How Long Do I Have to Keep Driver Qualification Files? Fines, Rules, and Common Mistakes

Q: How long do I have to keep driver qualification files?

A: According to 49 CFR §391.51, carriers must maintain a driver’s qualification file for as long as the driver is employed, plus three (3) years after the driver leaves. This rule applies to every driver you employ who operates a commercial motor vehicle under FMCSA regulations.

Driver Qualification Files: What Goes Inside

A complete DQ file isn’t just one or two forms. FMCSA requires multiple documents that prove your driver is fit and qualified to operate. Examples include:

• Driver’s employment application (§391.21)
• Motor Vehicle Records (MVRs) from each state, plus annual updates (§391.23, §391.25)
• Road test certificate or CDL equivalent (§391.31)
• Medical examiner’s certificate (MEC), Form MCSA-5876 (FMCSA Medical Overview)

For a full checklist, FMCSA provides a printable resource: Driver Qualification File Checklist (PDF).

How Long to Keep Each Item

Big picture: keep the entire driver qualification file for the driver’s employment period + 3 years after separation (§391.51(c)).

Items You May Purge After 3 Years

• Annual MVRs used for yearly reviews (§391.25)
• List of violations and review notes (§391.27)
• Verification notes for medical examiner registry (when required by rule)

Why This Matters

Think about it like this: a driver qualification file is your driver’s compliance folder. If DOT shows up for an audit or after a crash, this file proves you only put qualified drivers on the road. Without it, you’re wide open to violations, fines, and liability claims.

Fines and Consequences for Missing Driver Qualification Files

Failing to maintain DQ files can get expensive very quickly:

• FMCSA civil penalty tables show fines from $1,000 to $10,000+ per violation.
• If multiple drivers are missing files, fines stack across each one — quickly multiplying your exposure.
• Poor recordkeeping drives up CSA scores, which leads to more audits, higher insurance costs, and lost freight contracts.

Bottom line: a missing or incomplete DQ file isn’t just paperwork — it’s a direct hit to your bottom line.

Common Mistakes Carriers Make With Driver Qualification Files

Even small fleets that try to stay compliant often stumble on these:

• Forgetting annual MVR reviews: Every 12 months you must pull an updated MVR and document the review (§391.25).
• Letting medical certificates expire: An expired MEC is one of the top driver-related violations found at roadside inspections.
• Incomplete applications: Missing work history or leaving unexplained gaps opens you up to audit findings.
• Purging too early: Some carriers toss DQ files right after a driver leaves. Remember: keep them three years beyond employment.
• Disorganized storage: Scattered paperwork or poorly labeled digital folders make it impossible to prove compliance fast.

Quick Compliance Tips

• Centralize storage: Create a digital folder per driver with subfolders for Application, MVRs, Medical, Road Test, and Annual Review. Mirror it with paper if needed.
• Set reminders: Calendar the §391.25 annual review and MEC expiration dates.
• Use a purge policy: Only remove documents allowed under §391.51(d) after three years from execution — but retain the full file for employment + 3 years.

Sources (official): eCFR: 49 CFR §391.51 · Cornell Law: §391.51 · FMCSA DQ File Checklist (PDF) · FMCSA: Medical Examiner’s Certificate · FMCSA Civil Penalties