The Impact of CLP and CDL Eligibility Rules on the Trucking Industry

The trucking industry is the backbone of America’s economy, carrying the essential goods that keep our shelves stocked and our communities thriving. But a powerful new rule has just shaken up the way truck drivers qualify for their licenses — especially for those who aren’t permanent U.S. residents or citizens. This change targets the non-domiciled commercial learner’s permits (CLPs) and commercial driver’s licenses (CDLs), licenses that allowed some drivers who lived outside the United States to operate commercial trucks inside it.

This blog will break down, in simple but detailed terms:

• What “non-domiciled CLP/CDL” means
• The new FMCSA restrictions on eligibility
• Why these changes matter profoundly for trucking businesses and freight markets
• The ripple effects across logistics and supply chains
• What carriers, drivers, and regulators should do to adapt

1. What Does “Non-Domiciled” Mean?

A CDL is a special license you need to drive large trucks. A CLP is a training permit for learning before you get a full CDL. Domicile means your legal home or where you are based. A non-domiciled CDL/CLP is a license issued to someone who lives elsewhere—often outside the U.S.—but who needs to drive commercial vehicles inside the country.

For years, states permitted certain non-U.S. residents, including some temporary workers and other visa holders, to get these licenses. This “non-domiciled” option allowed a degree of flexibility for international drivers legally authorized to work in the U.S. freight system.

2. What’s Changing: The New FMCSA Restrictions

In September 2025, the Federal Motor Carrier Safety Administration (FMCSA) issued an Interim Final Rule (IFR) that greatly tightens rules on non-domiciled CLP/CDL issuance and renewal:

• Stricter Eligibility: Only non-U.S. citizens holding specific employment-based visas (H-2A, H-2B, E-2) can obtain or renew these licenses. Many others, including holders of Employment Authorization Documents (EADs), Deferred Action (DACA) recipients, asylum seekers, and refugees, are now ineligible.

• Verification Requirements: Applicants must present an unexpired foreign passport and valid Form I-94/I-94A every time they apply, renew, or upgrade their CDL/CLP. EADs alone are insufficient.

• In-Person Renewals: Online or mail renewals are banned for non-domiciled license holders. Each renewal requires the driver’s physical presence with the necessary documents.

• License Expiration Alignment: The CDL or CLP expiration date must match the I-94/I-94A expiration or be limited to one year—whichever is shorter.

• State Compliance and Revocation: States must pause issuing non-domiciled licenses until compliant with the new rule. States are required to revoke any licenses previously issued without following the stricter guidelines.

• Labeling: All non-domiciled licenses must be clearly marked "Non-Domiciled”.

These measures came after FMCSA investigations uncovered systemic violations by states issuing these licenses and several tragic crashes linked to non-compliant non-domiciled drivers.

3. Why These Changes Matter to the Trucking Industry

Driver Supply Shrinks

There are approximately 200,000 non-domiciled CDL holders and 20,000 CLP holders in the U.S. Many will be unable to renew under the new criteria, potentially causing a major driver exodus over the next two years.

Operational Disruptions

Companies that relied heavily on non-domiciled drivers face route restructuring, idle assets, and increased costs for recruiting and training domestic or visa-qualified drivers.

Market Pricing and Capacity Impact

Fewer eligible drivers inflate freight costs, especially in corridors that depended on cross-border or foreign-based drivers. This shortage threatens to slow deliveries and increase consumer prices.

Geographic and Lane Imbalances

Border states and international freight lanes will see the hardest hits, with potential reductions in cross-border freight movement capacity.

Compliance and Legal Risks

Carriers using drivers with revoked or invalid licenses face severe liability. State licensing agencies must overhaul procedures, heightening administrative burdens.

Broader Social and Workforce Effects

Many affected drivers are immigrants with legal work authorization. The rule restricts their ability to work, impacting families and the diversity of the trucking workforce.

4. What This Looks Like on the Ground

• Reports of drivers, including those under DACA, being denied renewals despite long driving tenure.
• Freight operators warning of capacity crunches, especially in dry van markets.
• California singled out by DOT for lax oversight, facing federal funding risks if non-compliance continues.

5. The Bigger Picture: Emerging Trends and Regulatory Shifts

This rule is a prime example of regulatory tightening that reshapes trucking’s workforce and operational landscape. It highlights:

• The interplay of safety, security, and national interest with economic efficiency.
• The growing emphasis on immigration and employment verification in licensing.
• The need for carriers to pivot towards domestic driver recruitment and credential management.

6. What Trucking Companies, Drivers, and Regulators Should Do Now

For Carriers:

• Audit your driver roster for non-domiciled CDL holders and renewal dates.
• Develop contingency plans including cross-training domestic drivers.
• Boost recruitment, training, and retention efforts for eligible drivers.
• Implement strict compliance checks on driver credentials.

For Drivers:

• Understand if your visa or status qualifies under the new rules.
• Prepare for in-person renewals with full documentation.
• Explore pathways to lawful permanent residence or citizenship for stability.

For State Licensing Agencies:

• Pause issuing non-domiciled licenses until fully compliant.
• Review and revoke invalid non-domiciled licenses immediately.
• Upgrade systems to verify immigration status via SAVE.
• Communicate clearly with license applicants about changes.

For Industry Groups:

• Provide guidance and support to carriers and drivers.
• Engage regulators for transitional policies.
• Monitor FMCSA rulemaking and comment actively.

For Shippers and Planners:

• Anticipate rising freight costs and capacity constraints.
• Build flexibility into logistics schedules and budgets.

7. Trucking’s Relay Race Has a New Starting Line

Think of the trucking industry as a big relay race. Drivers from all over had different starting points, thanks to non-domiciled licensing. Now, many of those drivers have been moved back or sidelined, sharply reducing the number eligible to run the race. This means slower logistics, tighter driver markets, and a tough adjustment for the industry. As trucking navigates this new landscape of stricter driver credentialing, safety, and immigration enforcement, businesses, drivers, and shippers must adapt quickly to keep America moving.