Carrier Launch KitDriver Qualification (DQ) File Checklist
Last updated: October 20, 2026 · Sources: 49 CFR 391.11, 391.21, 391.23, 391.25, 391.31–391.33, 391.43–391.45, 391.51, 391.53
Quick answer: You need one driver qualification (DQ) file per driver, including yourself if you drive (49 CFR 391.51). It holds the signed application, MVRs from every state licensed in the past 3 years, a road test certificate or CDL equivalent, the medical certificate record, and an annual MVR review. Keep the previous-employer investigation history in a separate, secure file. Keep both for the time the driver works for you plus 3 years.
Who can drive (interstate)
A driver must be at least 21, read and speak English well enough to talk with the public, understand road signs, respond to official inquiries and fill out reports. They must be able to safely operate the vehicle, be physically qualified, hold one valid license, not be disqualified, and have a road test certificate or accepted equivalent (391.11(b)).
What goes in the DQ file
| Document | Key details | Rule |
|---|---|---|
| Employment application | Signed, with every item in 391.21(b): 3 years of addresses, employers, accidents and violations; licenses; experience; suspensions; 7 more years of CMV employers for CDL drivers; certification statement | 391.21 |
| Initial MVR | From every state where the driver held a license in the past 3 years. Request within 30 days of hire and file within 30 days | 391.23(a)(1), (b) |
| Road test certificate or equivalent | A valid CDL can be accepted as the equivalent (except double/triple or tank endorsements), or a road test certificate from the past 3 years | 391.31; 391.33 |
| Annual MVR | At least every 12 months, from each licensing state | 391.25(a) |
| Annual review note | Reviewer's name and date; consider violations and accidents | 391.25(b)–(c) |
| Medical examiner's certificate | For CDL drivers, the CDLIS MVR showing medical status. Exams at least every 24 months | 391.43; 391.45; 391.51(b)(6) |
| Medical variance / SPE certificate | Only if applicable | 391.51(b)(7) |
| National Registry verification note | For non-CDL drivers: note verifying the examiner is on the National Registry | 391.51(b)(8) |
The separate investigation history file
Previous-employer safety performance history covers 3 years of DOT-regulated employers: accidents, plus drug and alcohol violations. File it within 30 days of hire with the driver's written authorization and your record of each contact or good-faith attempt. Keep it in a secure, access-controlled location (391.23(c)–(f); 391.53).
How long to keep it
- The DQ file and the investigation history file: the whole time the driver works for you, plus 3 years (391.51(c); 391.53(c)).
- Annual MVRs, review notes, medical certificates, variances and Registry notes may be removed 3 years after execution (391.51(d)).
Automatic failures to avoid
Knowingly using a driver without a valid CDL, or a disqualified or medically unqualified driver, is an automatic failure at the new entrant safety audit (385.321). See the safety audit checklist.
Checklist (per driver)
- ☐ Signed application with every 391.21(b) item
- ☐ MVRs from every state licensed in the past 3 years
- ☐ Road test certificate or copy of CDL accepted as equivalent
- ☐ Medical certificate record; expiration date on the calendar
- ☐ Investigation history file started within 30 days of hire
- ☐ Annual MVR and review date on the calendar
Keep the whole setup in one place
The Carrier Launch Kit New Authority: First 90 Days kit includes a DQ file tracker in the Excel workbook that flags expiring medical certificates. Get the kit → · Free First 30 Days Checklist
FAQ
Do I need a DQ file for myself as an owner-operator? Yes. You need one DQ file per driver, including yourself if you drive (49 CFR 391.51).
How long do I keep a driver qualification file? For the time the driver works for you plus 3 years (391.51(c)).
Can a CDL replace the road test? A valid CDL can be accepted as the road test equivalent, except for double/triple or tank endorsements (391.33).
How often do I need a new MVR? At least every 12 months, from each state where the driver is licensed, with an annual review (391.25).
Educational only, not legal advice. Carrier Launch Kit is not affiliated with FMCSA or USDOT. Check the current rule in the eCFR.
Want it all in one place? The New Authority: First 90 Days kit, $19.
Buy on Gumroad, $19Educational only, not legal advice. Affiliate disclosure.