California’s commercial driver’s license program is facing heightened federal scrutiny — and thousands of drivers and fleets are feeling the impact.
Following a Federal Motor Carrier Safety Administration (FMCSA) audit, the U.S. Department of Transportation (USDOT) announced that the California DMV will revoke approximately 17,000 non-domiciled Commercial Driver’s Licenses (CDLs) that were issued in violation of federal requirements. Those drivers have been notified that their CDLs will no longer meet federal standards and will expire within a set period.
For carriers that rely on non-domiciled drivers, especially in California, this is a critical moment to recheck licenses, documentation, and monitoring processes.
As of September 29, 2025, the Federal Motor Carrier Safety Administration (FMCSA) put new restrictions in place for non-domiciled commercial driver’s licenses (CDLs) and permits (CLPs) — licenses issued to individuals whose permanent home is outside the United States.
The rule significantly tightens eligibility and renewal requirements, creating new challenges for drivers who are not U.S. citizens or permanent residents and the fleets that employ them.
Under federal rules, when a state issues a non-domiciled CDL, it must:
Verify the driver’s lawful presence using unexpired documents (such as an Employment Authorization Document or a foreign passport with I-94).
Make sure the CDL does not extend beyond the expiration date of those documents.
Follow specific rules when issuing to certain foreign nationals.
In short: the CDL and the immigration/work-authorization timeline must always match and align under the updated federal framework.
FMCSA’s annual review of California’s non-domiciled CDL program uncovered multiple issues, including:
CDLs that remained valid past the expiration of the driver’s work authorization.
Inadequate verification of immigration status.
System gaps that allowed improper issuance or renewal of limited-term CDLs.
When FMCSA dug deeper into a sample of recent non-domiciled CDL records, it found a significant share that did not comply with federal standards. Regulators then pushed California to address these issues, resulting in the revocation of about 17,000 non-domiciled CDLs.
USDOT has also put federal funding on the line, signaling that sustained non-compliance could jeopardize tens of millions of dollars in highway safety funds. Even beyond California, FMCSA has been scrutinizing non-domiciled CDL programs in multiple states.
The message to states and fleets is clear: non-domiciled CDL compliance is now a high-priority enforcement area.
This enforcement action primarily impacts:
Drivers With California Non-Domiciled CDLs
Drivers who hold a California non-domiciled CDL and received a notice from DMV are directly affected. Once those licenses expire or are deemed out of compliance, they cannot be used to legally operate a commercial motor vehicle (CMV).
Fleets Employing Non-Domiciled Drivers in California
Carriers employing these drivers may face immediate operational and compliance risk. Dispatching a driver with an invalid CDL can lead to violations, out-of-service orders, and liability exposure in the event of a crash or audit.
Multi-State Fleets
Even if your fleet isn’t based in California, FMCSA’s actions there are a warning sign. If you rely on non-domiciled drivers licensed in any state, you should assume regulators may expand their reviews and tighten expectations.
If you employ non-domiciled drivers — especially those licensed in California — here’s what to do now:
Identify All Non-Domiciled CDL Holders: Many fleets begin by reviewing their current driver rosters and identifying:
Those with California CDLs, and
Any CDL noted as non-domiciled, limited term, or tied to temporary lawful presence.
Note the issuing state and expiration dates for each driver.
Request Driver Notices and Update Files: Fleets may choose to confirm whether affected drivers have received any DMV notice about their CDL. Keep a copy of these letters in the Driver Qualification File (DQF) and record any new expiration or disqualification dates.
Learn more about everything that goes into creating a compliant DQF.
Pull Fresh MVRs and Enable Continuous Monitoring: For impacted drivers, some fleets opt to obtain updated MVRs and use continuous monitoring so they are alerted quickly if a license is suspended, revoked, or expires. Depending solely on annual MVR pulls can increase the chance that a status change goes unnoticed.
Learn why continuous MVR Monitoring isn't optional for employers in 2025.
Build a Coverage Plan: If a portion of your California driver pool loses CDL eligibility, some operations teams plan for alternatives, such as:
Identify backup drivers or reroutes now.
Prioritize key lanes and customer commitments.
Coordinate with recruiting to proactively fill gaps rather than reacting in crisis mode.
Beyond immediate triage, this situation is a chance to strengthen long-term compliance practices.
Tie CDL Tracking to Work Authorization
Some fleets track both CDL expiration dates and work-authorization documentation timelines to help identify gaps early.
Set internal reminders for both timelines so you can validate updated documents before they lapse, not after.
Tighten DQF Management
DQFs typically include:
Which drivers are non-domiciled.
Current copies of licenses and any required supporting documents.
Dates of your last review and any follow-up actions.
Centralized, organized files are crucial during an audit — and they make it easier to spot problems earlier.
Standardize Hiring & Screening
Recruiting and HR teams may benefit from guidance on:
Recognizing non-domiciled CDL situations during application and onboarding.
Escalating complex cases to compliance, rather than making ad-hoc decisions.
Avoiding giving immigration advice, while still ensuring work authorization documentation is properly collected and reviewed.
Learn how leading fleets are overcoming the most prevalent hiring and onboarding challenges.
Strengthen English Language Proficiency (ELP) Practices
FMCSA is also focused on English Language Proficiency requirements. Hiring and training processes often include steps to confirm that drivers can:
Read and understand traffic signs and signals.
Communicate with enforcement officers.
Complete required reports and records.
Document your evaluations and any remedial training efforts.
Regulatory expectations are shifting quickly, but your fleet still has freight to move. Foley's all-in-one compliance platform can help you:
Centralize DQFs, track key expirations, and keep files audit-ready.
Monitor licenses continuously with near-real-time alerts for suspensions, revocations, and expirations.
Streamline hiring and onboarding while embedding compliance checks into your workflows.
The revocation of 17,000 non-domiciled CDLs in California is more than a local news story — it’s a signal that FMCSA expects tighter controls, better documentation, and proactive monitoring from both states and fleets.
Now is the time to:
Know exactly which drivers in your fleet hold non-domiciled CDLs,
Strengthen your document tracking and MVR monitoring, and
Put systems in place so regulatory changes don’t catch you off guard.
If you’d like support evaluating your current risk and building a monitoring strategy that fits your operation, Foley is ready to help. Speak with a compliance specialist today.