# Annual Driver Record Review Checklist: §391.25 in 30 Minutes

Canonical: https://www.fastdriverscreening.com/guides/annual-driver-record-review-checklist
Category: Compliance
Published: 2026-05-02
Updated: 2026-05-02
Read time: 9 min

## TL;DR

> The 49 CFR §391.25 annual review is a six-step, 30-minute-per-driver workflow: confirm the universe, pull a fresh MVR (and a §382.701(b) Clearinghouse limited query for CDL drivers), read every section, collect the §391.27 self-certification, write the signed determination, and file it under §391.51.

## Key takeaways

- §391.25(a) requires an MVR from every state where the driver held a license in the prior 12 months — state-of-residence changes are the most commonly missed case.
- For CDL drivers, the §382.701(b) limited Clearinghouse query is also annual; the $60 Annual Refresh package bundles both.
- §391.25(d) requires a signed reviewer note in the §391.51 file documenting the determination of qualification.
- §391.27 self-certification — the driver's annual list of violations — is a separate, parallel requirement and goes in the same file.
- A cohort-based schedule (everyone reviewed in the same calendar month) is easier to track for fleets under 25 drivers; anniversary-based scales better with software.

## Cited entities

- 49 CFR §391.25 (https://www.ecfr.gov/current/title-49/section-391.25)
- 49 CFR §391.27 (https://www.ecfr.gov/current/title-49/section-391.27)
- 49 CFR §391.15 (https://www.ecfr.gov/current/title-49/section-391.15)
- 49 CFR §391.51 (https://www.ecfr.gov/current/title-49/section-391.51)
- 49 CFR §382.701 (https://www.ecfr.gov/current/title-49/section-382.701)
- 49 CFR §383.51 (https://www.ecfr.gov/current/title-49/section-383.51)
- Motor Vehicle Record (MVR)
- FMCSA Drug & Alcohol Clearinghouse (https://clearinghouse.fmcsa.dot.gov)
- Federal Motor Carrier Safety Administration (https://www.fmcsa.dot.gov)

## Excerpt

The [49 CFR §391.25](https://www.ecfr.gov/current/title-49/section-391.25) annual review is the single most-skipped item in the entire [DQ file](/glossary/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 ta

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