# Annual MVR Review Requirements for Motor Carriers

Canonical page: https://fleetregulators.com/blog/annual-mvr-review-requirements

Published: 2026-09-19

The annual motor vehicle record review is a recurring driver-qualification requirement, not a one-time hiring task. Here is what to pull, what to document, and what to do when the record raises a question.

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Under [49 CFR 391.25](https://www.ecfr.gov/current/title-49/subtitle-B/chapter-III/subchapter-B/part-391/subpart-B/section-391.25), a motor carrier must inquire into each covered driver's driving record at least once every 12 months and review the record to determine whether the driver continues to meet applicable requirements. The carrier should retain the MVR, the review date, and the required certification in the driver's qualification file. Annual review does not replace the pre-employment investigation.

An annual MVR review is easy to miss because the driver may have been with the company for years. The deadline still recurs. A complete DQ file needs evidence that the carrier made the inquiry, reviewed the result, and documented the qualification decision.

## What the annual MVR review requires

Section 391.25 establishes a recurring inquiry and review of the driver's record. The carrier's process should identify the driver, request the record from the appropriate State agency, review the information, and complete the required certification. Use the current regulation for the exact applicability and record language for your operation.

- Track the anniversary of the prior inquiry or review so the next review is completed within 12 months.

- Request the record from the appropriate licensing State or States.

- Review the record for information that affects the driver's qualification or requires follow-up.

- Keep the MVR and the review certification with the driver's qualification records.

## Annual MVR review versus the pre-employment check

| Stage | Purpose | What the file should show |
| --- | --- | --- |
| Before hire | Investigate the applicant before allowing covered operation | Pre-employment MVR and the other applicable Part 391 records |
| Every 12 months | Confirm the carrier is still reviewing the driver's record | Annual inquiry, review, and qualification certification |
| After a concern | Resolve a new issue or qualification question | The record, follow-up, and any documented decision or action |

The annual review is not a promise that a driver has a clean record. It is a documented carrier review. A record that raises a question should be evaluated against the applicable qualification rules and the facts of the operation rather than treated as an automatic disqualification.

Keep recurring driver records on schedule

### Need help maintaining DQ files?

Fleet Regulators can audit driver files, track annual reviews and expirations, and flag missing records before a DOT review.

[Explore DQ file support →](https://fleetregulators.com/driver-qualification-files)

## Common annual MVR process failures

- Pulling an MVR at hire but never scheduling the next review.

- Keeping the MVR without a signed or otherwise required review certification.

- Using a calendar reminder without an owner responsible for completing the review.

- Failing to document follow-up when the record contains a new issue.

- Storing the annual review outside the DQ file so an auditor cannot retrieve it quickly.

## How to make the process audit-ready

1. Assign one owner for the annual review queue.

2. Use a driver roster with the last completed review date and next due date.

3. Save the MVR and certification using a consistent file name and location.

4. Escalate records that need a qualification decision instead of marking every review complete.

5. Sample completed files each month to confirm the process is working.

For the broader document list, compare this process with the [driver qualification file checklist](https://fleetregulators.com/blog/driver-qualification-file-checklist). If a review reveals missing or stale records, the [incomplete DQ file audit guide](https://fleetregulators.com/blog/incomplete-driver-qualification-file-audit) explains how to triage the gap.

## Frequently Asked Questions

**How often must a motor carrier review a driver's MVR?**

At least once every 12 months under 49 CFR 391.25, subject to the applicable rule and exceptions. The carrier must inquire into and review the driver's record and document the result.

**What must the carrier document after an annual MVR review?**

Keep the MVR, the inquiry or review date, and the required certification or review record in the driver's qualification file. Check current 49 CFR 391.25 and 391.51 requirements for your operation.

**Does an annual MVR review replace the pre-employment MVR?**

No. The annual review is an ongoing requirement after hire and does not replace the pre-employment investigation.

### Make your driver files audit-ready

Get a practical review of missing, expired, and recurring DQ-file requirements.

[Get DQ File Support →](https://fleetregulators.com/driver-qualification-files)

Sources & Regulatory References

- [49 CFR 391.25 - Annual inquiry and review of driving record ↗](https://www.ecfr.gov/current/title-49/subtitle-B/chapter-III/subchapter-B/part-391/subpart-B/section-391.25)

- [49 CFR 391.51 - DQ files ↗](https://www.ecfr.gov/current/title-49/subtitle-B/chapter-III/subchapter-B/part-391/subpart-B/section-391.51)

- [FMCSA - Part 391 driver qualification rules ↗](https://www.fmcsa.dot.gov/regulations/title49/part/391)