The driver qualification file: what goes in it, and how to keep it current.
Safety is the last department a moving company sets up. Sales comes first because it pays the bills. Dispatch comes next because the trucks have to leave. Safety waits until an insurer asks a question or a letter arrives from the DOT.
The driver qualification file is where to start. It is one folder per driver that proves the person behind the wheel is allowed to be there. It costs almost nothing to build, and it is one of the first things an investigator asks for.
The short answer
If you only read one box
One file per driver. Five things in it before the first trip, two more within 30 days, two more every 12 months. Keep it for three years after the driver leaves. Then track the dates, because the file you built correctly in March is out of date by the following March. CDL drivers follow a slightly different list, covered below.
Who needs a driver qualification file
Anyone who drives a truck rated 10,001 pounds or more for you on interstate moves. That includes the local leg of a move that starts or ends in another state, even if your truck never crosses the state line. The weight is the federal line for a commercial motor vehicle (§390.5T). A truck and trailer count together, and the line is lower than most owners think.
A 26 foot box truck counts. It does not need a CDL, and that is where the confusion starts. No CDL does not mean no file. The file rule and the CDL rule are two different rules with two different weight limits.
- Full-time, part-time, and seasonal drivers.
- Owners who drive, even one day a month.
- Independent contractors and their drivers, when they run under your DOT number.
- A helper who moves the truck between jobs. If they drive it on the road, they are a driver.
Only do moves that start and end in your state?
Then your state’s rules apply, not the federal ones. Most states use the same list, some with a different weight limit. Check with your state before you assume you are exempt.
What goes in the file
The list is short. What catches people is that each item has its own deadline.
| Document | When | Rule |
|---|---|---|
| Application for employment, complete and signed | Before the first trip | §391.21 |
| Medical examiner’s certificate (the medical card) | Before the first trip | §391.43 |
| A note that the medical examiner was on the National Registry the day the card was issued | Before the first trip | §391.23(m) |
| Road test form and certificate, or an accepted equivalent | Before the first trip | §391.31, §391.33 |
| Copy of the license, right class for the truck | Before the first trip | Good practice. Required when a CDL stands in for the road test (§391.33(b)). |
| Driving record (MVR) from every state where the driver held a license in the last 3 years | Within 30 days of the start date | §391.23(a) |
| Safety history from previous employers, last 3 years, or a record of your attempts to get it. If the driver had no DOT-regulated employer in that time, a dated note that says so | Within 30 days of the start date | §391.23(c), (d) |
| A new driving record | Every 12 months | §391.25(a) |
| A review note: who read that record, and the date | Every 12 months | §391.25(c) |
| A new medical certificate, with a new registry note | Before the old one expires. 24 months at most. | §391.45 |
CDL drivers are the exception on three rows. Their medical proof is the driving record, not a paper card. They need no registry note. And that driving record is due before the first trip, not within 30 days. The next section has the details.
The previous employer answers are kept apart from the rest, locked, where only the people who make hiring decisions can see them. A separate section of the same folder with restricted access is enough. The driver’s signed authorization to contact those employers goes in the same place (§391.53). Get it signed with the application, because you need it before you send the first request.
What CDL drivers add
If you run tractor-trailers or any truck rated 26,001 pounds or more, those drivers need a CDL, and their file needs five more things.
| Extra for CDL drivers | Rule |
|---|---|
| The driving record from the state that issued the CDL, pulled before the first trip. It has to show the driver's medical status and the type of driving they self-certified. This record is the medical proof for a CDL driver. | §391.23(m)(2), §391.51(b)(6) |
| The application lists 10 years of commercial driving jobs, not 3. | §391.21(b)(11) |
| A negative pre-employment drug test, kept with your drug and alcohol records. | §382.301 |
| A full query of the Drug and Alcohol Clearinghouse before the first trip, with the driver's consent. | §382.701 |
| A Clearinghouse query every 12 months after that. | §382.701 |
The first row replaces two rows of the main table. A CDL driver gets no paper medical card, and the registry note stopped being required for CDL drivers after June 22, 2025. Pull a new driving record after every new medical exam. Records from any other state where the driver was licensed in the last 3 years still follow the 30 day rule.
A CDL also saves you one step. A copy of the CDL can stand in for the road test, as long as it covers the type of truck you will assign.
The file most moving companies actually have
Open a typical driver folder and you will find three things. The license, the medical card, and a driving record from the week the driver was hired. Nothing else.
License, medical card, one driving record
Collected on day one, never touched again. No application, no road test, no previous employer check, no yearly review.
The full list, with dates that are still good
Every item in the table above, a signed note for each yearly review, and a medical card that has not expired.
A gap that is easy to miss
A regular license does not replace the road test. Only a CDL does, or a road test certificate issued in the last three years. Most movers run non-CDL trucks, so most of their drivers need a road test on file: a rated form signed by the person who rode along, plus the certificate.
The second gap is contractors. Their drivers’ files tend to be the thinnest ones in the cabinet, on the theory that the contractor handles it. If the truck runs under your DOT number, the file is yours to keep, whatever the contract says. What else to collect before a contractor runs a job for you is in the owner-operator onboarding Playbook.
What changed, and why old packets are wrong
Driver packets get copied from company to company for years. Three things in the old ones no longer match the rules.
The yearly list of violations is gone
Drivers used to sign a list of their own violations every year. That rule (§391.27) was removed in 2022. The yearly driving record and your signed review note are what count now.
Drug and alcohol history moved to the Clearinghouse
For CDL drivers, you now check the federal Clearinghouse for violations at other trucking companies, instead of asking each one. You still ask previous employers about accidents, and you still ask employers outside trucking (rail, transit, aviation) about testing. The Clearinghouse check is a CDL rule. When you hire someone for a non-CDL truck, the previous employer rule (§391.23(e)) still applies, so ask any employer that had them in a DOT-tested job directly.
CDL medical cards went electronic
Since June 2025 the examiner sends a CDL driver's result to FMCSA, and it shows on the driving record. A temporary exemption that let carriers rely on a paper card ended on October 11, 2026. Only drivers licensed in Alaska still have one, until October 12, 2027. For every other CDL driver the driving record is now the proof, so pull it after each new exam and keep it in the file. Non-CDL drivers still get a paper certificate, and you keep a copy.
One folder per driver, one way to name files
Paper or cloud, the layout is the same. One folder per driver, the same six sections inside every one, and a separate place for people who have left.
Folder layout
Drivers/
Last name, First name/
1 Application/
2 License and medical card/
3 Driving records/
4 Road test/
5 Annual reviews/
6 Previous employers (locked)/
Former drivers/
Last name, First name (left 2026-03)/File names
Document - Last, First - YYYY-MM-DD Medical card - Smith, John - 2026-04-18 MVR GA - Smith, John - 2026-05-02
The date in the name is the date on the document, not the day you scanned it. Year first, so the files sort in order. A folder full of files called IMG_4471 is a folder nobody can audit, including you.
Two people, two jobs
Files go stale when one person is supposed to do everything and nobody is checking. Split it.
Collects and tests
Gets the application, the license copy, and the medical card. Runs the road test and signs the certificate. Does not put the driver on a truck until safety says the file is ready.
Verifies and tracks
Orders the driving record, contacts previous employers, checks the medical examiner on the National Registry, and enters every expiry date in the tracker (next section) the same day.
In a small company both jobs may be you. Keep them as two separate steps anyway. The second step is the one that gets skipped.
The monthly check
The file is easy to build once. Audits fail on the dates that pass after that.
The check runs on one tracker of expiry dates. Build it in Airtable, not in a spreadsheet.
| What the tracker holds | In Airtable |
|---|---|
| One row per driver | Name, employee or contractor, CDL or non-CDL, and start date. |
| The dates that expire | A date field for each one: license, medical certificate, the next yearly driving record and review, and the 30 day deadline for a new hire. For CDL drivers, the next Clearinghouse query too. |
| The next date due | A formula field that shows the earliest of those dates for each driver. |
| A view sorted by the next date due | The driver whose date comes first is at the top. This is the view you open every month. |
A spreadsheet is easy to start and hard to scale. Two people edit the same row, or a formula breaks and nobody notices. Airtable is a database that looks like a spreadsheet, and you can change the tracker when the business changes. Elselab, the studio on our AI automation for moving companies page, can build it for you.
First working day of the month
Open the tracker and sort by the next date due. It takes five minutes.
Anything due within 60 days
Tell the driver in writing. Book the medical exam or order the driving record now, not the week it expires.
Anything due within 30 days
Second notice. Dispatch is told the date the driver comes off the schedule if nothing arrives.
Anything expired
The driver does not drive. No exceptions for a busy Saturday. A driver with an expired medical card is not qualified, and your insurer will see it the same way after a crash.
When a driver leaves
Move the folder to Former drivers, write the leaving date in its name, and keep it for three more years.
Download the kit
Two files, free, no sign-up. They are blank templates built from the federal rules. Put your company name on them and use them.
- Download
Driver qualification file checklist
One sheet per driver, grouped by deadline, plus the CDL add-ons, the folder layout, and the monthly check.
PDF, 3 pages
- Download
Blank driver file forms
Nine forms: cover sheet, application, driving record authorization, previous employer request, road test, road test certificate, annual review, medical and registry check, and a corrective training record.
PDF, 11 pages
The tracker is not a file to download. It lives in Airtable, as described in the monthly check above.
Before you rely on them
These templates follow the federal rules (49 CFR Parts 382 and 391) as we checked them in November 2026. Rules change, and states add their own. This is not legal advice. If you want your files reviewed before an audit, start with our lawyers for moving companies list.
What this Playbook does not cover
The driver file is one drawer of the safety cabinet. It does not cover the drug and alcohol testing program for CDL drivers, hours of service and logs, truck files and inspections, or the accident register. Each of those is its own job, and the driver file is the one to finish first, because every other record points back to a qualified driver.
It also leaves out the documents for the customer and the shipment. Those are in the moving company paperwork Playbook.
The recap
- Every driver of a truck rated 10,001 pounds or more needs a file. A 26 foot box truck counts.
- Before the first trip: application, medical card, registry note, road test or equivalent, license copy.
- Within 30 days: 3-year driving record and previous employer check.
- CDL drivers: the driving record is the medical proof, and it is due before the first trip.
- Every 12 months: a new driving record and a signed review note.
- A regular license does not replace the road test. Only a CDL does.
- Contractors' drivers under your DOT number need the same file.
- Keep the expiry dates in one Airtable tracker, and check it on the first working day of every month.
- Keep the file for three years after the driver leaves.