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CA Employer Pull Notice (EPN) Program Explained

Written by Tiffany Houkom | Sep 14, 2026, 9:25:59 PM

If you employ commercial drivers in California, the state doesn't wait for you to run an annual check. The Employer Pull Notice (EPN) program is a California DMV requirement that automatically sends employers a notice any time an enrolled driver's license record changes: a new conviction, a crash, a license suspension, or another reportable action. The California Highway Patrol (CHP) enforces it, and it's mandatory for most commercial fleets.

Key Takeaways

  • California's DMV requires certain commercial drivers to enroll in the Employer Pull Notice program.
  • Enrolled employers get automatic notices whenever a covered driver's license record changes, not annually.
  • New regulations effective April 1, 2026 require EPN enrollment, records, and payments to go electronic.
  • Out-of-state drivers on your California roster still need to be enrolled in the EPN program.
  • CHP audits check whether EPNs were reviewed, signed, and stored appropriately for review.

Who Needs to Enroll in the EPN Program?

Enrollment is mandatory for any employer of a driver who:

  • Holds a Commercial Class A or Class B license.
  • Holds a Commercial Class C license with a hazmat, passenger, or tank vehicle endorsement.
  • Operates a charter passenger vehicle seating 10 or fewer people for compensation.
  • Drives for a passenger stage corporation under a California Public Utilities Commission certificate or permit.

The mandatory categories above cover most fleets, but California Vehicle Code Section 1808.1 extends enrollment further, to ambulance drivers, tow truck drivers, and school, youth, or farm labor vehicle drivers. If your fleet includes any of these less common vehicle types, it's worth confirming whether your drivers fall under the requirement.

Enrollment is optional for other driving employees, but many employers choose to enroll them anyway as a matter of policy. A narrower exception exists for "casual drivers," defined as anyone employed fewer than 30 days in the preceding six months. This exception doesn't apply to roles requiring a passenger transportation endorsement.

Casual drivers don't need full EPN enrollment. Before letting one drive, an employer must obtain a public record for that driver that's less than six months old. The employer must then review, sign, and date that record, and keep it on file.

How an EPN Differs From a Standard MVR Pull

An annual motor vehicle record (MVR) check tells you what a driver's record looked like on one specific day. EPN works differently. Once a driver is enrolled, the DMV pulls that driver's record and automatically sends a notice to the employer whenever something changes, which is why the document itself is often just called a DMV pull notice. That mechanism is what closes the gap between annual reviews.

EPNs also come in a distinct format from a standard state MVR, built around fields like driver record information, violation and crash detail, and any department actions taken against the license. Employers are required to review, sign, and retain each notice. As a practical matter, it's worth keeping the EPN in the format California actually sent, since a converted or reformatted version may not hold up as proof of review if CHP asks for it during an audit.

EPN Compliance Is Now Fully Electronic

For years, employers had a choice between an online EPN account and a paper-based process involving mailed forms and checks. That choice is gone. Under California Code of Regulations, Title 13, Section 350.47, effective April 1, 2026, employers enrolled in the EPN program must submit documents, request and receive driver records, and pay invoices electronically. Paper enrollment forms and mailed payments are no longer an accepted path.

For employers who were still managing EPN by mail, this is a meaningful operational shift. It also raises the stakes for keeping requester codes, driver rosters, and account details current, since a lapsed or misconfigured electronic account is now the only account there is. Whether that account is managed directly or with outside help, the electronic requirement applies either way.

Don't Forget Out-of-State Drivers

It's easy to assume EPN only applies to California-licensed drivers, but that's not the case. A driver licensed in another state who has no prior California record is still required to enroll and is assigned an index number, often called an X License, for tracking purposes. From that point on, any California-reported activity on that driver, along with any activity their home state reports back to California, becomes part of the record employers are expected to monitor.

What CHP Auditors Actually Check

A CHP audit isn't just confirming that EPN paperwork exists somewhere. Auditors typically want to see:

  • The most recent EPN on file for each enrolled driver, dated within the past 12 months.
  • Evidence that each notice was reviewed, signed, and dated by the employer.
  • The EPN kept in the format California sent, since a converted version may raise questions during review.
  • Enrollment records for out-of-state and non-mandated drivers the employer chose to include.

One narrow exception applies to drivers with a controlled or blocked record, most often due to identity protection concerns. These records can't be pulled electronically and must be requested by mail directly from the DMV. Because these drivers can't be monitored through the normal EPN process, CHP does not require the same enrollment documentation for them during an audit.

Where Manual EPN Management Gets Difficult

Employers can handle EPN two ways: manage the account directly through DMV's system, or authorize a DMV-approved EPN agent to do it for them. An agent is a third party approved to submit enrollments, request records, and manage the account on the employer's behalf.

Either way, the work adds up fast for any employer with more than a handful of CDL drivers. Every enrolled driver generates its own stream of notices. Each one has to be opened and reviewed in a format that doesn't look like a standard MVR. Then it needs to be signed and filed somewhere that will hold up if CHP asks for it during an audit.

Some employers manage this manually, keeping a shared folder of PDFs and a spreadsheet of review dates. Others fold EPN review into the same process they already use for continuous driver monitoring, so notices get viewed, acknowledged, and archived alongside the rest of a driver's record instead of living in a separate system. Either approach can satisfy an audit. The difference tends to show up in how much time it takes to get there.

EPN keeps you compliant in California, but it only covers one state and one part of your risk exposure. For a closer look at how continuous MVR, CSA, and telematics monitoring work together to close the gaps that annual reviews leave behind, download our continuous monitoring guide.