Be Audit-Ready Before the Auditor Arrives
FMCSA auditors check DQ files document by document. DQVisor ensures every file is complete before they walk through the door.
What FMCSA Auditors Check — Document by Document
During a compliance review, auditors will examine driver qualification files for specific documents. Here's exactly what they look for and where carriers most commonly fail.
Employment Application (391.21)
What auditors check
Complete, signed, with required employment history and disclosures
Common failure
Missing employment history, unsigned application, or gaps in dates
Motor Vehicle Record (391.23)
What auditors check
Annual MVR from each licensing state, obtained within required timeframe
Common failure
Outdated MVR, missing states, or not obtained within 30 days of hire
Annual Review of Driving Record (391.25)
What auditors check
Documented review comparing MVR to driver certification, completed annually
Common failure
No evidence of review, review performed late, or missing for some drivers
Certification of Violations (391.27)
What auditors check
Signed annual certification from each driver listing violations or certifying none
Common failure
Missing certifications, unsigned forms, or certifications not completed annually
Road Test Certificate (391.31)
What auditors check
Valid road test certificate or CDL copy as equivalent
Common failure
No road test documentation and no CDL copy to serve as equivalent
Medical Examiner's Certificate (391.43)
What auditors check
Current, valid medical certificate from a National Registry examiner
Common failure
Expired medical card, examiner not on National Registry, or missing entirely
Pre-Employment Inquiries (391.23(d))
What auditors check
Documentation of inquiries to previous employers within required timeframe
Common failure
Inquiries not sent, no documentation of attempts, or responses not filed
CDLIS MVR Verification (2026)
What auditors check
CDLIS MVR confirming medical certification status for CDL drivers
Common failure
New requirement — many carriers are not yet tracking this document
How to Prevent Audit Failures
- Run a DQ file audit on your own fleet before FMCSA does
- Set up automatic alerts for expiring documents — 60 days minimum
- Ensure every new driver has a complete file within 30 days of hire
- Keep road test certificates or CDL copies on file for every driver
- Track annual review dates separately from MVR dates — they're different requirements
- Document all pre-employment inquiry attempts, even when previous employers don't respond
- Start tracking CDLIS MVR verification now — don't wait for enforcement
The 8 Required DQ File Document Categories
How DQVisor Keeps You Audit-Ready
See all DQVisor features, learn about DOT compliance requirements, or read our complete DQ file guide.
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