Annual MVR Review Requirements

For drivers subject to the rule, the annual MVR process includes both obtaining the driving record and reviewing it. Saving the MVR alone does not document the review. §391.25 describes the annual inquiry, the review and the record of who reviewed it and when.

Separate the inquiry from the review

The inquiry obtains the driver’s motor vehicle record. The review considers that record and whether the driver meets the relevant safe-driving and qualification standards. Treat them as two tasks in your filing system. A report arrival date may help track the inquiry, but it should not silently become the review date.

For the inquiry’s timing and licensing jurisdictions, read §391.25(a). For the review itself, use §391.25(b). Confirm applicability to the driver and operation rather than assuming every person on your payroll follows the same process.

What to keep together

• The driving record obtained for the inquiry.
• The driver identifier and relevant licensing information.
• The date the review was performed.
• The name of the person who performed the review.
• Any operational follow-up that resulted, kept with appropriate supporting evidence.

The required review note is addressed by §391.25(c). Driver-file retention requirements appear in §391.51. Use the actual rule for the retention period and any exceptions rather than applying one deletion date to every document in a driver’s folder.

Set a date that means something

A useful tracker distinguishes the last completed review from the next scheduled follow-up. Do not move the completed date merely because you asked someone to obtain a report. If the report is delayed, the outstanding task should remain visible. Once the review is complete, record the actual review evidence before updating your tracker.

Choose an internal reminder far enough ahead to obtain records and complete the review. That reminder is your work schedule; it does not change the regulatory requirement. Document a consistent process so another team member can take over without inventing dates.

Example: the report exists but the review is missing

A driver’s folder contains a recent MVR, but nobody can find the reviewer’s note. The next action is to establish whether the review took place and obtain the appropriate evidence. It is not to mark the file complete based on the report’s presence. If the review still needs to be done, the responsible person should perform it and record the actual date.

Do not backdate a note to make the tracker appear current. Preserve the facts and handle any gap through your compliance process. This keeps the record useful to the next person reviewing the file.

Annual review is not the hiring investigation

The pre-employment inquiries and investigations in §391.23 serve a different stage of the driver relationship. Organize the initial hiring evidence separately from recurring annual records, while keeping both accessible through the driver file. Completing one process does not automatically document the other.

Common filing problems to catch

Check for documents saved under the wrong driver, duplicate reports with unclear dates, a reviewer field left blank and next-review dates advanced without supporting evidence. Also check whether someone has stored a screenshot of an order confirmation instead of the actual driving record.

Make the follow-up specific: “obtain the report,” “complete the review” or “file the review note” is more useful than “fix DQF.” The driver-file checklist template gives you a place to record an owner and next action. It does not order reports or perform the review.

For the agency’s interpretation of the review, see FMCSA’s annual driving-record review guidance.