FMCSA Orders California to Revoke 17,000 CDLs Over Compliance Failures
Nathaniel Miller, Special Advisor to SambaSafety
The Federal Motor Carrier Safety Administration (FMCSA) has directed California to revoke approximately 17,000 non-domiciled commercial driver’s licenses following a federal review that uncovered widespread failures in the state’s commercial driver’s license (CDL) program. Inadequate identity verification practices, improper validation of lawful presence, and the dismissal of commercial licensing standards are nothing short of systemic failures that have led to the revocation of these licenses.
The agency initiated this action under the US Code of Federal Regulations (CFR) § 384.307, which allows the FMCSA to conduct a federal review of CDL law compliance when a state fails to comply with the requirements.
Another 24,000 licenses remain under review. This could bring the total affected licenses to 41,000, a significant share of California’s non-domiciled CDL records, based on available state and federal data.
FMCSA Audit Findings Triggered Federal Action
The FMCSA audit identified multiple inconsistencies in California’s handling of CDLs for foreign nationals lawfully present in the US under temporary work authorization. The review found:
- Inadequate verification of lawful presence and identity documentation
- License validity periods are misaligned with employment authorization timelines
- Gaps in the state’s testing and validation process related to English-language proficiency, which is required for drivers under 49 CFR §391.11(b)(2)
- Broader non-compliance with federal CDL standards outlined in 49 CFR Parts 383 and 384
States are required to verify the identity, lawful presence, and eligibility of every driver before issuing commercial licenses. When states fail to meet these requirements, the FMCSA is allowed to order corrective action. This can include suspending and revoking licenses or retesting drivers.
The Scale of Impact and Who’s Affected
California is the first state in recent years to undergo a federal CDL program review, resulting in large-scale revocations of this magnitude. Industry analysts expect that similar federal reviews could expand to other states, particularly where non-domiciled CDL processes resemble those in California. Industry experts have indicated that not every driver will face immediate operational suspension. However, every impacted license must be verified, and fleets must confirm that drivers comply with federal and state requirements.
A Pattern of Federal Enforcement Intensifies
The FMCSA’s actions are not new to California. The state has faced similar disruptions to its CDL program in the past. In April 2022, the California DMV strengthened its process for matching medical examiners’ certificates to CDL records electronically. Although the rule itself was not new, California began enforcing its program more strictly. Now, CDLs automatically downgrade when a medical certificate cannot be matched in the Commercial Driver’s License Information System (CDLIS).
Many fleets assumed this was a minor administrative update. Instead, it created unexpected operational challenges.
A regional fleet in California experienced the impact when a driver reported that his CDL had been downgraded to a non-commercial class, despite submitting his medical certificate on time. The fleet checked the record and found the downgrade had happened three days earlier. The DMV was unable to match the certificate to the driver’s CDL record.
This small discrepancy produced a larger ripple where the carrier subsequently identified two additional drivers facing similar downgrades—issues that surfaced only through manual review after the fact.
No routes were canceled, and no customers were lost; however, the disruption was real, unnecessary, and completely preventable. The gap between a regulatory change and a fleet’s ability to spot its impact is important. The FMCSA's revocation in California highlights this issue.
React or Be Ready: How the Industry is Responding
Events like California’s revocation and the recent non-domiciled CDL action reveal which fleets are prepared for rapid compliance shifts. They also show which fleets rely on reacting after the fact.
High-performing fleets exhibit a consistently different pattern. Their smooth response has nothing to do with luck. It is the result of disciplined daily habits that ensure clarity long before a disruption occurs.
Safety teams begin the day with structured verification, including licensing status, medical timelines, endorsements, violations, lawful presence indicators, and any new information that may impact driver eligibility. Supervisors receive only exceptions. Dispatch sees readiness before assignment. Leaders receive concise updates without asking.
This is operational maturity.
Less-prepared fleets often discover compliance problems only when drivers self-report or during urgent audits. This leads to delays and issues that escalate to the leadership level. Every fleet should reassess its readiness after the recent CDL revocation. The most resilient fleets should:
- Revalidate all driver data, including CDL status and work authorization documentation.
- Establish centralized communication channels for compliance information.
- Expand monitoring beyond licensing. Include violations, equipment compliance, and documentation alignment.
- Conduct tabletop exercises simulating regulatory disruptions.
This is how fleets prevent operational surprises and move from reactive compliance to proactive readiness. As federal directives may expand into other states, it is imperative for fleets and their insurers to remain adaptable by being ready for changes.
Building Organizational Readiness Beyond Compliance
Industry leaders note the revocations showcase a deeper issue: whether they have the infrastructure and discipline to understand their exposure before it becomes a disruption.
For emerging safety leaders, the moment offers a significant lesson. Effective leadership doesn’t require memorizing every regulation. Success depends on building systems that make visibility simple, communication consistent, and action predictable.
Perfection is not required.
Discipline is.
Fleets that move through moments like this calmly aren’t fortunate. They’re prepared. And readiness is something every fleet can build starting now. Start with accurate data, clear workflows, and one shared definition of readiness. Those fundamentals will outlast any specific regulatory update.
| Prepared Fleet | Unprepared Fleet | |
| Visibility |
Daily verification of licenses, medical cards, violations, and lawful status; exceptions are identified automatically. |
Periodic checks, manual lookups, or reliance on driver self-reporting. |
| Records & Rosters |
Clean, reconciled, centralized, and continuously updated. |
Outdated, fragmented across teams; multiple versions of “the list.” |
| Communication Flow |
One source of truth for safety, operations, and dispatch |
Inconsistent communication; siloed understanding of readiness. |
| Response to Regulatory Change |
Immediate awareness of who may be affected and what action is required. |
Issues are discovered only after drivers report problems. |
| Operational Impact |
Minimal assignments are adjusted quickly with confidence. |
Delays, manual audits, uncertainty, and leadership escalation. |
| Driver Experience |
Clear expectations, proactive communication. |
Confusion, last-minute calls, and inconsistent messaging. |
| Leadership Confidence |
High; they receive accurate, timely insights. |
Low; they rely on reactive reports built under pressure. |
| Culture |
Proactive, disciplined, and system-driven. |
Reactive, dependent on individuals and tribal knowledge. |
About Nathaniel "Safety Nate" Miller
Nathaniel "Safety Nate" Miller is the founder and CEO of Ascent Advisory Group, LLC, and one of the nation’s leading voices in safety, risk, and organizational resilience. With nearly 25 years of executive experience in EHS, risk management, and business continuity, he is known for transforming culture, building high-reliability systems, and aligning safety strategy with business performance.
He has held senior leadership roles at Gordon Food Service, United Technologies, Schindler Elevator Company, and SCANA Energy. He is the author of Fix the Pond: Leadership That Prevents Failure, Protects People, and Builds Resilient Systems. A sought-after speaker and systems thinker, Nathaniel specializes in helping organizations simplify complexity, strengthen accountability, and build sustainable operational excellence.