📖 Table of Contents
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What a DQ file is
It is a folder — paper or digital — for each driver the motor carrier uses. 391.51(a) says you maintain one for each driver you employ. You may combine it with a personnel file.
After authority, this sits next to insurance, UCR, and — if you run a CDL truck — a testing program. See the post-authority checklist and the August 2026 Motus update if the registration side is still messy.
What 391.51 actually requires
The regulation is a short list. Vendor checklists are not. If it is not in 391.51(b), it is either a different file or extra paper.
In the DQ file
391.51(b) list
- Signed employment application (391.21)
- Hiring MVR from each licensing authority (391.23(a)(1))
- Road-test certificate, or a CDL copy you accepted instead (391.31 / 391.33)
- Annual MVR (391.25(a)) — after year one
- Annual review note: who looked, and when (391.25(c)(2))
- Medical proof (see 2026 rules below)
- SPE certificate or medical exemption, if the driver has one
- National Registry verification note — required for non-CDL; CDL note ended June 22, 2025
Often stuffed in
Not 391.51
- Drug tests, random-pool proof, Clearinghouse queries — Part 382
- Previous-employer safety performance history — 391.53 investigation history file
- Annual “list of violations” — 391.27 was removed May 9, 2022
- ELDT certificates, insurance cards, training packets
Before you haul vs later
Some items block the first trip. Some have a 30-day clock. The annual MVR is later.
Before the first load
Do not drive without these
- Application on file — 391.21(a)
- Medical proof in the file — 391.23(m)
- Road test or accepted CDL equivalent — 391.31, 391.33
- CDL drivers: Clearinghouse full query first — that is Part 382, not the DQ file. See drug & alcohol setup.
30 days / later
Clock starts at hire
- Hiring MVR into the DQ file within 30 days — 391.23(b). The inquiry itself is also a 30-day item (391.23(a)(1)).
- Previous-employer safety performance history: replies, or a good-faith note, in the investigation history file within 30 days — 391.23(c)(1).
- No prior DOT employers in the last three years? Write that down within 30 days — 391.23(c)(4).
- Annual MVR + review note — at least once every 12 months — 391.25. Not a day-one item.
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Medical proof in 2026
After the National Registry II (NRII) compliance date of June 23, 2025, CDL and CLP medical status lives on the CDLIS motor vehicle record. Non-CDL drivers still use paper.
CDL / CLP
Official proof: CDLIS MVR
Put the CDLIS MVR from the current licensing State in the DQ file. That is the standing 391.51(b)(6)(ii) rule after NRII.
Non-CDL
Still the paper MEC
Keep the medical examiner's certificate, or a legible copy, plus a note that the examiner was on the National Registry on the issue date (391.51(b)(6)(i) and (b)(8)(i)). NRII did not move non-CDL drivers to CDLIS.
Not the DQ file
Drug and alcohol records are a Part 382 file: tests, refusals, policy receipts, consortium agreements, Clearinghouse queries. Keep them secure and separate. The testing guide covers the program itself.
Previous-employer safety performance history — accidents and, for older DOT jobs, drug/alcohol history — goes in the 391.53 investigation history file. Controlled access. Hiring use only. As of January 6, 2023, FMCSA-regulated prior employers are checked through the Clearinghouse (391.23(e)(4)), not a faxed drug-history form.
What an audit actually looks at
A missing folder is not listed as “the” new-entrant fail item. 49 CFR 385.321 automatic fails that touch drivers include using a physically unqualified driver (391.11(b)(4)), using a disqualified driver, and — for CDL operations — having no drug and alcohol program.
In practice, expired or missing medical proof is how “physically unqualified” shows up. Missing previous-employer notes and a missing annual-review name/date are common records gaps. They are not the same as that automatic-fail list.
How long to keep it
391.51(c): keep the file for the whole time the driver works for you, then three years after.
391.51(d) lets you pull these after three years from the date they were made: the annual MVR, the annual review note, the medical certificate or CDLIS MVR, any medical variance, and the National Registry note. The rest of the file still rides until employment plus three years.
Punch list
Print this in your head. Check it before the first load, then once a year.
CDL truck
CDLIS MVR in the file. Paper MCSA-5876 only if you are inside the April 11–October 11, 2026 exemption and the certificate is less than 60 days old.
Non-CDL CMV
Copy of the MEC plus a National Registry verification note. Same application, MVR, and road-test rules.
No prior trucking job
You still need the application and MVR. For safety history, document that no DOT-employer investigation was possible (391.23(c)(4)).
Someone leases onto you
You keep their DQ file. Their own MC number does not move that job off your desk.
FAQ
Do I need a file if I am the only driver?
Yes. 391.51 applies to each driver the motor carrier employs. FMCSA's Safety Planner includes owner-operators. One truck is still a motor carrier with a driver.
Where do I keep it?
Principal place of business, a regional office, or a driver work-reporting location (390.29). Combined with a personnel file is allowed. If it is not at the principal place of business, produce it within 48 hours (weekends and federal holidays do not count). Phone photos in a labeled folder count if you can print or show them.
Is a CDL enough instead of a road test?
A motor carrier may accept a valid CDL for the vehicle class as the equivalent of a road test (391.33). Keep a copy in the file. The carrier can still require a road test. If you are the motor carrier and you skip the CDL equivalent, someone else gives the test. You cannot test yourself (391.31(b)).
What about leased-on drivers?
The carrier that uses the driver keeps the file. Lease onto another authority, and that carrier keeps yours. Take a driver onto yours, and you keep theirs. FMCSA's 390.5T guidance says you cannot transfer FMCSR responsibility to an owner-operator just because they also hold authority.
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