The long and winding road to digital med cards, or Federal Motor Carrier Safety Administration (FMCSA) Medical Examiner’s Certification Integration Rule / Rule II / National Registry II (NRII), has been notoriously bumpy.
If you’re a commercial driver, a fleet manager, or anyone dealing with DOT compliance, you’ve probably heard about this transition – potentially since the rule was first proposed about a decade ago.
While NRII officially went into effect June 23, 2025, a temporary waiver had been in place from July 14 - October 12, 2025, which permitted interstate CDL and CLP holders, as well as motor carriers, to use a paper copy of the medical certificate as valid proof of medical certification.
As of Oct. 13, 2025, the Federal Motor Carrier Safety Administration (FMCSA) reissued its temporary waiver allowing the use of paper medical examiner’s certificates for up to 60 days after issuance. The reissued waiver is effective Oct. 13, 2025, through Jan. 10, 2026, meaning paper med cards will still be accepted through that date.
What is the Certification Integration Rule?
The FMCSA Medical Examiner’s Certification Integration rule covers how commercial drivers’ medical certification information is collected, stored, and shared. Before the rule went into effect, drivers with commercial learner permits (CLPs) or commercial driver’s licenses (CDLs) were required to provide a paper copy of their Medical Examiner’s Certificate (MEC) to their state’s driver licensing agency. This certificate, often referred to as a med card or med cert, confirms that they are physically qualified to drive a commercial motor vehicle.
Under the new rule, the FMCSA required certified medical examiners to send the results of the DOT medical exam directly to the National Registry of Certified Medical Examiners. And the FMCSA was then responsible for electronically transmitting those results to state licensing agencies. However, CDL drivers still had to carry and present paper medical cards until full integration.
This digital system was initially proposed to go live in 2018; however, due to technical and security issues with the FMCSA’s IT system, it was pushed back to June 2025.
RULE II / NATIONAL REGISTRY II (NRII)
National Registry II – often called Rule II or NRII, was the next step in the process, which set the final compliance date of June 23, 2025, to eliminate reliance on paper cards entirely and enforce daily electronic integration.
Under Rule II, the FMCSA requires certified medical examiners to send the results of the DOT medical exam directly to the National Registry of Certified Medical Examiners by the next calendar day. The FMCSA is then responsible for electronically transmitting those results to state licensing agencies through upgraded NRII systems, eliminating the need for drivers to submit paper certificates themselves.
This means that employers must rely solely on MVR checks to confirm CDL driver medical certification, and the physical med card is no longer acceptable for CDL compliance. MVR is the sole source of truth.
I've heard this FMCSA rule was delayed. What does this mean?
This digital system was initially proposed to go live in 2018; however, due to technical and security issues with the FMCSA’s IT system, it was pushed back to June 2025 under an updated Rule II. The current waiver allows the use of paper medical examiner’s certificates for up to 60 days after issuance. The waiver is effective through Jan. 10, 2026.
However, it's important to note that some states have not yet started implementing the new process. The FMCSA website provides more details on these states.
What happens now?
Medical examiners in states that have implemented the digital process should electronically submit results directly to the FMCSA. The FMCSA will forward those results to state licensing agencies. Drivers will no longer need to submit their own medical certificates. However, if the digital med card isn't on file, a paper med card is permissible through the effective waiver date.
What does this change mean for me?
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For CDL Drivers: Failing to keep a valid medical card on file with your state licensing agency means your CDL could be downgraded, putting your job at risk. Your DQF must contain the MVR showing valid medical certification, or a copy of the paper med card during the transition period.
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For Non-CDL Drivers: Non-CDL drivers continue to receive, carry, and present paper medical cards issued by their Certified Medical Examiner.
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For Fleet Managers: Not tracking medical certification properly could lead to DOT compliance violations and fines of up to $20,000.
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What You Should Do with DOT Medical Certificates Now
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Drivers: Make sure your medical certification is up to date. Double-check to ensure the new system is in place in your state. If you operate across various states with potentially different requirements, it’s best to be safe and continue the hybrid system, keeping both a paper med card and a digital file in your DQF.
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Carriers: Keep verifying medical certificates. Ensure your drivers have valid medical certifications from a registered examiner. Employers in participating states may rely on MVR checks to confirm CDL driver medical certification, or must have a copy of the paper med card in the DQF.
Stay Updated: Both drivers and carriers should stay informed about FMCSA announcements. Since this rule has been delayed multiple times, there’s always a chance of further changes. Keeping up to date will help you avoid compliance headaches.
Foley's DOT compliance platform, notifies you of medical certificate expirations with sufficient time to schedule DOT physicals and get new med cards for your drivers. Get your free demo now to help ensure your fleet is in compliance.
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