Annual MVR Review Requirement: 49 CFR §391.25 Compliance Guide for Fleet Managers

A driver qualification file that's missing an annual motor vehicle record (MVR) is one of the easiest violations for an auditor to find. Every motor carrier must pull and review an MVR for each CDL driver at least once every 12 months according to regulation 49 CFR §391.25.

What §391.25 Requires

The regulation is specific:

1. Obtain an MVR from every state in which the driver held a license or permit during the preceding year
2. Review the MVR for any violations, accidents, license suspensions, or revocations
3. Have a designated carrier official sign the review, confirming the MVR was examined and the driver remains qualified
4. Place the MVR and signed review in the driver's DQF within the 12-month window

"Annual" means within 12 months of the previous review, not by calendar year end. If a driver's last MVR review was dated March 15, 2026, the next one must be completed by March 14, 2027.

The Review Process

Step 1: Pull the MVR

Request the driver's motor vehicle record from the state DMV or through an authorized MVR provider. For drivers who held licenses in multiple states during the year, you need to pull an MVR from each state.

The MVR must be the official state record, not a self-reported driving history from the driver. Driver-provided records aren't acceptable substitutes.

Step 2: Review for Disqualifying Offenses

Check the MVR against the disqualifying offenses listed in 49 CFR §391.15 and §383.51.

Major Disqualifying Offenses

A driver is disqualified from operating a CMV if the MVR shows any of the following:

Serious Traffic Violations

Multiple serious violations trigger escalating disqualification:

Serious violations include: excessive speeding (15+ mph over), reckless driving, improper or erratic lane changes, following too closely, traffic offense committed in connection with a fatal accident, driving a CMV without a CDL, and driving without a CDL in possession.

Railroad-Highway Grade Crossing Violations (§383.51)

Step 3: Evaluate Non-Disqualifying Violations

Not every violation on an MVR is disqualifying. But patterns matter. The reviewing official should note:

• Moving violations: speeding, failure to obey traffic signals, improper turns
• Accidents: Any reportable crashes, regardless of fault.
• License restrictions or conditions like corrective lenses, daylight-only, etc.
• Out-of-service orders: any prior OOS orders in the review period

These don't automatically disqualify a driver, but they inform your risk assessment and may trigger additional monitoring or retraining. And a string of moving violations, which wouldn't individually disqualify someone, can still tell you a lot about where that driver is headed.

Step 4: Document the Review

The carrier official reviewing the MVR must:

• Sign and date the review document
• Note any violations found
• Record the determination: driver remains qualified, or driver is disqualified pending resolution

This signed review, along with the MVR itself, goes into the driver's DQF. Both documents are required. The MVR alone, without a signed review, doesn't satisfy §391.25. Carriers get cited on this point constantly.

“Pulling the MVR is half the requirement. The other half is the documented review, a carrier official must sign off confirming they examined the record and determined the driver's qualification status. We see carriers that pull MVRs on time but never document the review. That is still a violation.”

Step 5: Take Action on Disqualifying Findings

If the MVR reveals a disqualifying offense:

1. Immediately remove the driver from safety-sensitive functions. Don't wait for the review cycle to fully complete.
2. Document the removal and the reason in the driver's file.
3. Determine whether the disqualification is temporary or permanent. Some offenses carry fixed disqualification periods; others (like a second DUI) result in lifetime disqualification with limited reinstatement options.

One instance is enough. Operating a disqualified driver is classified as an acute violation under FMCSA safety fitness standards. A single occurrence can trigger enforcement action, including a conditional or unsatisfactory safety rating.

Annual MVR Review vs. Continuous MVR Monitoring

Plenty of fleets now use continuous MVR monitoring programs that provide real-time alerts when a driver's record changes.

Use continuous monitoring to catch problems in real time. Use the annual review to satisfy the regulatory requirement and maintain a clean DQF.

Carriers that rely solely on the annual review have a 12-month blind spot. A driver could get a DUI conviction the day after their MVR is pulled and keep driving for nearly a year before the next review catches it. Continuous monitoring closes that gap.

But carriers that rely solely on continuous monitoring and skip the documented annual review will fail a compliance review, even if they catch every violation in real time. You need both.

Common Audit Failures Related to MVR Reviews

FMCSA investigators cite these MVR-related issues most frequently:

1. Review not completed within 12 months. The most common failure by far.
2. MVR pulled, but no signed review document. The pull isn't enough.
3. MVR pulled from only one state. Drivers with multistate licenses require MVRs from each state.
4. No action taken on disqualifying findings. The MVR showed a DUI, but the driver kept operating. That's an acute violation.
5. The wrong person signed the review. The driver signed instead of a carrier official.

How to Build a Compliant Annual Review Process

1. Maintain a centralized schedule. Track every driver's last MVR review date and set 30-day advance alerts for the next one. Don't rely on memory or calendar reminders.

2. Pull MVRs from all relevant states. Check each driver's CDL record to determine if they held licenses in multiple states during the review period.

3. Designate specific officials to conduct reviews. Not every employee should sign off on MVR reviews. Designate qualified officials who understand disqualifying offenses and can make accurate fitness determinations.

4. Use a standardized review form. A consistent form ensures every review covers the same checklist: disqualifying offenses, serious violations, accident history, license status, and the fitness determination.

5. File the MVR and signed review together in the DQF. Both documents are required. An MVR without a signed review is a violation. A signed review without the underlying MVR is also a violation. Keep them together.

For a complete list of all DQF documents and their requirements, see our DQF Checklist. For DQF retention timelines, see our related article: How Long to Keep a Driver Qualification File.