Annual MVR and Driving Record Review: What 391.25 Requires

Of all the recurring Part 391 obligations, the annual driving record review is the one most often half-completed. Carriers pull the MVR, file it, and stop — missing the review document that the rule actually asks for.

What the rule asks for

At least once every 12 months, 391.25 requires a carrier to:

1. Obtain the driver's motor vehicle record from each state where the driver held a commercial licence or permit in the preceding 12 months.
2. Review that record to determine whether the driver meets minimum requirements for safe driving and whether the driver is disqualified under Part 391.15.
3. Document the review, noting the reviewer's name and the date of the review, and keep it in the driver qualification file.

So the file needs two artifacts each year: the record, and the signed review of it.

What the reviewer is supposed to weigh

The rule is not a formality. The review considers the driver's accident record and any violations that indicate an inability to operate safely, alongside the carrier's own standards. In practice a defensible review notes:

• The states checked and the date each record was pulled.
• Violations found in the period, and their disposition.
• Any disqualifying offence under 391.15.
• The conclusion reached, and any conditions attached — additional training, for example.
• Who made the decision, and when.

The scheduling problem

Every driver has a personal 12-month clock, anchored to hire date or the last review. A twenty-truck fleet is running twenty separate clocks; a hundred-truck fleet is running a hundred. Reviews slip for the ordinary reason: nothing reminds anyone until an auditor asks.

Three habits fix it:

• Anchor the next date at the moment you complete a review, not at the start of the next year.
• Warn early — 60 and 30 days out — so pulling records from a slow state does not push you past the deadline.
• Track standing, not just documents: current, due soon, overdue, or never done.

Common findings

• The MVR is on file but the review document is not.
• The review exists but is undated or unsigned.
• Only one state was checked for a driver who held a licence in two.
• More than 12 months elapsed between reviews, even though both reviews exist.

How CabFiles handles it

CabFiles records each annual review against the driver, stores the violation count, decision and findings, and sets the next review date automatically. Every driver shows a standing — current, due soon, overdue or missing — and warnings arrive before the deadline rather than after. The review and the MVR both land in the driver's file, so the audit packet contains the pair the rule expects.

Related reading: driver qualification file requirements and our DOT audit preparation checklist.

Who may perform the review

The reviewer must be someone the carrier designates, and the review has to be a considered judgement rather than a signature. That judgement looks at the record for violations of driving rules and regulations, whether the driver still meets minimum requirements for the operation, and whether any pattern warrants action. Documenting the reasoning briefly is what separates a review from a filed MVR.

Keeping the 12-month cycle from slipping

The cycle is measured from the previous review, not from the hire anniversary or the calendar year. One late review pushes every subsequent one, and carriers frequently discover a 14-month gap only during an audit. Track the next due date the moment a review is completed, and warn early enough to order the MVR from the state before the date arrives — order times vary by jurisdiction and can consume a week.

When the record shows something

A poor record does not automatically disqualify a driver, but it does require a decision that you can explain. Record what was found, what you decided and why, and any conditions attached — additional training, a monitoring period, a change of operation. If disqualification is required by rule, note the rule. The file should let a reader six months later understand the decision without asking you.

Drivers licensed in more than one state

If the driver held a licence in another state during the period, pull that record too. Multi-state history is where reviewers most often miss a violation, and it is a routine audit question.

This is general guidance on a federal recordkeeping requirement, not legal advice.