Reviewed by Randy Powelson, founder of CertiFlow · Last updated 2026-09-06 against published guidance on hired and non-owned auto insurance and MVR screening
This is general information, not legal or insurance advice. Requirements vary by state, insurance carrier, and policy. Read your own policy language and confirm the specifics with your broker or counsel.
The exposure
When employees drive personal vehicles for work, employers commonly carry hired and non-owned auto (HNOA) coverage, because the business can be held liable for a crash an employee causes on the job — even in a car the company does not own.
Many commercial auto and HNOA policies include driver-eligibility conditions — for example, that employees who drive for work hold a valid license and carry their own auto insurance, and sometimes that their driving records are checked. The specifics vary by carrier and policy, and not meeting a policy's stated conditions can complicate or jeopardize a claim. Review your own policy language with your broker.
Background: Insurance Information Institute — business insurance · FMCSA — Commercial Driver's License Program (for the CDL vs. ordinary-license line below).
The four records to keep current
01Driver's license
A current, valid license for the class of vehicle they drive, with the expiry date on file. For most delivery and visiting-staff roles this is an ordinary license, not a CDL. Track the issuing state and expiry — not the license number, which does not belong in a shared sheet.
02Personal auto insurance (certificate of insurance)
A COI for the employee's own auto policy, showing liability limits at or above the minimum you require, plus the policy dates. A personal policy can limit or exclude coverage when the car is used for business or delivery, which is part of why the employer's hired and non-owned auto (HNOA) layer matters.
03Motor vehicle record (MVR) check
An MVR from the state licensing agency shows license status, violations, and suspensions. Run it on a defined cadence — many employers check at hire and then annually — and record the date and result. CertiFlow does not pull these; a screening vendor does.
04Vehicle registration
Current registration for the vehicle the employee actually drives for work, with its expiry date. Simple to forget, easy to keep.
Why lapses matter
In many states, an employer who lets an employee drive for work without reasonable checks on their license or driving history can face a negligent entrustment or negligent hiring claim if that employee causes a crash — a claim against the employer itself, separate from the employee's own liability. How these claims work, and what damages apply, varies by state.
How to run it
Keep one source of truth for every driver, not a folder per manager. For each of the four records, store the expiry date and a status, and check ahead of the date rather than after it. A free driver compliance tracker spreadsheet is a fine start; past a handful of locations, the manual date-checking is what breaks.
Set an MVR re-check cadence (many employers use annual, plus after any incident), decide your minimum liability limits, and make sure someone owns the follow-up when a date is approaching.
Where CertiFlow fits — and where it doesn't
CertiFlow is a system of record and an expiry-alert engine: it holds each driver's license, COI, MVR-check date, and registration across every location, and sends escalating email alerts as each date approaches. It does not pull DMV or MVR records, run background screening, or provide continuous license monitoring. Pair it with a screening vendor (SambaSafety, Foley, Checkr) for the data-pull side.
For multi-location operators
Track every driver's records without chasing dates
CertiFlow keeps each driver's license, insurance certificate, MVR-check date, and registration in one place across all your locations, with escalating email alerts as each expiry date approaches — so nothing lapses unnoticed.
- Every driver record, every location, one view
- Escalating alerts from 30 days out
- Pairs with your MVR screening vendor
Frequently asked questions
Do I need to track this if employees drive their own cars, not company vehicles?
Yes — that is exactly the situation hired and non-owned auto (HNOA) coverage is for. An employer can be held responsible for a crash an employee causes while working, even in a personal car the company does not own, and the verification behind that coverage is what this tracking supports.
Which records should I keep for each driver?
Four: a valid driver's license with its expiry date, a certificate of insurance (COI) for the employee's personal auto policy showing limits at or above your minimum, a motor vehicle record (MVR) check on a set cadence, and current vehicle registration.
Does CertiFlow pull driving records or run MVR checks?
No. CertiFlow is a system of record and an expiry-alert engine. It does not connect to any DMV, run MVR checks, perform background screening, or provide continuous license monitoring — pair it with a screening vendor such as SambaSafety, Foley, or Checkr for that.
How often should we re-check a motor vehicle record?
There is no universal rule. Many employers check at hire and then annually, with more frequent checks for higher-risk roles or after an incident. Your insurer or broker may set an expectation — confirm it with them.
What is negligent entrustment?
A legal claim that an employer allowed someone to drive for work when it knew, or should have known, the person was unlicensed or unfit. It is a claim against the employer directly, separate from the driver's own liability, and how it works varies by state.