MVR Monitoring and Annual MVR Compliance

Understanding the Annual MVR Requirement

Under 49 C.F.R. § 391.25, motor carriers must:

• Obtain and review each Driver’s MVR at least once every 12 months.
• Confirm the Driver holds a valid and appropriate license.
• Identify any violations, crashes, or license changes that could affect qualification.
• Maintain records documenting that the review was completed.

The Federal Motor Carrier Safety Administration (FMCSA) has issued regulatory guidance clarifying that employer notification systems and third‑party providers may be used to satisfy these obligations, provided the carrier reviews the information and maintains appropriate records.

How MVR Monitoring Supports Annual MVR Compliance

Rather than relying on a single annual snapshot, MVR Monitoring provides a continuous Driver monitoring process to help employers stay informed of changes to a Driver’s record throughout the year. This approach allows companies to:

• Identify adverse driving activity as it occurs.
• Take timely action when a license status or driving record changes.
• Maintain more current and accurate Driver Qualification files.
• Reduce compliance risk during Audits or Roadside Inspections.

FMCSA guidance confirms that employer notification systems—whether they operate through automatic state notifications (“push” systems) or regularly accessed checks (“pull” systems)—can satisfy the annual MVR review requirement when used appropriately.

SambaSafety's Compliance Position

SambaSafety’s platform is designed to align with FMCSA guidance by continuously monitoring enrolled Drivers across participating states and making updated MVR information available to employers for review.

Key compliance‑supporting capabilities include:

• Monitoring Drivers licensed in states with employer notification systems.
• Regularly checking driving records in states without notification programs.
• Automatically obtaining updated MVRs when new adverse information is identified.
• Maintaining electronic records to support Driver Qualification file requirements.

This approach enables employers to conduct their required reviews using current information while maintaining electronic documentation consistent with FMCSA recordkeeping guidance.

Important State-Specific Consideration

While FMCSA guidance allows employer notification systems and continuous monitoring to satisfy the annual MVR review requirement, J.J. Keller recommends that customers continue to obtain a full annual MVR for Drivers licensed in certain states due to state‑specific data availability, reporting nuances, or regulatory considerations.

We recommend continuing to pull an annual MVR for Drivers licensed in the following states:

• Arizona (AZ)
• California (CA)
• Connecticut (CT)
• Illinois (IL)
• Indiana (IN)
• Iowa (IA)
• Maryland (MD)
• North Dakota (ND)
• New Hampshire (NH)
• New Jersey (NJ)
• Oklahoma (OK)
• Pennsylvania (PA)
• South Dakota (SD)

For Drivers licensed in these states, maintaining a traditional annual MVR in addition to continuous monitoring helps ensure the most complete and defensible Driver Qualification file.

Continuous monitoring remains a valuable tool for identifying interim changes throughout the year; however, pulling an annual MVR for these states supports a more conservative compliance posture.

Official Compliance Statement (pdf)

For a detailed explanation of how continuous Driver monitoring and employer notification systems align with FMCSA Guidance to 49 C.F.R. § 391.25, including applicable regulatory references and a list of supported states, please review the official compliance statement below. This document is intended to support understanding of regulatory guidance and does not replace an employer’s responsibility to review Driver records and maintain compliance with applicable laws.