What 391.25 means in plain language
FMCSR 391.25 requires that your motor carrier review your driving record at least once every 12 months. This is not a driver-facing test or document you submit yourself—it's an internal carrier obligation. Your employer must pull your Motor Vehicle Record (MVR) from your state's licensing agency and examine it to verify that you remain qualified to operate a commercial vehicle.
The review is meant to catch problems early: traffic violations, license suspensions, medical disqualifications, or other issues that might have emerged since your last review. If your carrier fails to conduct this annual review, they are in violation of 391.25, regardless of whether your actual driving record is clean.
If you received a citation for 391.25, it typically means a roadside inspector discovered during an investigation that your carrier had not documented an annual MVR review in the required timeframe. This is a carrier-level violation, but it appears on your inspection record.
What our enforcement data actually shows
Across our database of 13 million+ roadside inspection records, 391.25 shows zero all-time citations, zero citations in the last 12 months, and zero citations in the last 90 days. The out-of-service rate is 0.0%, meaning this code has never resulted in an out-of-service placement.
This enforcement pattern indicates that 391.25 citations are extremely rare in roadside inspection practice. Inspectors may not routinely audit carrier MVR review procedures during normal roadside stops, or when they do identify a lapse, it may be handled through other administrative channels rather than cited as a moving violation or vehicle defect. The absence of any OOS placements reflects that this violation does not directly disable a vehicle or immediately disqualify a driver from operating.
Who gets cited most
Given zero enforcement citations in our database, no geographic or carrier pattern exists to report. This code has not appeared in any state or carrier population in our 13 million+ inspection records.
How severe is this compared to similar codes
Other codes in the Driver Fitness category show far higher citation frequencies. For example, across our inspection records, 391.41(a) — Physical qualification general — has been cited 42,270 times with a 16.2% out-of-service rate. Similarly, 391.41A-MCPC (Physical qualification) has 30,779 citations and a 14.4% OOS rate. Codes related to Commercial Driver's License validity—such as 383.23(a)(2) for operating with the wrong CDL class—exceed 50,000 citations with OOS rates above 98%.
By contrast, 391.25's zero-citation history suggests that annual driving record reviews are either being completed reliably by carriers, or violations are addressed through non-inspection channels. The citation is theoretically possible but practically uncommon.
How to avoid it
Since 391.25 is a carrier-level obligation, your primary defense is communication and awareness:
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Ask your safety department or HR when your last annual MVR review was conducted. Request documentation that shows the date and results. If your carrier cannot produce this record for the past 12 months, flag it immediately so they can conduct the review before an audit or inspection uncovers a gap.
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Ensure your address and contact information are current with your state's driver licensing agency. If your carrier requests your MVR and the state has an outdated mailing address, there may be delays in receiving the report. Update your address proactively when you move.
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Report any traffic violations, license suspensions, or medical changes to your carrier immediately. Do not wait for the annual review to surface a problem. Carriers that know about issues can address them in real time and demonstrate due diligence if an inspection occurs.
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Keep a personal copy of your driving record. Many states allow drivers to request their own MVR online at no cost. Knowing what your carrier will see helps you spot discrepancies or outdated information that might trigger a compliance question.
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If you change carriers, ensure your new employer receives your MVR and documentation of previous annual reviews. A gap in review documentation across the transition could trigger a citation if inspected shortly after onboarding.
The citation itself is rare, but the underlying requirement—that carriers maintain an audit trail of driver fitness checks—is a core part of the Federal Motor Carrier Safety Administration's oversight framework. Your role is to stay informed and help your carrier meet the deadline.