Driver qualification files for regulated and non-regulated fleets

The driver qualification process is a key component of any modern fleet safety program regardless of the fleet size or nature of operation.  A company’s adherence to driver selection criteria has a tremendous impact on overall fleet safety.  Here we discuss several key components that comprise a successful driver screening process for both regulated and non-regulated fleets.

Best practices for all fleets

Fleet application form

Non-DOT regulated fleets should consider adding a driver addendum to their job application form that requests the following information:

  1. A copy of the most recent driver’s license
  2. Driving experience
  3. Crash record
  4. Traffic violation convictions
  5. Criminal history*
  6. Transportation related training
  7. Authorization to investigate the applicant's background

Fleet operation job analysis

Employers should establish written job requirements for drivers of company vehicles.  This will provide clarity, eliminate occupational ambiguity and further allow performance benchmarking and standard comparisons, such as those associated with a telematics system. 

Driver interview process

The driver interview is the time to answer any questions that arise during the background check screening process.  This will also allow the opportunity to determine if the applicant has the proper license class, endorsements or restrictions.

Reference checks

A check with previous employers allows for screening of the information provided by the job applicant and information on their overall character and professional ability.  The information obtained during this process should be added to the driver file.

Motor vehicle record

Both initial and ongoing driver motor vehicle records should be obtained and included in the driver file.  It is recommended that MVR’s are obtained at a minimum annually and kept within the driver qualification file for future reference.  In the event of a serious motor accident, this information will show that drivers’ history is collected.

Physical qualifications

A DOT medical card requirement allows your organization to evaluate the physical fitness of an applicant prior to hire.  This requirement can also be instituted for non-regulated fleets.  Ongoing reevaluation of employees allows for the tracking of health conditions affecting motor vehicle operations such as eye sight, hearing or other medical conditions. 

Road test

A road test will allow employers the opportunity to view the applicant while they are operating equipment similar to that required by the job.  A driver’s attitude, skill set and road rule compliance are all subject to evaluation during the test.  The test should include roads that are the same or similar to that which they will encounter if awarded the driving position.


Regulated fleet requirements

Commercial motor vehicle ― driver qualification file requirements for CDL holders

Federal Motor Carrier Regulations, Title 49 – Transportation, Part 391 list the following requirements for drivers requiring Commercial Driver’s Licenses.  Under FMCSA (Federal Motor Carrier Safety Administration) provisions, individual driver files must be kept and maintained.  At minimum, each file should contain the following:

  1. Application for employment
  2. Copy of driver’s license
  3. Copy of current medical card for CDL drivers (make a copy of the actual card that the drivers carry)
  4. Copy of current drug/alcohol test
  5. Current year MVR
  6. Certificates (copies) of any driver training
  7. Copies of road test summary
  8. Accident information specific to the driver

FMCSA link to a driver qualification file checklist is found here:



Fleet operations with no CDL drivers should consider maintaining items 1, 2, 5, 6, and 8 from the above (as applicable).  Medical card obtainment is often required even if the 26,001 GVW isn’t applicable, such as commercial combination loads in excess of 10,001lbs, or for-hire passenger transportation.

The driver qualification process is a key component of any modern fleet safety program regardless of the fleet size or nature of operation.  While additional information such as credit and criminal history may also be obtained, following these listed criteria is the cornerstone of any safety conscious fleet program. 

Additional commercial motor vehicle driver file related information may be obtained using this link: Electronic Code of Federal Regulations (eCFR)


*Consult an attorney regarding requests for a criminal history information. Criminal background requests are subject to local jurisdictions’ regulations.

This material is provided for informational purposes only and does not provide any coverage or guarantee loss prevention. The examples in this material are provided as hypothetical and for illustration purposes only. The Hanover Insurance Company and its affiliates and subsidiaries (“The Hanover”) specifically disclaim any warranty or representation that acceptance of any recommendations contained herein will make any premises, or operation safe or in compliance with any law or regulation. By providing this information to you. The Hanover does not assume (and specifically disclaims) any duty, undertaking or responsibility to you. The decision to accept or implement any recommendation(s) or advice contained in this material must be made by you.

LC 2021-433