date | 391.25 | At least every 12 months | 3 years from the date |
| Medical status: the CDLIS driving record from the driver’s current licensing state | 391.51(b)(6) | Before the first trip | 3 years from the date |
| Skill Performance Evaluation certificate, medical exemption or medical variance, if the driver has one | 391.49 391.51(b)(7) | If it applies | 3 years from the date |
For a driver who does not need a CDL, the file holds the medical examiner’s certificate or a legible copy. It also needs a note that the examiner is on the National Registry of Certified Medical Examiners.
One item you may still see on old checklists: the driver’s yearly list of traffic violations. That rule, 391.27, is now marked “Reserved” in the regulations. FMCSA’s own printable checklist (revised July 2017) still shows it, so check each item against the current rule.
FMCSA’s checklist also lists records that apply only in some cases, such as entry-level driver training certificates and pre-employment drug and alcohol documents. Our guides to entry-level driver training and DOT drug and alcohol testing cover those rules.
Annual Tasks
Put these on the calendar for every driver, including yourself:
- Pull a new driving record. At least once every 12 months, ask each state that licensed the driver in the past year for a record covering at least that year.
- Review it. Check whether the driver still meets the safe-driving rules or is now disqualified. Give great weight to violations like speeding, reckless driving and driving under the influence.
- Write the note. Put a note in the file with the name of the person who did the review and the date.
Also watch the medical side. A medical certificate lasts up to 2 years, or less if the examiner sets an earlier date, and the CDLIS record shows the driver’s current status. Our DOT physical guide covers the exam.
How Long to Keep Each Record
The whole file
Employment + 3 years
Keep each driver’s file for as long as the driver works for you, and for 3 years after.
49 CFR 391.51, paragraph c
Rolling records
3 years from the date
You may remove the annual driving records, review notes, medical records and any SPE certificate or medical exemption 3 years after the date on each one.
49 CFR 391.51, paragraph d
The Separate Driver Investigation History File
When you hire a driver, you must also ask the driver’s past DOT-regulated employers from the last 3 years about the driver’s safety record. That includes crashes and drug and alcohol violations. Those answers go in a different file, the driver investigation history file (49 CFR 391.53).
- Keep it in a secure place, open only to the people who need it for the hiring decision.
- It holds the driver’s written permission to ask about drug and alcohol history, and each past employer’s answer or your good faith efforts to get one.
- Keep the histories for a hired driver while the driver works for you, plus 3 years.
Our guide to DAC reports, PSP and MVR explains these background checks from the driver’s side.
If You Are an Owner-Operator on Your Own Authority
With your own authority, you are both the carrier and the driver. Each role has its own jobs in the file:
As the carrier
- Keep a qualification file on yourself, like any other driver.
- Have someone other than you give your road test. Or accept a copy of your own CDL in its place, if you took the CDL road test in the same type of truck.
- Pull your own driving record every 12 months, review it and write the note.
As the driver
- Fill out and sign a driver application, even though you are the only driver.
- Keep your medical certificate current. For a CDL driver, the file proves it with the CDLIS record from your state.
- Know the limit: a CDL does not stand in for the road test on double or triple trailers or tank vehicles.
Starting out? Our guide to getting your own trucking authority covers the steps before this one.
Sub-Hauling for Accelerated
Accelerated’s sub-hauler program is for carriers that run their own authority. You onboard through MyCarrierPackets, then pull the freight we post. As your own carrier, your DQ files stay your job.
What it takes to qualify
- Active operating authority, with your own MC and DOT numbers
- At least 6 months in business as a carrier
- A car-hauling truck in good condition and a clean safety record
- The required insurance, sent by your agent
Your authority, your truck, contracted OEM freight.
Driver Qualification File FAQs
What goes in a driver qualification file?
The driver’s signed application, driving records from each state that licensed the driver in the past 3 years, the road test certificate or accepted equivalent, each annual driving record and review note, and medical records. For a CDL driver, that is the CDLIS driving record from the current licensing state.
How long do you keep a driver qualification file?
Keep the file while the driver works for you and for 3 years after. Annual driving records, review notes, medical records and any SPE certificate may be removed 3 years after their date.
Does an owner-operator need a driver qualification file?
Yes, if you run under your own authority, because you are the motor carrier. FMCSA says every driver needs an application on file, including owner-operators. Someone other than you must give your road test, or you can accept a copy of your CDL in its place.
How often do you review a driver’s driving record?
At least once every 12 months. Pull a new record from each state that licensed the driver, review it, and put a note in the file with the reviewer’s name and the date.
Haul Cars on Your Own Authority
Accelerated holds contracts with the automakers and posts that freight for sub-haulers. Run your own truck under your own MC and DOT numbers, onboard once through MyCarrierPackets, and choose your ACH pay terms.
Rather drive under our authority? Apply to contract with Accelerated.
Sources
Last checked September 28, 2026. This is a plain summary of federal recordkeeping rules. The medical certificate rules changed in 2025, so check 391.51 and 391.43 each year.
- 49 CFR 391.51, general requirements for driver qualification files
- 49 CFR 391.11, general qualifications of drivers
- 49 CFR 391.21, application for employment
- 49 CFR 391.23, investigation and inquiries
- 49 CFR 391.25, annual inquiry and review
- 49 CFR 391.27 (Reserved)
- 49 CFR 391.31, road test
- 49 CFR 391.33, equivalent of road test
- 49 CFR 391.43, medical examination and certificate
- 49 CFR 391.53, driver investigation history file
- FMCSA Safety Planner, 6.1.2 Driver Qualification File
- FMCSA, Driver Qualification File Checklist (PDF, rev. July 2017)
- Accelerated, sub-hauler program