Every DQF has 31 items. An audit asks for all of them.
FMCSA Part 391 requires up to 31 items per driver qualification file - application, past-employer inquiries, drug and alcohol history, medical certificate, MVR, annual review, certificate of violations. Gaps show up under audit. A purpose-built DQF tracker pre-loads the template, tracks every item's expiry independently, and produces a complete file in 60 seconds.
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items in a complete DQF
3 years
DQF retention after termination
48 hrs
typical FMCSA audit document window
$16,864
max per-driver DQF penalty
- FMCSA Part 391 requires a Driver Qualification File (DQF) for every CDL driver - with 18+ distinct documents per file.
- A single missing document in a random audit triggers violations that can affect your CSA score, insurance rates, and DOT authority.
- The hardest part of DQF is not the initial file - it's staying on top of annual MVR checks, medical card renewals, and periodic reviews.
- Purpose-built DQF software tracks each item with its own renewal cadence and stores the document alongside the expiry record.
- ExpiryEdge's multi-channel reminders reach drivers in the cab (SMS/WhatsApp) without requiring them to check email.
What belongs in a complete DQF
The Part 391 required items - mapped to record types in your tracker.
Recurring DQF obligations, by cadence
Each item has its own clock. Calendar one cycle per item, every driver.
Medical Examiner's Certificate
Up to 24 months validity (less with certain conditions). Track the expiry date, not the issue date. Driver must self-certify at each renewal.
Motor Vehicle Record (MVR)
Pull annually per driver, per state holding driving privileges. Review, sign, and file. The review signature is audit-visible.
Certificate of Violations
Driver submits annually listing all moving violations from the past 12 months (or attest none). Must be on file even when clean.
Annual Driving Record Review
Carrier review of the MVR plus certificate of violations. Document the review finding: acceptable, coaching required, or disqualified.
Drug & Alcohol Program
Random pool testing at FMCSA minimum annual rates. Per-driver record of selections, tests, results, and any SAP referrals.
CDL and endorsements
State-issued with state-specific cadence. Hazmat endorsements require TSA background check every 5 years.
Four ways an FMCSA audit arrives
Not every audit is a full Compliance Review. Know which scenario you are facing so you bring the right records.
Compliance Review (CR)
On-site or off-site review, usually triggered by safety score deterioration or a reportable incident. Investigator requests driver files, D&A records, HOS records, and vehicle inspection history. Typically 48-hour document window.
New Entrant Safety Audit
Mandatory within 12 months of receiving DOT authority. Focus on verifying carrier is following Parts 390-397, including complete DQFs. Failure means authority revocation until remediated.
Roadside Inspection (Level I-VI)
Driver or vehicle intercepted. Driver must produce medical card, CDL, HOS records. A missing or expired medical card is an immediate out-of-service violation.
Focused Review
Targeted on one BASIC (Behavior Analysis Safety Improvement Category) - Unsafe Driving, HOS, Vehicle Maintenance, Drugs/Alcohol, Driver Fitness, or Crash Indicator. Usually triggered by the carrier appearing in OSHA high-risk categories.
What a DQF tracker actually does
Six capabilities that separate a Part 391 tool from an employee database with hope attached.
Part 391 template out of the box
Every driver record comes pre-populated with the Part 391 DQF items. Not a blank custom field, not a generic employee record. A DQF is a DQF.
Per-item expiry tracking
Medical card has its expiry. MVR has its annual cycle. Annual review has its own. Each item tracked independently with its own reminder cadence.
Driver-side access
Drivers upload their renewed medical card from their phone. The document lands directly in the DQF. No faxing, no photo in a group text.
Automatic escalation
Driver ignores the 14-day SMS reminder for their medical card? The safety manager gets the 7-day alert. Dispatcher gets the day-of alert. No truck leaves the yard on an expired card.
One-click file export
FMCSA investigator requests Driver Smith's DQF. Export. PDF packet with every required item. Sixty seconds. The audit becomes a show-and-tell, not a scramble.
Retention clock for terminated drivers
Three-year retention after termination. Tracker shows when a terminated-driver file can be retired and when it must still be kept. No premature disposal, no indefinite hoarding.
Rollout in six steps
Works for fleets from 10 to 1,000 drivers.
Import driver roster
CSV import or direct sync from Samsara, Motive, or your TMS. Every active driver becomes a record with the Part 391 template attached.
Upload existing documents
For each driver, upload what you already have: application, MVR, medical card, road test cert. Documents that live in personal email or file cabinets become part of the digital DQF.
Identify gaps
The template shows red on any DQF item missing. Most fleets find 15-30% of files have at least one gap - usually missing PSP requests, missing annual review sign-offs, or expired medical cards nobody caught.
Close the gaps
Renew what is expired. Request what is missing. Document the review signatures. Week-one work; do not skip it to get to fancy features.
Configure reminder schedules
Medical card: 180/90/30/7 days. MVR: annual cycle with 60-day lead. Annual review: 30-day lead. Each on the channel the owner uses.
Run a mock audit
Pick three drivers at random. Export their files as PDFs. Review against the Part 391 checklist. If any gap remains, fix it. If none remain, you are ready for an FMCSA review.
Frequently asked questions
What safety managers and fleet owners ask before rolling out DQF software.
What is a Driver Qualification File (DQF)?
A DQF is the collection of documents required by FMCSA Part 391 demonstrating a driver is qualified to operate a commercial motor vehicle for your carrier. It contains up to 31 items including the employment application, past employer inquiries, drug and alcohol testing history, MVR, medical certificate, road test, annual reviews, and certificate of violations. Complete DQFs are required for every CDL driver and must be produced on demand during an FMCSA audit.
How long must we keep driver files?
For active drivers, maintain the DQF current throughout employment. After termination, retain the file for three years from the date of termination. Drug and alcohol program records follow separate retention rules under Part 382 (up to five years for positive tests and refusals). Document every step of the retention and disposal cycle.
Can drivers maintain their own files?
Drivers can contribute documents (renewed medical card, renewed CDL, certificate of violations) but the carrier remains responsible for DQF completeness under Part 391. A driver-upload workflow speeds things up, but the safety manager has to verify the document is what it claims to be and is placed in the correct record.
What about intrastate drivers?
Intrastate DQF requirements vary by state, but most states mirror Part 391. A handful allow exemptions for specific industries or short-haul operations. Check your state's version of 391 (for example, California Title 13 §1234 or Texas §522). A good tracker lets you configure state-specific DQF items.
How is this different from our TMS?
TMS manages loads, routes, and billing. A DQF tracker manages driver qualification records. Some TMS platforms include basic driver file features; most do not meet Part 391 without supplemental tracking. Use the TMS for operations; use a dedicated tracker for qualification files.
What triggers an FMCSA compliance review?
Most commonly: deteriorating CSA safety scores in any BASIC category, a reportable crash, a pattern of roadside inspection violations, or a complaint. Some reviews are random or part of a new-entrant program. Carriers with clean scores rarely see a full review, but roadside inspections and focused reviews happen regardless.
Related guides
More guides to help you pick the right compliance tool.
Sources & further reading
Authoritative references consulted for this article.
- FMCSA - 49 CFR Part 391 (Driver Qualifications) - The authoritative federal rule defining what must be in every DQF and how long to retain it.
- FMCSA - Large Truck and Bus Crash Facts - Statistical background on commercial motor vehicle safety supporting the driver qualification framework.
- FMCSA - Safety Measurement System (SMS) - Public scoring system that uses driver qualification data as part of carrier safety profiles.
- FMCSA - CSA BASICs Definitions - Official definitions for each Compliance, Safety, Accountability behavior category.
- FMCSA - National Registry of Certified Medical Examiners - Federal registry for medical examiners certifying CDL medical cards.
- FMCSA - Drug & Alcohol Clearinghouse - Mandatory query database for pre-employment and annual checks.
Pass your next FMCSA audit in the first hour.
ExpiryEdge pre-loads the Part 391 template, tracks every expiry independently, and exports a complete DQF on demand.
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