At least once every 12 months, a US motor carrier must inquire into the driving record of each driver from every state where that driver held a licence, review the record for disqualifying or concerning history, and make a note that the review was done. The separate 391.27 list of violations the driver used to furnish was rescinded effective May 9, 2022, so the annual is now three steps and not four. An MVR sitting in a folder with no review note is still an incomplete annual.
Three pieces, not one PDF
Fleets collapse this into “we pull MVRs once a year.” The rule is more specific.
- Inquiry to each state driver licensing agency where the driver held a licence (391.25(a)).
- Review of that record against your standard for a safe driver, including whether the driver is disqualified (391.25(b)).
- A note that the review was performed, kept in the qualification file (391.25(c)(2)).
The 391.27 list of violations is gone - stop collecting it
For decades the annual had a fourth step: once every 12 months the driver furnished a list of every motor-vehicle conviction other than parking, or certified there were none. FMCSA rescinded that rule. The final rule was published March 9, 2022 and took effect May 9, 2022, on the reasoning that the annual MVR inquiry already reports the same convictions from the authoritative source.
Three things follow. A missing violations list is not an audit finding, and an auditor citing one is working from a superseded checklist. A carrier still gathering signed lists is spending a signature per driver per year on a document with no regulatory home - harmless, but it is not evidence of anything the MVR does not already prove. And a self-declaration form is still a legitimate hiring and coaching tool if you want one; it is simply a company practice now, not 391.27, and it should be filed as such.
The step this did not remove is the review note. Rescinding the driver’s list made the carrier’s own review of the MVR the whole of the annual, so a file with an MVR and no note is weaker now than it was before 2022, not stronger.
Cadence that survives turnover
Anchor the annual on hire-month anniversary or on a fleet-wide month (many Canadian-US dual fleets pick January). Write the choice in the safety program and sample it. Mixed cadences without a written rule look like you only reviewed the drivers who remembered.
High-risk or new drivers may be pulled more often under company policy. More frequent pulls are allowed. Skipping a 12-month cycle is not.
What the review note should say
Who reviewed it, the date, which MVR(s) were considered, and the conclusion (meets standard / follow-up / remove from safety-sensitive work). A sticky “OK” with no date is weak evidence. The note can be short. It cannot be implied.
FAQ
If the MVR is clean, do I still need a review note?
Yes. The file has to show that a person looked at the record and reached a conclusion. A clean MVR without a dated review is an incomplete 391.25.
Does a Canadian abstract count as the annual MVR?
No. A provincial abstract is the Canadian program document. For US-side 391.25 you still need the state MVR inquiry for licences the driver held in the United States.
More in US driver qualification files · short answers on the FAQ · terms on the glossary.
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Related guides
Driver files in the wider operation
Explore related driver-file workflows in the TruckerPro TMS:
- Track annual MVR and review dates (truckerpro.ca)
Related reading on truckerpro.ca
More driver-file resources from the TruckerPro family:
- Clearinghouse query tracking (truckerpro.ca)
Keeping annual and pre-employment queries evidenced against each driver. - Driver qualification file software (truckerpro.ca)
DQF document tracking and audit packets for US-authority fleets. - TruckerPro driver file management (truckerpro.ca)
Expiry tracking, audit packets and version history without the binder.
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