FMCSA MVR Requirements: What Motor Carriers Must Pull and When

What FMCSA Requires for MVRs, in One Paragraph

If you operate commercial motor vehicles in interstate commerce, FMCSA requires you to obtain a Motor Vehicle Record (MVR) for every driver at two points: once at hire (covering every state where the driver was licensed in the past 3 years, under 49 CFR 391.23) and at least once every 12 months thereafter (under 49 CFR 391.25). The annual requirement is not just pulling the record. A designated person must review it and document that review with a dated, signed note. Both the MVR and the review note go in the driver's qualification file and must be kept for the duration of employment plus 3 years after.

That's the short answer. The rest of this guide explains each piece, the deadlines that trip carriers up, and how to keep the paperwork audit-ready.

What Is an MVR?

A Motor Vehicle Record is the official driving history a state's licensing agency keeps on a license holder. It lists license class and endorsements, expiration, and the driver's record of traffic convictions, accidents, suspensions, and disqualifications. For a motor carrier, the MVR is the primary evidence that a driver is legally licensed and does not have a driving history that disqualifies them from operating a CMV.

MVRs are state-specific. A driver who held licenses in two states over the past three years has driving history in both states' systems, which is why FMCSA's at-hire rule is built around "every state where the driver was licensed," not just the current one.

Who Has to Comply

The MVR requirements apply to motor carriers operating CMVs in interstate commerce under 49 CFR Part 391. In practice that means vehicles with a gross vehicle weight rating or gross combination weight rating of 10,001 lbs or more, vehicles designed to carry 9 or more passengers for compensation (or 16 or more not for compensation), and any vehicle hauling placarded hazardous materials. Many intrastate operations fall under state rules that mirror these federal requirements.

If you maintain driver qualification files (and if the above describes your fleet, you must), MVRs are a required part of them. For the full picture of what else belongs in a DQ file, see our complete guide to FMCSA driver qualification files.

The At-Hire Requirement: 49 CFR 391.23

Before or shortly after a driver starts, you must make an inquiry into their driving record. Under 391.23(a)(1), this means obtaining an MVR from each state where the driver held a motor vehicle operator's license or permit during the preceding 3 years.

Two details matter here:

• Timing. The inquiry must be made within 30 days of the date employment begins. Pull it late and you have a citable gap, even if the record itself is clean.
• Multiple states. A driver who moved or held a license in more than one state during the lookback period needs an MVR from each of those states, not just their current one. Missing a state is a common and avoidable error.

The at-hire MVR is a one-time document tied to the hiring investigation. It stays in the file as proof you checked the driver's history before putting them behind the wheel.

The Annual Requirement: 49 CFR 391.25

This is where most MVR violations happen, because it has two parts and carriers often complete only the first.

Part 1: Pull the record (at least every 12 months)

Under 391.25(a), at least once every 12 months you must obtain an MVR from the appropriate agency of every state where the driver held a CMV license or permit during the preceding 12 months. The 12-month clock is rolling from the date of the last inquiry, so a record pulled on March 1 needs its replacement no later than the following March 1.

Part 2: Review the record and document it

Under 391.25(b), a person designated by the carrier must review the MVR to determine whether the driver still meets minimum requirements for safe driving and is not disqualified under 391.15. The review should consider the driver's accident record and any evidence of dangerous or disqualifying driving behavior.

Then 391.25(c)(2) requires you to keep a note in the file identifying the person who performed the review and the date it was done. In practice, a complete review note records:

• The reviewer's name and the driver's name
• The date of review
• The disposition (qualified or not qualified to continue driving)
• The reviewer's signature

Pulling the MVR but never documenting the review is one of the most frequent audit findings in this area. The record alone does not prove anyone looked at it. The note does.

What happened to the annual list of violations? Drivers used to furnish a separate annual list of their traffic convictions under former 49 CFR 391.27. FMCSA's Record of Violations final rule eliminated that requirement effective May 9, 2022, reasoning that the 391.25 annual MVR review already covers the same ground. If your file template still asks drivers to self-certify their violations on a separate form, it is out of date.

How Often Should You Actually Pull MVRs?

Annual is the federal floor, not a best practice ceiling. Many carriers pull MVRs quarterly, and some enroll drivers in state or third-party license monitoring programs that push alerts when a new conviction or suspension hits a driver's record. The reason is simple: a driver can pick up a serious violation or a license suspension the day after their annual review, and you would not know until the next pull twelve months later. The more safety-sensitive your operation, the more a tighter cadence pays for itself.

Whatever cadence you choose, the recordkeeping obligation is the same: keep the records and document the reviews.

What Disqualifies a Driver

The review under 391.25 exists to catch disqualifying history. The disqualification standards live in 49 CFR 391.15 and include major offenses such as driving a CMV with a suspended or revoked license, leaving the scene of an accident, using a CMV to commit a felony, and driving under the influence. A driver whose MVR shows a disqualifying offense should be removed from safety-sensitive functions until the matter is resolved. The point of the annual review is to surface these before an auditor (or worse, a crash investigation) does.

Retention: How Long to Keep MVRs

MVRs and the associated review notes are part of the driver qualification file and follow the file's retention rules: keep them for the entire duration of the driver's employment, then for 3 years after the driver leaves.

Document	Retention
At-hire MVR (391.23 inquiry)	Duration of employment + 3 years
Annual MVR (391.25 inquiry)	Duration of employment + 3 years
Annual review note (391.25(c)(2))	Duration of employment + 3 years

Many carriers retain DQ records longer than the federal minimum (often 7 years after termination) to cover state statutes of limitations for negligent-hiring claims and insurance requirements. Digital storage costs almost nothing compared to the risk of not having a record when you need it.

The MVR Violations That Get Carriers Cited

The pattern with MVR findings is almost always missing paperwork or a missed deadline, not an unqualified driver. The most common:

1. No at-hire MVR for one or more states the driver was licensed in (391.23).
2. At-hire MVR pulled after the 30-day window (391.23).
3. No annual MVR within the rolling 12-month period (391.25(a)).
4. MVR pulled but no documented review note (391.25(c)(2)).
5. Review note missing the reviewer's name, signature, or date.

Every one of these is a tracking problem, not a judgment problem. The driver was usually fine. The carrier just couldn't prove the check happened on time.

What Non-Compliance Costs

FMCSA recordkeeping and qualification violations carry real civil penalties. For most Part 382/390-399 violations, penalties run up to $19,246 per violation, and recordkeeping deficiencies can run up to $1,584 per day (capped at $15,846). All amounts are adjusted annually for inflation under 49 CFR Part 386, Appendix B. Beyond the dollars, a pattern of qualification-file gaps feeds into your safety rating and, if an unqualified driver is ever in a serious crash, an incomplete file becomes a centerpiece of civil litigation.

Make the Deadline Surface Before It Passes

The honest truth about MVR compliance is that the requirements are not hard to understand. They are hard to remember, driver by driver, across a rolling 12-month cycle, when nobody owns the calendar. That's exactly the failure mode that turns a fleet of qualified drivers into a stack of citations.

This is where a system beats memory. Core Compliance stores each driver's MVR and annual review as dated documents on their file and surfaces the rolling 12-month anniversary on your dashboard well before it lapses, with a weekly digest every Monday and escalating alerts at 10, 5, and 1 day out. Instead of hoping someone notices an MVR is due, the deadline finds you.

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