What is a DQ file? The driver qualification file, explained

If you’ve started hiring drivers, someone has probably told you to “keep a DQ file” for each one. Here’s what that actually means.

A driver qualification file — a “DQ file” — is the collection of documents that proves a specific driver is qualified to operate your commercial motor vehicles. It’s required by 49 CFR Part 391, and you keep one per driver. In an audit or a records request, it’s the first thing an examiner asks to see.

What goes in a DQ file

Part 391 breaks the contents into two kinds of documents: things you collect once at hire, and things you refresh on a schedule.

Collected at hire

• Employment application (391.21) — signed, covering the required work history (3 years, or 10 for CDL positions)
• Pre-employment MVR (391.23) — the motor vehicle record from each state the driver was licensed in
• Safety performance history (391.23(d)–(e)) — inquiries to prior DOT employers from the last 3 years, including the 382.413 drug & alcohol request
• Road test certificate (391.31) — or a copy of the driver’s CDL, which may be accepted in its place
• Clearinghouse pre-employment query (382.701) — a full query for CDL drivers, before their first driving duty
• English language proficiency note (391.11)

Refreshed on a schedule

• Medical examiner’s certificate (391.43) — the med card; keep the current one, and watch the expiration printed on it (up to 24 months)
• Annual MVR (391.25(a)) — a fresh motor vehicle record at least every 12 months
• Annual review of driving record (391.25(b)) — your documented yearly review of that MVR

The recurring items are where files quietly fall out of compliance. A med card that lapsed last month or an MVR that’s 14 months old is a finding waiting to happen — see the new-entrant audit checklist for how these show up in an audit.

How long do you keep it?

Keep the DQ file for the length of the driver’s employment plus three years after they leave. The inquiries and investigations you made at hire have their own retention rules, but the practical answer is: don’t throw a file away when a driver quits.

The common mistakes

• Treating the ELD as the file. Your ELD handles hours of service and often DVIRs. It does not hold DQ files, med cards, or drug & alcohol records.
• Forgetting the annual items. The hire-day documents are easy to remember; the annual MVR and annual review are the ones that slip.
• Missing the Clearinghouse query. For CDL drivers this is required before their first driving duty, and again every year.

The easy version

A DQ file is just a checklist — but it’s a checklist with expiration dates, run across every driver you employ. HaulPapers keeps that checklist per driver, tracks the dates that move, and tells you what’s missing before an auditor does.

You can check one driver’s DQ file for free, no account required.

HaulPapers is software, not a law firm, and is not affiliated with FMCSA or USDOT. This article summarizes public regulations and is not legal advice.