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Driver Qualification File Audit Checker

Review a driver file against common 49 CFR Part 391 checkpoints, including the core records identified in § 391.51, annual MVR review, medical qualification and related record-control issues.

Reviewed against current Part 391 sources · September 4, 2026Your answers stay in this browser
How to use it

Choose Yes, No, Not sure or N/A for each checkpoint. This tool is a readiness screen—not a legal determination that Part 391 applies or that a file is compliant.

1. Have you determined that Part 391 DQ requirements apply to this driver?

Confirm the vehicle, operation, interstate/intrastate status, exceptions and any state-specific requirements.

2. Is a compliant driver employment application in the file?

§ 391.21 and § 391.51(b)(1).

3. Is the initial licensing-authority MVR inquiry documented?

§ 391.23(a)(1), § 391.23(b) and § 391.51(b)(2).

4. Is the road-test certificate or permitted equivalent documented?

§§ 391.31, 391.33 and § 391.51(b)(3), subject to current exceptions.

5. Is the current annual MVR inquiry present?

§ 391.25(a) and § 391.51(b)(4).

6. Is the annual driving-record review note present?

§ 391.25(c)(2) and § 391.51(b)(5).

7. Is current medical-qualification evidence documented for this driver?

§ 391.51(b)(6). CDL/CLP and non-CDL processes differ. A temporary FMCSA paper-MEC exemption is also in effect through October 11, 2026.

8. If applicable, is the medical variance / SPE documentation present?

§ 391.51(b)(7). Choose N/A if the driver has no applicable variance or SPE certificate.

9. For a non-CDL driver, is National Registry verification documented when required?

§ 391.23(m)(1) and § 391.51(b)(8)(i). Choose N/A for a driver to whom this does not apply.

10. Is the separate safety-performance investigation history controlled?

§ 391.23 and § 391.53. This related record set is not simply the same thing as the § 391.51 DQ file.

11. Are retention dates being managed?

§ 391.51(c)-(d): general employment + 3-year retention, with specific recurring records removable 3 years after execution.

12. Could you produce the driver file promptly during an FMCSA review?

Organization and accessibility matter—not just whether documents exist somewhere.

What the current § 391.51 list includes

The current rule identifies the driver application, initial MVR, road-test/equivalent documentation, annual MVR, annual driving-record review note, medical-qualification evidence, applicable medical variance/SPE records, and certain National Registry verification documentation. Applicability and exceptions can change which records are appropriate for a particular driver.

One common outdated checklist item

Older DQ-file checklists often list an annual driver certification of violations under former § 391.27. FMCSA removed that requirement in 2022. Current audits should be based on the current regulation rather than an old checklist copied forward year after year.

Safety-performance history is related—but separately controlled

The previous-employer safety-performance investigation required by § 391.23 is maintained in the driver investigation history file under § 391.53. Treating every driver record as one uncontrolled folder can create both organization and confidentiality problems.

Primary sources

Important boundary

This free tool is general educational information. It does not determine whether Part 391 applies to a driver, replace legal or regulatory review, or certify that a carrier or driver file is compliant.