What goes in a driver qualification (DQ) file?
Under 49 CFR 391.51, you must keep a qualification file for every driver you employ. It must contain:
- The driver's application for employment (391.21).
- Inquiries to previous employers — the safety-performance history, including DOT drug/alcohol history (391.23).
- A motor vehicle record (MVR) from every state the driver was licensed in, obtained at hire (391.23).
- The annual MVR and the annual review of driving record (391.25).
- A road test certificate or an acceptable equivalent — a valid CDL accepted in lieu of a road test (391.31 / 391.33).
- The medical examiner's certificate and, where required, the medical examiner's national registry verification (391.43).
- A note relating to the annual driving-record review confirming the driver remains qualified (391.25).
The medical certificate is the item that most often lapses. A driver whose medical card expires becomes medically unqualified the moment it does — an automatic-failure item on an audit. Track expiration dates and re-certify before they pass.
How long to keep DQ records
Retention is specific and auditors check it:
- The active DQ file — kept for as long as the driver is employed, plus 3 years after they leave.
- Annual MVR and annual review — retained for 3 years.
- Medical certificates — keep the current one; retain superseded ones per your policy and the 3-year rule.
A file that's complete today but missing last year's annual review still fails. The DQ file is a living record, not a hiring formality.
The Drug & Alcohol Clearinghouse: what you must query
The FMCSA Drug & Alcohol Clearinghouse (49 CFR Part 382, Subpart G) is a federal database of CDL drivers' drug and alcohol program violations. Every carrier that employs CDL drivers has two standing query obligations:
- Pre-employment full query — before you let a new CDL driver operate, you must run a full query, which requires the driver's specific electronic consent in the Clearinghouse. You cannot use the driver until you've reviewed the result.
- Annual limited query — at least once every 12 months for every current CDL driver, with the driver's general written consent on file. If a limited query shows a record exists, you have 24 hours to obtain the driver's consent and run a full query, and you must remove the driver from safety-sensitive functions until it's resolved.
You must also report violations you determine — positive tests you're the employer for, refusals, and actual-knowledge violations — and record return-to-duty and follow-up completions. Under the stricter 2026 timelines, report promptly (within about 24 hours of the triggering event).
Why the Clearinghouse now controls the license itself
Since November 18, 2024, the Clearinghouse-II rule connects the database to state licensing. When a driver enters prohibited status — an unresolved violation — their state must downgrade their CDL until they complete return-to-duty. For you, that means a driver can silently lose their CDL mid-employment.
The defensive move is continuous monitoring, not once-a-year checking. A driver in prohibited status whom you keep driving is an unlicensed driver — an automatic-failure violation and a serious liability exposure. See how this fits the broader 2026 changes.
The DQ and Clearinghouse mistakes that fail audits
- Letting a medical certificate lapse without catching it.
- No pre-employment full query before the driver's first dispatch.
- Missing the annual limited query on a current driver.
- No driver consent on file for queries.
- Skipping the annual MVR / annual review.
- Not reporting a determined violation to the Clearinghouse.
Each of these is common, avoidable, and exactly what an auditor is trained to find. A managed DQ and Clearinghouse program keeps the files complete and the queries on schedule so none of these is ever the reason you fail.