Annual Driver Record Review Checklist: §391.25 in 30 Minutes

The 49 CFR §391.25 annual review is the single most-skipped item in the entire DQ file. Carriers will run a clean pre-employment package, file every document in §391.51 order, and then quietly miss the twelve-month review on the same driver eleven months later because no one took ownership of the calendar. The annual review is not optional and it is not a paperwork formality — it is a documented federal determination, signed and dated, that the driver remains qualified to operate a commercial motor vehicle for another year. Done well, it takes about thirty minutes per driver and produces a clean file that audits cleanly. Done poorly, or skipped entirely, it produces a §391.25 violation on every audit report for the next eighteen months.

This guide is a time-boxed checklist for getting through the annual review at the pace of a real fleet operator: pull, read, classify, document, file. Use it as a printable for the dispatcher who actually runs the review.

The federal requirement, in three sentences

49 CFR §391.25(a) — At least once every 12 months, the motor carrier shall make an inquiry to obtain the motor vehicle record of each driver it employs, covering at least the preceding 12 months, to the appropriate agency of every State in which the driver held a commercial motor vehicle operator's license or permit during the time period.

49 CFR §391.25(b) — At least once every 12 months, the motor carrier shall review the motor vehicle record of each driver it employs to determine whether that driver meets minimum requirements for safe driving or is disqualified to drive a commercial motor vehicle.

49 CFR §391.25(d) — A note, including the name of the person who performed the review of the driving record required by paragraph (b) of this section, shall be retained in the driver's qualification file.

The three sentences map onto three actions: pull, review, document. Each action takes about ten minutes; the whole annual review takes thirty.

Step 1: Confirm the universe of drivers due for review (5 minutes, monthly)

The first step is not per-driver — it is per-month. At the start of every month, pull the list of drivers whose last §391.25 review was completed eleven or more months ago. This list is the queue for the month.

The two cleanest patterns:

• Cohort-based — every driver gets reviewed in the same calendar month each year (e.g., all reviews happen in January). Easy to track, easy to budget, easy to verify in an audit.
• Anniversary-based — each driver is reviewed in the month their pre-employment screen was completed. More accurate to "twelve months from prior MVR" but harder to track without software.

Either pattern satisfies the §391.25 "at least once every 12 months" rule. The cohort pattern is easier for carriers under twenty-five drivers; the anniversary pattern works better at scale with a tracking system. The important thing is that no driver's review goes past twelve months.

Step 2: Pull the new MVR (5 minutes per driver)

For each driver due for review:

• Identify every state where the driver currently holds a license OR held one during the prior twelve months (state-of-residence changes are the most commonly missed case)
• Order an MVR from each state through your screening provider
• For CDL drivers, order the §382.701(b) Clearinghouse annual limited query
• Wait for results (FastDriverScreening delivers most MVRs same-day; some states take up to one business day)

The Annual Refresh package at $60 bundles the MVR with the Clearinghouse limited query, which is the cleanest single order for a CDL annual review.

Step 3: Read the new MVR carefully (10 minutes per driver)

The §391.25(b) review is more than a glance. Read each section in order:

Identification

Verify the name, date of birth, license number, and state of issue match the driver record on file. Address mismatches are not by themselves a §391.25 issue, but they suggest the driver has moved and may have other states of license under §391.25(a).

Current license status

The single most important field. The status code must be VALID/ELIGIBLE for the driver to remain qualified. A SUSPENDED, REVOKED, CANCELLED, DISQUALIFIED, or EXPIRED status is an automatic §391.15 disqualification — write the file note immediately and remove the driver from CMV operation.

Class and endorsements

Verify the driver still holds the class and endorsements required for the position. A driver who lost a HazMat endorsement during the year cannot continue hauling placardable HazMat on the existing endorsement record.

Medical certification

Verify the medical card on the MVR matches the §391.43 medical examiner's certificate in the DQ file. An expired medical card is a §391.41 disqualification — even if every other section reads clean.

Convictions during the year

Read every conviction line. For each one, do the §383.51 classification analysis (major / serious / grade-crossing / non-disqualifying — see our companion guide on the MVR violations decision tree). Flag any conviction that is currently disqualifying or that, combined with prior convictions, triggers a §383.51(c) two-strikes rule.

Accidents during the year

Read every accident line. PSP gives the carrier-perspective view (crashes the driver was the named driver in); the MVR gives the state-DMV view (crashes the state DMV recorded). The two should be largely the same, but discrepancies are worth investigating.

Administrative actions

Read every administrative action — financial responsibility suspensions, child-support enforcement holds, failure-to-appear suspensions. These do not always show up as a "current status" but are still material to the §391.25 review.

Step 4: Collect the §391.27 driver self-certification (5 minutes per driver)

Separately from the MVR review, every driver must furnish to the carrier — once per year — a list of all violations of motor vehicle laws (other than parking) for the prior twelve months, even if they were not cited or convicted.

49 CFR §391.27(a) — Each motor carrier shall, at least once every 12 months, require each driver it employs to prepare and furnish it with a list of all violations of motor vehicle traffic laws and ordinances (other than violations involving only parking) of which the driver has been convicted or on account of which he/she has forfeited bond or collateral during the preceding 12 months.

49 CFR §391.27(b) — If a driver has not been convicted of, or forfeited bond or collateral on account of, any violation which must be listed pursuant to paragraph (a) of this section, the driver shall so certify.

The driver fills out the §391.27 form, signs and dates it. The carrier compares the driver's list against the new MVR — discrepancies (driver did not list a conviction that appears on the MVR) are themselves a §391.21 disclosure issue worth investigating.

Step 5: Write the annual review note (5 minutes per driver)

The §391.25(d) note is the document the auditor reads to verify the review was done correctly. It should include:

• Driver name and CDL number
• Reviewer name (typically the safety director, dispatcher, or compliance officer)
• Review date
• The list of MVRs pulled (state and date of each)
• The Clearinghouse limited query result and date (CDL drivers)
• The §391.27 self-certification date
• A summary of any convictions in the prior twelve months and the §383.51 classification of each
• The reviewer's specific finding: either "the driver continues to be qualified to operate a CMV under 49 CFR Part 391" or "the driver is disqualified under §[specific cite] until [date]"
• The reviewer's signature and date

Keep the note brief but complete. A signed, dated paragraph is the difference between a clean audit finding and a §391.25 violation.

Step 6: File the documents (2 minutes per driver)

Add the following to the driver's §391.51 file, in the §391.51 order:

• The new MVR(s) — file under §391.51(b)(2)
• The §391.27 self-certification — file under §391.51(b)(7)
• The §391.25 review note — file under §391.51(b)(7) along with the prior reviews

If any document is missing or stale, fix it before closing the file. A signed review with no underlying MVR is a worse audit finding than no review at all — it suggests the carrier is producing the paperwork without doing the work.

Edge cases that come up at scale

• A driver was on medical leave for part of the year — review the partial-year MVR; document the leave dates in the file note.
• A driver changed states mid-year — pull MVRs from both states and document the change in the file note.
• A driver had a CDL change (e.g., upgraded from B to A) during the year — verify the new class on the MVR matches the §391.43 medical card and the position requirements.
• A driver's license expired during the year — verify the renewal happened before the expiration and document the renewal date in the file note.

What an auditor will check

When the FMCSA auditor opens the §391.51 file for a long-tenured driver, the §391.25 audit trail is one of the easiest places to find violations. The auditor will look for:

• A new MVR pulled within the prior twelve months (date on the report header)
• An MVR from every state the driver held a license in during the year
• A signed §391.27 driver self-certification within the prior twelve months
• A signed §391.25 review note within the prior twelve months
• A Clearinghouse limited query within the prior twelve months for CDL drivers (§382.701(b))
• Coherent dates across the documents (review dated after the MVR, not before; review dated before the next pre-employment cycle if the driver changed states)

A clean file produces a "no §391.25 violations" finding on the audit report. An incomplete one produces a violation per missing document, per driver, per year.

How FastDriverScreening fits

The Annual Refresh package at $60 packages the MVR with the §382.701(b) Clearinghouse limited query as a single click. Order on the first business day of the cohort month, receive the results that day, run the §391.25 review, file the documents — and the year's compliance is done. For non-CDL commercial drivers (where the Clearinghouse rule does not apply), the MVR Basic package at $40 covers the §391.25 inquiry side of the requirement.