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. Separately, 391.27 requires the driver to furnish a list of violations at least annually. An MVR sitting in a folder with no review note is 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
Once every 12 months the driver must furnish a list of all violations of motor vehicle laws (other than parking) for the preceding 12 months, or a certification that there were none. This is the driver’s statement. It does not replace the state MVR.
Auditors compare the list to the MVR. Undeclared tickets are a coaching and honesty issue; a missing list is a file issue.
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.
Related guides
When you are ready for software
Editorial links to the TruckerPro product site (separate intent from these guides):
- Track annual MVR and review dates (truckerpro.ca)
Related reading on truckerpro.ca
Deeper regulatory articles and the software side of the same job, on our product site:
- Clearinghouse query tracking (truckerpro.ca)
Keeping annual and pre-employment queries evidenced against each driver. - Driver file management in a TMS (truckerpro.ca)
Expiry tracking, audit packets and version history without the binder. - TMS for US carriers (truckerpro.ca)
The same records under FMCSA rules, for US-authority fleets. - Trucking compliance software (truckerpro.ca)
Where driver files sit inside the wider compliance picture a TMS tracks.
Ready to digitize driver files?
TruckerPro tracks licences, medicals, abstracts/MVRs, and expiries for US and Canadian fleets — free company signup, free demo on request.