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● Updated April 2026 · 42 FMCSA Requirements

DOT Compliance Checklist for Small Carriers — Every FMCSA Requirement in Plain English

Written for the fleet owner with 1–20 trucks who doesn't have a compliance department. No regulation-speak. No generic advice. Every item tells you exactly what it is, when you need it, and what happens if you miss it.

📋 42-item interactive checklist📄 Free PDF download⚡ 18 min read🔍 Audit-ready structure
42compliance requirements
7categories covered
$10Kmax fine per day per violation
45days to fix after failed audit
● QUICK ANSWER

DOT compliance for motor carriers is governed by 49 CFR Parts 380–399. The seven core areas are: operating authority and registration, driver qualification files, drug and alcohol testing, hours of service and ELD compliance, vehicle inspection and maintenance, insurance, and accident records. This guide covers all 42 requirements across those seven areas — with plain-English explanations and the specific consequence of missing each one.

Who This Applies To — And There Are No Exceptions

The most dangerous misconception in trucking compliance is "I'm too small to need all this." That belief ends careers.

FMCSA jurisdiction applies to any motor carrier operating a commercial motor vehicle (CMV) in interstate commerce. The definition of a CMV is broader than most carriers realize:

🚛
Over 10,001 lbs GVWR

Any vehicle — truck, van, pickup pulling a trailer — with a gross vehicle weight rating over 10,001 lbs. Most commercial trucks qualify automatically.

☢️
Hazmat placards required

Any vehicle transporting hazardous materials in quantities requiring DOT placards. Size doesn't matter — a pickup truck hauling certain chemicals is a CMV.

🚌
9+ passengers for compensation

Any vehicle designed to carry 9 or more passengers and used for compensation. Shuttle operators, charter buses, and similar operations are included.

⚠️ One truck. One driver. Full compliance required.
An owner-operator with one truck, their own USDOT number, and a single interstate route has the identical documentation requirements as a 500-truck fleet. FMCSA does not have a "small carrier" exemption for DQ files, drug testing programs, ELD requirements, or vehicle inspection records. The only difference is you don't have a compliance department. That's what this checklist is for.

What Auditors Actually Check — And in What Order

A DOT compliance review (audit) isn't random. FMCSA auditors follow a structured process. Understanding their sequence tells you where your highest-risk gaps are and what to fix first.

1
Driver Qualification Files — pulled for every active driver

DQ files are the most common source of violations at small carriers. Auditors pull files for all active drivers on day one. A single missing document in a single driver's file is a violation. Ten drivers with one missing document each is ten violations. The math compounds fast.

2
Drug & Alcohol Testing Records — including Clearinghouse logs

Auditors verify your testing program is formally established, that pre-employment tests are documented for every current driver, that you're enrolled in a random testing pool, and that your Clearinghouse query log shows both pre-employment and annual queries for every CDL driver.

3
Hours of Service Logs — 6 months minimum

Auditors request ELD data and supporting documents for all active drivers going back 6 months. They're looking for HOS violations (11-hour rule, 14-hour window, 30-minute break) and checking that ELD data is consistent with supporting documents like fuel receipts and toll records.

4
Vehicle Maintenance Records — annual inspections and DVIRs

Every active CMV must have a current annual inspection report — and the previous report must still be on file (14-month retention). DVIRs for the past 3 months are reviewed. Missing maintenance records or uninvestigated defects are primary violations.

5
Insurance & Operating Authority — verified through SAFER

Auditors verify BMC-91 filing is current, minimum liability limits are met, and operating authority is active. This section rarely produces primary violations for established carriers — but a lapsed BMC-91 filing can trigger immediate authority revocation.

📌 Documents must predate the audit — without exception
You cannot assemble compliance records after an auditor arrives. An MVR pulled the morning of an audit doesn't satisfy last year's annual review requirement. A drug test completed during the audit doesn't satisfy a missing pre-employment test. Every document in your DQ file must be dated from when it was actually obtained. The timestamp matters as much as the document itself.
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The Complete DOT Compliance Checklist — PDF

All 42 items, organized by section. Designed to survive a real audit — not just look good in a folder. Print it, fill it in, keep it updated.

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The Full DOT Compliance Checklist — 42 Requirements

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Operating Authority & Registration

Before your first truck moves a single mile

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USDOT Number — registered and activeCritical
When: Before first commercial move49 CFR §390.19
If you miss this: Operating without a USDOT number = $1,000–$10,000 fine per violation. Every mile driven is a separate infraction.
MC Number (Operating Authority) — if for-hire interstateCritical
When: Before first for-hire move49 CFR §365
If you miss this: For-hire carriers without operating authority can have their trucks impounded at any weigh station.
BOC-3 — Process agent designation filedCritical
When: Before operating authority activates49 CFR §366
If you miss this: Without BOC-3, operating authority will not be granted or may be revoked. Freight brokers will refuse to dispatch you.
UCR (Unified Carrier Registration) — paid annuallyHigh Risk
When: Every year, before Jan 149 USC §14504a
If you miss this: UCR violation = $100–$5,000 fine. Some states perform UCR checks at weigh stations and will put you OOS.
MCS-150 Biennial Update — filed every 2 yearsHigh Risk
When: Every 24 months, based on USDOT suffix49 CFR §390.19
If you miss this: Failure to file biennial update = FMCSA will mark your authority inactive. Loads will be rejected by brokers who verify SAFER.
IFTA Fuel Tax Registration — if operating in multiple statesMedium
When: Before operating across state linesIFTA Agreement
If you miss this: Operating without IFTA decals in participating states = fines up to $1,000 per state, plus back taxes owed.
📁

Driver Qualification File (DQ File)

One folder per CDL driver — auditors pull this first

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Driver Employment Application — completed and signedCritical
When: Before driver's first dispatch49 CFR §391.21
If you miss this: Missing application = automatic DQ file violation. Auditor flags the driver's entire file. Fine per driver, per item.
Pre-Employment MVR — from every state licensed in past 3 yearsCritical
When: Before first dispatch49 CFR §391.23
If you miss this: Hiring a driver without an MVR check means you have no documented knowledge of their driving record. Negligent hiring exposure in any accident.
Road Test Certificate — or equivalent skills test waiverCritical
When: Before first dispatch49 CFR §391.31
If you miss this: No road test = driver was never formally qualified by your company. This is a primary violation that opens every related record to scrutiny.
Medical Examiner Certificate — current (not expired by one day)Critical
When: Current at all times while driver is active49 CFR §391.41
If you miss this: Zero grace period. Expired by one day = driver is disqualified. 7-point CSA violation. Potential insurance denial if accident occurs.
Previous Employer Verification — 3 years of driving historyHigh Risk
When: Within 30 days of hire49 CFR §391.23
If you miss this: Missing verification = you hired a driver without knowing their full safety record. Every previous employer must be contacted in writing.
Annual MVR Review — every 12 months, every state licensedCritical
When: Every year49 CFR §391.25
If you miss this: Annual MVR is one of the most commonly missed DQ items. Missing for one year = violation. Missing for multiple drivers = pattern finding in audit.
Annual Driver Certification of Violations — signed by driverHigh Risk
When: Every year (Jan 1 is the common reset)49 CFR §391.27
If you miss this: The driver must provide a written list of all traffic violations from the past 12 months. Even if they had none, they must certify 'none.' Missing this is a primary audit violation.
Annual Driving Record Review — carrier reviews the annual MVRHigh Risk
When: Every year49 CFR §391.25
If you miss this: You must document that you actually reviewed the MVR and determined the driver still meets qualifications. The review itself must be in the file.
Clearinghouse Pre-Employment Query — full query before first dispatchCritical
When: Before first safety-sensitive function49 CFR §382.701
If you miss this: Dispatching any CDL driver without a Clearinghouse query is a federal violation — even if the driver is clean. No query = violation. Period.
Clearinghouse Annual Limited Query — every current CDL driverHigh Risk
When: Every year49 CFR §382.701
If you miss this: Missing annual query = violation per driver. FMCSA auditors check Clearinghouse query logs directly — they can see if you queried or not.
Entry-Level Driver Training (ELDT) Certificate — for new CDL holdersHigh Risk
When: For any driver who obtained CDL after Feb 7, 202249 CFR Part 380
If you miss this: If your driver got their CDL after February 2022 and you don't have their ELDT completion record, they were technically unqualified when you hired them.
🧪

Drug & Alcohol Testing Program

One missing test can cost you your operating authority

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Formal D&A Testing Program — consortium or own programCritical
When: Before first CDL driver dispatched49 CFR Part 382
If you miss this: No testing program = operating without a required safety system. This is a primary violation that can trigger immediate corrective action requirements.
Pre-Employment Drug Test — negative result before first dispatchCritical
When: Before first safety-sensitive function49 CFR §382.301
If you miss this: If a driver is involved in an accident and has never been drug tested, your liability exposure is unlimited. Every day they drove without a negative result is a violation.
Random Testing Pool — enrolled and tested at required ratesCritical
When: Ongoing — current rates: 50% drug, 10% alcohol49 CFR §382.305
If you miss this: Not enrolling in a random testing pool or testing below required rates is a primary audit finding. FMCSA will review your testing rate against driver count.
Post-Accident Testing Procedures — documented and followedCritical
When: Within 8 hrs (alcohol) and 32 hrs (drugs) of qualifying accident49 CFR §382.303
If you miss this: Missing a required post-accident test is one of the most expensive compliance failures — it triggers both a primary violation and potential insurance coverage disputes.
Reasonable Suspicion Training — all supervisors of CDL driversHigh Risk
When: Before supervising any CDL driver49 CFR §382.603
If you miss this: Every supervisor who dispatches or supervises CDL drivers must have 60 minutes of alcohol training and 60 minutes of drug training on file. No exceptions.
MIS Annual Report — submitted to FMCSA by March 15High Risk
When: Every year by March 1549 CFR §382.403
If you miss this: The Management Information System (MIS) report summarizes your testing program results. Failure to file is a separate violation from testing program failures.
Testing Records Retention — 5 years for positives, 1 year negativesHigh Risk
When: Ongoing49 CFR §382.401
If you miss this: Auditors will request test records. Missing records for required tests is treated the same as missing tests — you cannot prove compliance without documentation.
⏱️

Hours of Service & ELD Compliance

Every log is a legal document — treat it that way

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ELD — registered on FMCSA's approved device listCritical
When: Installed before driver logs first mile49 CFR §395.8
If you miss this: Running an unregistered or uncertified ELD is treated as running no ELD. Every log from that device is potentially invalid. All drivers on that unit get OOS orders.
ELD Data Transfer — driver can transfer logs to inspectorHigh Risk
When: Ongoing — at every roadside inspection49 CFR §395.24
If you miss this: If a driver cannot transfer ELD data to an inspector via Bluetooth, USB, or email within 1 minute, the inspector may treat it as a missing log violation.
HOS Logs — retained 6 monthsCritical
When: Ongoing — 6-month rolling retention49 CFR §395.8
If you miss this: Auditors request HOS logs for the past 6 months. Missing logs = violation per driver per day. A 5-driver fleet with 30-day gaps = 150 individual violations.
Supporting Documents — fuel receipts, toll records, BOLs retained 6 monthsHigh Risk
When: Ongoing — 6-month retention49 CFR §395.11
If you miss this: Supporting documents corroborate ELD data. Auditors use them to detect falsified logs. Missing them makes it impossible to defend against HOS violation allegations.
HOS Rules — drivers trained and following correctlyCritical
When: Every shift49 CFR §395.3
If you miss this: The 11-hour driving limit, 14-hour on-duty window, 30-minute break, and 60/70-hour limit must all be met. Each individual rule violation is a separate CSA score event.
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Vehicle Inspection & Maintenance

Every truck. Every year. Every day.

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Annual CMV Inspection — by a qualified inspectorCritical
When: Every 12 months per vehicle49 CFR §396.17
If you miss this: A CMV without a current annual inspection sticker is OOS on sight at any roadside inspection. No annual inspection = no legal operation. The report must be on the vehicle.
Annual Inspection Report — retained 14 monthsHigh Risk
When: Filed after each annual inspection49 CFR §396.21
If you miss this: The report must outlast the next inspection by 2 months. If you can't produce it during an audit, it's treated as if the inspection never happened.
Pre-Trip DVIR — completed by driver before each tripCritical
When: Every day before dispatch49 CFR §396.11
If you miss this: The DVIR must document that the driver inspected the vehicle. If a defect causes an accident and you have no DVIR, negligence is nearly impossible to defend.
Post-Trip DVIR — completed by driver after each tripHigh Risk
When: Every day after final delivery49 CFR §396.11
If you miss this: Post-trip DVIR documents any defects found during the day. Missing post-trip DVIRs for multiple drivers = pattern finding. 3-month retention required.
Defect Repair Documentation — mechanic sign-off before re-dispatchCritical
When: Before redispatching any vehicle with a reported defect49 CFR §396.11
If you miss this: If a driver reports a defect on the DVIR, a qualified mechanic must certify repair before the vehicle moves again. Operating with a known unrepaired defect is a serious violation.
Preventive Maintenance Schedule — documented and followedHigh Risk
When: Ongoing — per your PM interval49 CFR §396.3
If you miss this: Auditors look for a systematic maintenance program. 'I fix things when they break' is not a compliance program. No PM schedule = no documented systematic inspection.
Maintenance Records — retained while vehicle is in fleet + 1 yearHigh Risk
When: Ongoing49 CFR §396.3
If you miss this: All repair orders, PM records, and inspection records must be kept. Missing records make it impossible to demonstrate systematic vehicle care at audit.
🛡️

Insurance & Financial Responsibility

One lapse can void every claim you ever file

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BMC-91 Filing — liability insurance on file with FMCSACritical
When: Before operating authority activates — must be continuous49 CFR §387.7
If you miss this: A single day without BMC-91 coverage on file with FMCSA can trigger automatic revocation of operating authority. Your insurer files this — verify it annually.
Minimum Liability Limits — $750K (general freight), $5M (hazmat)Critical
When: Continuous49 CFR §387.9
If you miss this: Carrying less than minimum required limits is a federal violation and may void your operating authority entirely. Verify limits at every policy renewal.
Cargo Insurance — if required by operating authority or contractsMedium
When: Per contract requirements49 CFR §387.301
If you miss this: Many shippers and brokers require cargo insurance minimums beyond FMCSA requirements. Operating without it doesn't violate federal law but will end your shipper relationships.
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Accident Register & Safety Records

Every DOT-recordable accident must be documented

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Accident Register — maintained for 3 yearsHigh Risk
When: Entry required for every DOT-recordable accident49 CFR §390.15
If you miss this: A DOT-recordable accident that is not in your register is a primary violation. Auditors cross-check the register against your insurance claims and state police records.
Recordable Threshold Documentation — fatality, injury, or tow-awayHigh Risk
When: At every accident49 CFR §390.5
If you miss this: You must document why each accident was or was not recordable. 'We decided it wasn't' without documentation is not defensible when an auditor finds a police report.
Post-Accident Drug/Alcohol Test Decision — documentedCritical
When: Within hours of every qualifying accident49 CFR §382.303
If you miss this: You must document the decision to test or not test after every accident. If the accident meets the threshold and you didn't test, that failure is a primary violation.
📊

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Record Retention Guide — How Long to Keep Everything

"How long do I keep this?" is one of the most common compliance questions — and one of the easiest to get wrong. Here are the required retention periods for every major document category, pulled directly from 49 CFR.

Document TypeRetention PeriodCFR ReferenceRisk
Driver Qualification File (entire file)3 years after driver leaves§391.51Critical
Medical Examiner Certificate3 years§391.51Critical
Annual MVR3 years§391.51High Risk
Previous Employer Verification3 years§391.51High Risk
Drug Test — Positive / Refusal5 years§382.401Critical
Drug Test — Negative Result1 year§382.401High Risk
Drug Testing MIS Reports5 years§382.401High Risk
ELD / HOS Logs6 months§395.8Critical
HOS Supporting Documents6 months§395.11High Risk
Annual Vehicle Inspection Report14 months§396.21Critical
DVIR (Driver Vehicle Inspection Report)3 months§396.11High Risk
Vehicle Maintenance Records1 year after vehicle leaves fleet§396.3High Risk
Accident Register3 years§390.15High Risk
Clearinghouse Query Results3 years§382.701High Risk
💡 When in doubt, keep it longer
These are minimum retention requirements. If an accident or legal claim is pending, retain all related records indefinitely until the matter is fully resolved. Many carriers keep DQ files for the life of the company — the cost of storage is trivial compared to the cost of a missing document in litigation.

Surviving a DOT Compliance Review — What Actually Happens

Most small carriers have never been through a DOT compliance review and don't know what to expect. Here's the realistic sequence.

Pre-Audit Notice

FMCSA typically provides written notice 48–72 hours before a comprehensive compliance review. However, they are not required to do so. An 'investigative review' triggered by a crash or complaint may have little or no notice. In either case, your documents must already be in order — there is no time to assemble records after notification.

Day 1 — Document Request

The auditor will request a list of all active drivers and all CMVs currently in your fleet. They will then request DQ files for all active drivers, drug testing records, and 12 months of HOS logs for a sample of drivers. Have these organized and accessible. Disorganized files extend the audit duration — which gives auditors more time to find issues.

Day 2–3 — Detailed Review

The auditor reviews each document against the regulatory requirement. Every missing item, every expired date, every undated document is flagged. They cross-reference your driver list against Clearinghouse query logs directly — discrepancies are immediately visible. Vehicle maintenance records are reviewed against the annual inspection dates.

Exit Conference

The auditor presents their findings. They explain which violations were found, how they're rated, and what the preliminary safety rating will be. This is your opportunity to provide any documents you believe were overlooked. After the conference, you have a formal response window — but the documents themselves must have predated the audit.

Safety Rating Issued

Satisfactory: You passed. Continue normal operations. Conditional: You have 45 days to correct all violations and request a follow-up review. Your rating is public in SAFER immediately. Unsatisfactory: FMCSA issues a notice of proposed enforcement action. You have 45 days to contest or correct before operations are at risk.

The 7 Most Common DOT Compliance Mistakes at Small Fleets

These aren't theoretical. These are the seven violations that show up most frequently in FMCSA compliance reviews at small carriers — pulled from FMCSA enforcement data and real audit findings.

01

Letting medical certificates expire without a tracking system

This is the single most common DQ file violation at small fleets. Most carriers know the rule — they just don't have a reliable alert system. By the time the expiration is discovered, it's usually at a weigh station or during an audit. Zero grace period means every day it was expired is a violation.

Fix: Set automated alerts 60, 30, and 14 days before every driver's certificate expiration. Track in a system that alerts more than one person.
02

Not running annual MVRs on every driver

Many carriers pull MVRs at hire and then never again. 49 CFR §391.25 requires an annual review. A driver could accumulate serious violations between hire and their next renewal — and your DQ file would show no knowledge of it.

Fix: Set a calendar reminder to pull MVRs in January for all active drivers. Document the review with a signed and dated note in each DQ file.
03

Skipping Clearinghouse annual queries

Most carriers know about the pre-employment Clearinghouse query. Far fewer consistently run the annual limited query required for every current CDL driver. FMCSA auditors pull Clearinghouse query logs — they can see exactly which dates you queried and which drivers you missed.

Fix: Query all active CDL drivers in the Clearinghouse every January. Retain the query results in each driver's DQ file.
04

Operating without a formal drug testing program

Owner-operators and new small carriers frequently operate for months without a formal DOT drug testing program in place. They know they need it — they just haven't set it up yet. 'I haven't gotten around to it' is not a defense in an audit.

Fix: Join a DOT drug testing consortium immediately. Cost is typically $150–$250 per driver per year and it covers random pool enrollment, collection site access, and MRO services.
05

Missing the annual driver certification of violations

Every CDL driver must sign a document certifying their traffic violations for the past 12 months — even if they had none. This requirement exists under 49 CFR §391.27. Many carriers have never heard of it. Auditors find it missing in a majority of DQ files at small carriers.

Fix: In January each year, have every CDL driver complete and sign a violation certification. Keep the original in their DQ file.
06

Incomplete or missing DVIR records

Drivers fill out pre-trip and post-trip DVIRs every day — and then they stack up in the cab, get lost, or never make it back to the office. The 3-month retention requirement means you need a system for collecting and filing them, not just completing them.

Fix: Use a digital DVIR system so records are automatically retained. If using paper, collect DVIRs weekly and file by vehicle and date.
07

No MCS-150 biennial update

The MCS-150 form (Motor Carrier Identification Report) must be updated every 24 months based on the last two digits of your USDOT number. Many small carriers file it once when they register and never again. FMCSA will mark your authority inactive — and brokers verify SAFER on every load.

Fix: Set a calendar reminder for your USDOT suffix-based filing window. The update is free and takes 10 minutes on FMCSA's Portal.
TC
TruckComplianceHQ Editorial Team
FMCSA Compliance Specialists

This guide was developed by the compliance team at TruckComplianceHQ, drawing on 49 CFR Parts 380–399, FMCSA enforcement statistics, and direct input from small fleet owners and transportation safety attorneys. All regulatory information reflects requirements in effect as of April 2026. This guide is for informational purposes only and does not constitute legal advice. For carrier-specific compliance guidance, consult a qualified transportation attorney or DOT compliance consultant. Always verify current requirements at FMCSA.dot.gov.

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Frequently Asked Questions

It's a structured list of every requirement a motor carrier must meet under FMCSA regulations. It covers driver qualification files, drug and alcohol testing, hours of service records, vehicle inspections, and insurance. For small carriers without a compliance team, this checklist is the only thing standing between you and a failed DOT audit.
One truck. If you're operating in interstate commerce with a vehicle over 10,001 lbs GVWR, FMCSA regulations apply to you from day one. There is no small fleet exemption. An owner-operator with one truck has the exact same documentation requirements as a carrier with 200 trucks.
Driver Qualification Files, every time. DQ files are the single most common source of violations at small carriers because they require 10+ individual documents per driver, updated on different schedules. After DQ files, auditors move to drug and alcohol testing records, HOS logs, vehicle maintenance records, and insurance filings — in roughly that order.
You receive a safety rating: Satisfactory, Conditional, or Unsatisfactory. Conditional means you have 45 days to fix all violations or face a follow-up review. Unsatisfactory means FMCSA can issue an operations out-of-service order after 45 days. Your rating is public in FMCSA's SAFER database — brokers and shippers can see it the day it's issued. Many will stop dispatching you immediately.
Yes, completely. If you have your own USDOT number, you need a DQ file on yourself, a formal drug and alcohol testing program (usually through a consortium), an ELD, annual vehicle inspections, and proper insurance filings. The most common owner-operator failure is operating without a drug testing program — often because nobody told them they needed one.
A roadside inspection is a random check at a weigh station or during a traffic stop — it primarily checks your vehicle's mechanical condition, your ELD and current HOS logs, and your operating authority documents. A DOT compliance audit (also called a compliance review) is a formal investigation of your entire operation — including DQ files, drug testing records, maintenance records, and insurance. Roadside inspections feed data into your CSA score, which determines how likely you are to receive a compliance review.
It depends on the record type. DQ files: 3 years after the driver leaves. Medical certificates: 3 years. Annual MVRs: 3 years. HOS logs: 6 months. Drug test results: 5 years for positives and refusals, 1 year for negatives. Annual vehicle inspections: 14 months. Maintenance records: 1 year after vehicle leaves fleet. Accident register: 3 years. When in doubt, keep it longer.
The Clearinghouse is a federal database launched in January 2020 that records every CDL driver's drug and alcohol violations. As a carrier, you must register at clearinghouse.fmcsa.dot.gov, run a full pre-employment query on every new CDL driver before their first dispatch, and run annual limited queries on all current CDL drivers every calendar year. Auditors can pull your Clearinghouse query log directly — they'll know immediately if you missed any queries.

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