The motor vehicle record is in the folder. Who reviewed it, and when?
If your driver-file process ends when an MVR download arrives, it is missing a separate part of the annual task. For drivers subject to 49 CFR 391.25, the carrier must obtain the record and review it. The qualification file needs evidence of both.
This is a current-rules refresher, checked October 19, 2026, rather than an announcement of a new October deadline. Confirm that Part 391 applies to your operation and check its Subpart G exceptions before applying a general checklist to a particular driver.
The annual task has two parts
Section 391.25 requires an inquiry at least once every 12 months to each licensing authority where the driver held a commercial motor vehicle operator's license or permit during that period. The record must cover at least the preceding 12 months.
The carrier must also review the driver's record at least once every 12 months to assess minimum safe-driving qualifications or disqualification. The rule requires consideration of the driver's accident record and relevant violations, with particular weight given to conduct indicating disregard for public safety.
Keep the MVR in the qualification file. Also keep a review note identifying the reviewer and the date of review. A download receipt alone does not identify a person who performed that safety review.
One old form went away. The review did not.
FMCSA's Record of Violations final rule, effective May 9, 2022, removed the separate federal requirement for drivers to supply an annual list of traffic convictions under former section 391.27. The agency described that paperwork as duplicative of the MVR inquiry.
That change did not abolish the carrier's annual MVR inquiry or review under section 391.25. If an old packet combines a driver-supplied violations list with the carrier's review, separate the obsolete federal form requirement from the review obligation that remains. A company may have additional internal reporting policies; label those as company policy rather than an unchanged federal annual-list mandate.
Review the information, not just the presence of a PDF
FMCSA's published guidance says carriers should consider reasonably available information about driving experience, including known violations outside the licensing authority's record. The agency expressly labels this guidance explanatory and nonbinding; the regulation supplies the legal requirements.
A practical process should therefore bring relevant information to the reviewer rather than treating a clear-looking MVR as an automatic approval. Document the review actually performed. Do not backdate a missing review note or create a conclusion that the available record does not support.
Check retention before replacing last year's record
Section 391.51 lists the annual MVR and review note among qualification-file records. It generally requires retaining a driver's file throughout employment and for three years afterward, while allowing specified records, including annual MVRs and review notes, to be removed three years after execution.
That exception is not permission to delete last year's MVR every time a new one arrives. Keep your retention procedure tied to the correct document category and date.
A useful office check this week
Recommended practice: choose one active driver file and trace the last inquiry, the record obtained, the completed review and the next due date. Then check the rest of the roster using the same sequence. Assign someone to follow missing records through to completion. An internal reminder date is an office control, not a new federal deadline.
Keep this task separate from the Clearinghouse annual query. Completing one does not document the other.
For help organizing driver files or an upcoming review, see DOT Consulting Solutions' services, call (910) 915-8804 or email info@dotconsultingsolutions.com.
The useful question is not simply whether a record exists. It is whether the file shows the required work was done.
Photograph: Inside the weigh station, Oregon Department of Transportation, July 30, 2019; CC BY 2.0. Resized and converted to WebP. Archival industry context, not a DOTCS client visit or an annual MVR review.
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