# DOT Driver Road Test Requirements: What Motor Carriers Must Keep in the DQ File Canonical page: https://fleetregulators.com/blog/dot-driver-road-test-requirements Author: Rhythm Gandhi | Published: 2026-08-08 The road test requirement trips up carriers more than it should. Not because the test is complicated, but because most carriers do not know when a CDL acts as an equivalent, what the certificate must say, or what happens when the document is missing during an audit. --- Under [49 CFR 391.31](https://www.ecfr.gov/current/title-49/subtitle-B/chapter-III/subchapter-B/part-391/subpart-C/section-391.31), motor carriers must administer a road test to each driver they employ to operate a commercial motor vehicle. Under [49 CFR 391.33](https://www.ecfr.gov/current/title-49/subtitle-B/chapter-III/subchapter-B/part-391/subpart-C/section-391.33), a valid CDL that required the driver to pass a driving skills test that is equivalent to or more rigorous than the Part 391 road test may satisfy the requirement. The carrier examines the CDL and retains a copy. The certificate of driver's road test, or documentation of the CDL equivalent, belongs in the driver qualification file. Verify current requirements and applicable conditions against 49 CFR Part 391 Subpart C. Here is where I see this requirement go wrong. Small fleets hire a driver with a CDL and assume that handles it. They are often right, but they cannot explain why or show the documentation that proves it. Or they hire a non-CDL driver for a vehicle that requires a road test, and nobody administers one. Both situations create a gap in the DQ file that becomes a violation during a DOT audit. Who This Applies To - Motor carriers employing drivers to operate commercial motor vehicles subject to Part 391. - Carriers hiring CDL drivers who need to know whether the CDL satisfies the road test requirement and how to document it. - Carriers hiring non-CDL CMV drivers who need to actually administer and document the road test. - New authorities building DQ files for the first time. ## When the road test requirement applies Under 49 CFR 391.31, before a motor carrier allows a driver to operate a commercial motor vehicle, the carrier must administer a road test to that driver. The road test must be conducted in the type of CMV the driver will operate, or one representative of it. This applies generally to drivers subject to Part 391. Exemptions and special cases exist. Verify the current rule against 49 CFR Part 391 and FMCSA guidance before making applicability determinations for specific driver populations or operations. ## When a CDL may satisfy the road test requirement Under 49 CFR 391.33, a driver who holds a valid CDL issued by a U.S. state that required the driver to take and pass a driving skills test that is equivalent to or more rigorous than the road test required by 391.31 may satisfy the road test requirement through that license. The carrier's responsibility when relying on this provision: - Examine the CDL. It must be valid. - Determine that the CDL class and endorsements cover the type of vehicle the driver will operate. - Retain a copy of the CDL in the driver qualification file as the documentation of the road test equivalent. - Verify current conditions under 49 CFR 391.33 before relying on this equivalency for any specific driver or operation. ## The road test decision framework | Driver situation | Road test required? | Accepted equivalent | What carrier retains in DQ file | | --- | --- | --- | --- | | CDL holder, license class covers the vehicle type | Not required if CDL skills test was equivalent or more rigorous | Valid CDL, under 49 CFR 391.33 | Copy of valid CDL; notation of equivalency basis | | Non-CDL driver operating a vehicle requiring road test | Yes -- road test must be administered | None for non-CDL drivers; road test must be completed | Certificate of driver's road test (49 CFR 391.35) | | Driver upgrading to larger/different vehicle type not covered by prior test | Verify against applicable rules | May need new road test for new vehicle type | New certificate or updated documentation | | CDL but license class does not cover the vehicle type to be operated | Verify against applicable rules | Equivalency only applies when CDL covers the operation | Road test certificate for the applicable vehicle type | Always verify the current rule and any applicable conditions against 49 CFR Part 391. Specific operational situations may have different requirements. ## What the road test covers Under 49 CFR 391.31, the road test must enable the person administering it to evaluate the driver's ability to operate the vehicle safely. The test should include elements relevant to the type of vehicle and operation. Common elements include: - Pre-trip vehicle inspection procedures. - Coupling and uncoupling of trailer, if the vehicle has a trailer. - Placing the vehicle in operation and use of controls. - Use of lights and safety equipment. - Operating the vehicle in traffic, including intersections, railroad crossings, curves, and grades. - Backing and turning the vehicle. - Entering and exiting highway traffic. - Braking and stopping. Verify current required test elements against 49 CFR 391.31 and FMCSA guidance. The test must be conducted in a vehicle representative of the type the driver will operate. ## Who can administer the road test Under 49 CFR 391.31, the road test must be administered by a person who is qualified to evaluate the driver's ability to operate the type of vehicle used for the test. FMCSA does not prescribe a specific credential for road test examiners, but the examiner must be qualified for the type of vehicle involved. Verify current requirements against 49 CFR 391.31 and FMCSA guidance. The carrier should document who administered the test on the certificate. ## What the certificate of driver's road test must contain Under [49 CFR 391.35](https://www.ecfr.gov/current/title-49/subtitle-B/chapter-III/subchapter-B/part-391/subpart-C/section-391.35), the certificate of driver's road test must contain: - The name of the motor carrier. - The driver's name and signature. - The date of the test. - The name of the person who administered the test and their signature. - A description of the type of commercial motor vehicle used for the test (or the general geographic area of the route). - The examiner's statement that the driver successfully completed the road test. Verify the current required certificate contents against 49 CFR 391.35. The certificate belongs in the driver qualification file. ## Common audit mistakes - Assuming all CDL holders are automatically covered without examining whether the CDL class covers the vehicle type the driver will operate. - Relying on the CDL equivalency but retaining no copy of the CDL in the DQ file. - Administering a road test but losing or never creating the certificate. An undocumented test did not happen for audit purposes. - Using a generic certificate form that is missing required information (examiner name, vehicle description, date). - Hiring a non-CDL driver for a vehicle that requires a road test and never completing one before the driver goes to work. - Missing road test certificates in inherited or purchased driver files when acquiring a fleet. ## What to document in the DQ file The DQ file must contain one of the following for each applicable driver: **Option A (road test administered):** The signed and completed Certificate of Driver's Road Test under 49 CFR 391.35. **Option B (CDL equivalent):** A copy of the driver's valid CDL, with documentation showing the carrier examined it and it covers the vehicle type the driver will operate. Keep this copy current -- if the license expires or the driver obtains a new license, update the file. Use the free [Driver Qualification File Checklist](https://fleetregulators.com/#guide) to verify that the road test certificate (or documented CDL equivalent) is present along with the other required DQ documents for each active driver file. The Safety Gal's Take The road test gap I find most often is not missing road tests. It is carriers who hired CDL drivers, relied on the CDL equivalency correctly, but never copied the license into the file. So when I pull the DQ file there is nothing documenting how they satisfied the road test requirement. The rule does not just say "CDL is fine." It says the carrier must examine the license and retain a copy. That copy is your documentation. If it is not in the file, you have no way to show compliance. ### Need Help Auditing Your Driver Files? Book a free compliance review. We will check your DQ files for missing road test documentation, expired documents, and other gaps before an auditor finds them. [Book a Free Compliance Review →](https://fleetregulators.com/contact) Related Service ### Driver Qualification File Management We audit DQ files for missing road test documentation, expired documents, and the gaps that audit findings are made of. We build and maintain files so you are not scrambling the week before an audit. [Get DQ File Support →](https://fleetregulators.com/driver-qualification-files) ## Frequently Asked Questions **When is a DOT road test required for a commercial driver?** Under 49 CFR 391.31, motor carriers must administer a road test to each driver they employ unless the driver holds a valid CDL that required passing a driving skills test equivalent to or more rigorous than the Part 391 road test. The carrier must examine the CDL and retain a copy in the driver qualification file. Verify specific applicability against 49 CFR 391.31 and 391.33. **What is an acceptable equivalent to the DOT road test?** Under 49 CFR 391.33, a driver who holds a valid CDL that required passing a driving skills test that is equivalent to or more rigorous than the Part 391 road test may satisfy the requirement through that CDL. The carrier examines the CDL and retains a copy in the DQ file. Verify the current rule and conditions against 49 CFR 391.33. **What must the certificate of driver's road test contain?** Under 49 CFR 391.35, the certificate must identify the driver, the motor carrier, the type of commercial motor vehicle used for the test, the date, the name and signature of the person who administered the test, and the examiner's determination. Verify current required content against 49 CFR 391.35. **Where does the road test certificate go?** The certificate of driver's road test belongs in the driver qualification file. Under 49 CFR 391.51, DQ files must be retained for the duration of employment plus three years. During a DOT audit, the auditor will look for either the certificate or documentation of an accepted equivalent such as a copy of the CDL. **What happens if the road test certificate is missing from the DQ file?** A missing certificate or missing CDL copy is a citable violation during a DOT audit. Carriers cannot retroactively fix the period the driver operated without documentation. Audit existing files for this document, resolve what gaps you can with available documentation, and establish a consistent process for every new hire going forward. Sources & Regulatory References - [49 CFR 391.31 - Road Test ↗](https://www.ecfr.gov/current/title-49/subtitle-B/chapter-III/subchapter-B/part-391/subpart-C/section-391.31) - [49 CFR 391.33 - Equivalent of Road Test ↗](https://www.ecfr.gov/current/title-49/subtitle-B/chapter-III/subchapter-B/part-391/subpart-C/section-391.33) - [49 CFR 391.35 - Certificate of Driver's Road Test ↗](https://www.ecfr.gov/current/title-49/subtitle-B/chapter-III/subchapter-B/part-391/subpart-C/section-391.35) - [49 CFR Part 391 - Qualifications of Drivers ↗](https://www.ecfr.gov/current/title-49/subtitle-B/chapter-III/subchapter-B/part-391) - [FMCSA - Driver Qualification Files Guidance ↗](https://www.fmcsa.dot.gov/regulations/title49/part/391)