Qualified Driver or Qualified on Paper? What FMCSA’s ELDT Crackdown Means for Motor Carriers
FMCSA’s recent enforcement actions against Entry-LevelDriver Training (ELDT) providers have renewed attention on an importantquestion for motor carriers: Does having a CDL necessarily mean a driver isfully qualified to operate safely for your business?
FMCSA recently removed more than 110 ELDT providers from itsTraining Provider Registry after connecting roadside inspection data involvingEnglish-language proficiency violations back to the schools that certifiedthose drivers. The agency has also identified more than 160 additionalproviders for potential removal or further action and launched a nationwideaudit of third-party CDL skills testers.
These enforcement actions are about more than removingtraining providers from the registry. They highlight a broader issue for thetrucking industry: Meeting minimum requirements on paper does not eliminate acarrier’s responsibility to properly qualify the drivers operating under itsauthority.
How Did Commercial Driver Training Get Here?
There was a time when trucking did not have the CommercialDriver’s License (CDL) system we know today.
Congress passed the Commercial Motor Vehicle Safety Act in1986, establishing minimum national standards for commercial driver licensing.By April 1, 1992, drivers of covered commercial motor vehicles were required tohave a CDL.
Before that standardized system, licensing requirements werelargely left to individual states. Drivers could hold chauffeur’s licenses orother state-specific credentials, and some experienced drivers weregrandfathered into the new system without completing the same testing requiredof new applicants.
The next major shift came with the federal Entry-LevelDriver Training requirements, which took effect in February 2022.
What Are the FMCSA ELDT Requirements?
FMCSA’s Entry-Level Driver Training requirements establishedminimum training standards for drivers seeking certain commercial drivingcredentials, including a first Class A or Class B CDL, an upgrade from a ClassB to Class A CDL, or certain endorsements.
The goal was to create greater consistency in how newcommercial drivers were trained before becoming licensed.
However, the system also relied heavily on trainingproviders to self-certify that they met applicable federal requirements to belisted in FMCSA’s Training Provider Registry.
ELDT also took effect during a period of significant growthand change in the trucking industry. Increased interest in entering theindustry drove greater demand for commercial driver training, making effectiveoversight of training providers especially important.
FMCSA’s recent enforcement actions demonstrate what canhappen when weaknesses within that system are identified.
But training is only one piece of the driver qualificationpuzzle.
A CDL Is Only One Part of Driver Qualification
ELDT compliance, holding a CDL, and being qualified to drivefor a motor carrier are related, but they are not the same thing.
ELDT establishes minimum training requirements for certaindrivers entering the industry or obtaining new commercial driving credentials.
A CDL demonstrates that a driver has met applicablelicensing requirements.
Federal regulations establish minimum qualifications forcommercial motor vehicle drivers.
But being qualified on paper is not enough. Motor carriers mustensure that the drivers operating under their authority not only meet federalrequirements but are also genuinely qualified to operate safely and act in thebest interests of both the company and the public. Making that determination requiresadditional due diligence and investigation.
The moment a driver begins operating under your authority,their performance on the road can create exposure for your business. That makesdriver qualification more than just checking off compliance boxes. It is anongoing component of safety and risk management.
What Should Motor Carriers Pay Special Attention to When Hiring Drivers?
The hiring process is when a motor carrier has the greatestcontrol over driver selection. A thorough hiring and qualification process is aproactive form of risk mitigation and one of the best ways to protect yourcompany in the event of a large claim. It is imperative not to cut corners inthis area.
Bare-minimum compliance is not enough to mitigate yourexposure. When vetting a driver, look closely at the applicant’s drivinghistory because past behavior is one of the best indicators of futureperformance. Know the risk you may be bringing into your operation.
Make sure the application is complete and includes thedriver’s full work history. Take the time to request and carefully reviewverifications of previous employment (VOEs). These records often provideinformation that may not appear on a motor vehicle record (MVR), includingaccidents or termination for safety-related issues. Give serious considerationto any significant moving violations listed on the MVR, because certainviolations are much more likely to predict a future crash.
One of my favorite, and lesser-known ways to vet a driver isto run a Pre-Employment Screening Program (PSP) report. PSP reports are notrequired by FMCSA regulations, but they give motor carriers access to acommercial driver’s last three years of roadside inspection history and lastfive years of DOT-recordable crashes. Many violations that truck driversreceive on the road do not appear on their MVRs. An MVR will not tell youwhether someone consistently performs pre-trip inspections or is prone to hours-of-serviceviolations. A driver with a history of poor roadside inspections is at greaterrisk of a crash and likely to bring those same habits to your company that willharm your safety scores. Crashes and Safety Measurement System (SMS) scores aremajor factors that underwriters consider when calculating insurance premiums.
Carriers should also consider what their safety data,operating environment, equipment, and insurance programs reveal about the typeof driver best suited to their operation.
In my work with trucking companies, my role extends beyondreviewing what has already gone wrong. I help identify where exposure existsbefore it develops into an expensive claim, violation, preventable crash, or higherinsurance premium.
How Driver Qualification Can Affect Safety and Insurance Risk
If you think hiring a good driver is expensive, wait untilyou hire the wrong one.
Poor driver qualification practices can increase a carrier’sexposure to roadside violations, out-of-service events, failed loads, equipmentdamage, preventable crashes, and costly insurance claims. The consequencesextend well beyond the individual driver: They can affect a carrier’s safetyrecord, operating costs, reputation, and insurance premiums.
Insurance is already one of the largest expenses manytrucking companies face. While carriers cannot eliminate every risk associatedwith operating a commercial fleet, there are ways to mitigate it proactively.
That is why doing your due diligence before a driveroperates under your authority is so important.
Carriers should continue reviewing safety data, identifyingtrends in driver performance, and strengthening policies and procedures whengaps emerge.
Stronger Driver Qualification Starts with Due Diligence
FMCSA’s increased scrutiny of ELDT providers is an importantreminder that regulatory compliance is only one layer of protecting a truckingbusiness.
Government agencies, training providers, testingorganizations, motor carriers, and drivers each play a distinct role in creating a safer trucking industry. Forcarriers, that means understanding the requirements that apply to theiroperation and developing processes that identify potential risks before theybecome violations, crashes, or costly losses.
At Marquee Insurance Group, our role goes beyond looking atwhat has already gone wrong. We work with motor carriers to identify whereexposure exists before it turns into a claim.
That work can include taking a closer look at driverqualification processes, reviewing safety data, identifying trends, andstrengthening policies and procedures.
No process can eliminate every risk that comes withoperating a trucking company. But carriers can identify the risks within theircontrol and put stronger safeguards around them.
Good risk management isn’t about checking a box becausesomeone told you to. It’s about protecting your drivers, your equipment, yourbusiness, and your livelihood.
About the Author
Antonette Nordlund, CDS is the Fleet & Safety Advisor at Marquee Insurance Group, where she works with motor carriers to identify risk, strengthen safety practices, and better understand how operational decisions can affect their commercial insurance exposure.
Recommended Sources & References
FMCSA— Entry-Level Driver Training (ELDT)
FMCSA — TrainingProvider Registry
FMCSA— Driver Qualification / 49 CFR Part 391
FMCSA— 2026 ELDT Enforcement Action
FMCSA— Commercial Driver’s License Program
