§391.51(b) lists the required contents of every driver qualification file: the §391.21 application; pre-hire MVR from every state where the driver held a CDL in the prior 3 years; road-test certificate (§391.31) or CDL equivalent (§391.33); annual MVR (§391.25(a)); annual review note (§391.25(c)(2)); medical examiner's certificate (§391.43(g)) or CDLIS MVR with med-cert status for CDL drivers (§391.51(b)(6)(ii)); and — for non-CDL drivers hired after June 22, 2025 — the NRCME verification note per §391.23(m).
§391.27 is gone
§391.27 (annual driver violation certification) was rescinded May 9, 2022. It is not required. Templates that still include it produce DQF clutter, not compliance.
Retention
§391.51(c) requires retention while the driver is employed plus 3 years after termination. The 3-year clock starts at termination, not at file creation.
What's commonly missing
- A current medical examiner's certificate (the most common DQF gap by a wide margin)
- The §391.25(c)(2) annual review signature on the most recent MVR
- The §391.23 inquiry responses (often the responses are in but never filed against the driver)
- §391.31 road-test certificate where the driver lacks a CDL equivalent
How to prevent it
- Treat the DQF as a checklist of discrete items, each with its own retention and expiration date.
- §391.25 annual MVR + review is the cycle that breaks DQFs — schedule it.
- When a medical cert renews, file the new one — the prior one is superseded, not deleted.
How Roadworthy HQ helps
The driver's DQF tab presents the required items as present or missing with expiration dates, keeps the upload history for each item, and enforces the retention period on every document. The dashboard's audit-readiness panel reflects which drivers have complete files and which have gaps.