Commercial trucks move the American economy every day, carrying goods across local streets and interstate corridors alike. The commercial driver’s license (CDL) system ensures that only qualified, properly screened drivers are entrusted with this responsibility. When that system works as intended, it protects the trucking industry and everyone who shares the road.
In this study, at Bader Law Injury Lawyers, we examine how commercial driver’s licenses have been issued to drivers who should not have qualified under federal or state safety standards, and what that means for public safety.
Using a wide range of data sets, we examined where CDL licensing oversight failed and how unsafe or improperly qualified drivers remained legally licensed, despite disqualifying conditions.
We explain how breakdowns in the CDL system can place unsafe commercial drivers behind the wheel legally and why that matters to everyone on the road.
The Stakes: Why CDL Integrity Is a Public Safety Issue
Based on our review of statistical data provided by the U.S. Department of Transportation Office of Inspector General, in 2024, 4,909 people were killed in crashes involving large trucks and buses.
The year before, 5,472 people died in large-truck crashes, a figure that remains historically high even after an 8% decline from 2022, based on our analysis of data by the U.S. Department of Transportation and NHTSA. Federal data consistently show that about 70% of people killed in large-truck crashes are occupants of other vehicles, not the truck drivers themselves.
When something goes wrong with a heavy commercial vehicle, the risk is disproportionately borne by the public. The size and weight make even low-speed errors far more severe when a tractor-trailer or heavy straight truck is involved.
Where Crashes Occur
The location and time of these incidents further illustrate public risk. In 2023, 75% of fatal large–truck crashes occurred on non–interstate roads, not high-speed freeways.
These are arterial roads, local corridors, and commuter routes where passenger vehicles, delivery trucks, pedestrians, cyclists, and school traffic mix closely.
Interstate highways, despite their higher speeds, account for only about a quarter of fatal truck crashes. This pattern underscores that CDL integrity is not an abstract regulatory issue; it affects everyday driving environments.
Timing compounds the exposure risk. 76% of fatal large–truck crashes occur on weekdays, during the same hours when most people commute, run errands, or transport children. These are not isolated overnight incidents; they happen when roads are busiest, and consequences ripple outward.
How the CDL System Is Supposed to Work
The commercial driver’s license standardizes safety across states for operators of heavy and complex vehicles. A CDL is required for drivers operating vehicles over specific weight thresholds, carrying hazardous materials, or transporting multiple passengers.
Unlike a standard driver’s license, a CDL carries higher entry barriers and stricter ongoing requirements. In theory, the CDL system is layered: licensing, training oversight, medical certification, and roadside enforcement all reinforce one another. When each layer functions correctly, unqualified drivers are filtered out before they can operate large commercial vehicles.
The analysis conducted by our Bader Law Injury Lawyers team focuses on what happens when those layers fail (or fail to communicate), creating gaps that allow unqualified drivers onto the road.
Qualification Requirements
To qualify for a CDL, drivers must pass knowledge and skills tests, meet medical standards, and avoid disqualifying offenses.
Certain violations (such as driving under the influence or leaving the scene of a crash) can result in suspension, revocation, or permanent disqualification. Federal rules also require entry-level driver training (ELDT) from approved providers prior to testing.
Domiciled vs. Non-Domiciled Licenses
There are two primary categories of CDLs: domiciled and non-domiciled. Domiciled CDLs are issued to U.S. citizens and lawful permanent residents.
Non-domiciled CDLs may be issued to certain foreign nationals who are lawfully present and authorized to work in the United States for a limited period. These licenses are intended to be temporary and must not extend beyond the driver’s authorized stay.
The Role of Verification
Verification is the linchpin of the CDL system. States are required to confirm identity, lawful presence, work authorization duration, and testing integrity.
For non-domiciled CDLs, this includes reviewing documents such as an unexpired foreign passport, an approved CBP I-94 Arrival/Departure Record, and valid employment authorization. If the authorization expires, the CDL should expire in tandem.
Where Licensing Breaks Down
Our review of audits, enforcement actions, and court records reveals that CDL failures rarely stem from a single point of collapse. Instead, they emerge from recurring patterns across verification, testing, training, and enforcement.
Audit “failure rates” are often misinterpreted as indictments of individual drivers. They are not. Instead, these figures measure process breakdowns (including missing verification steps, misaligned expiration logic, and inconsistent oversight). Many drivers were eligible at the time of issuance but remained licensed after their circumstances changed.
What matters most is the duration of exposure. Each improperly issued or extended license represents months or years during which oversight mechanisms did not function as designed. It is this persistence, rather than the initial error alone, that accumulates risk and creates potential hazards for other road users.
Verification Failures: Non-Domiciled CDLs
One of the most persistent issues involves non–domiciled CDL verification. Audits repeatedly show states issuing licenses without properly confirming lawful presence or aligning license expiration with work authorization. In practice, this has meant eight-year CDLs issued to drivers whose legal work authorization was valid for only a fraction of that time.
Licenses that remain valid after a driver’s authorization expires undermine the core principle of conditional eligibility and illustrate how administrative compliance gaps can persist quietly. Under these conditions, drivers can operate legally for extended periods despite incomplete eligibility.
Testing Integrity Failures
In Massachusetts, former state police sergeant Gary Cederquist was convicted on nearly 50 charges for participating in a bribery scheme that exchanged passing CDL scores for gifts and favors.
Between 2019 and 2023, at least 17 drivers received fraudulent passes, facilitated by falsified records. This case is particularly concerning because under normal conditions, most applicants fail the CDL test, with Massachusetts reporting a pass rate of just 41% in 2022.
Training Oversight Failures
Even when testing remains valid, gaps in training can weaken overall safety outcomes. The Federal Motor Carrier Safety Administration (FMCSA) has removed nearly 3,000 CDL training providers from the Training Provider Registry (TPR) for inactivity or noncompliance.
According to our interpretation of data provided by the American Association of Motor Vehicle Administrators (AAMVA), another 4,000 providers were placed on notice for failing to meet Entry-Level Driver Training (ELDT) standards.
Drivers who complete instruction through noncompliant programs may hold technically valid licenses while lacking the required instruction, creating another layer of potential risk.
Roadside Enforcement and Administrative Failures
Data from enforcement actions underscores how administrative weaknesses translate to real-world exposure. Citations and Out-of-Service (OOS) orders increasingly involve drivers whose license status is suspended, revoked, expired, or improperly documented.
Many of these issues arise from non-driving-related reasons, such as failure to upload a Medical Examiner’s Certificate or other paperwork lapses. While these administrative failures do not necessarily indicate unsafe driving, they expose gaps in real-time compliance tracking.
Audit Evidence: What States Found
State and federal audits provide the clearest window into how widespread CDL licensing issues have become. Across multiple jurisdictions, investigators uncovered strikingly similar failure rates, suggesting structural problems rather than isolated mistakes.
North Carolina: Non-Domiciled Licenses Under Scrutiny
In North Carolina, Transportation Secretary Sean Duffy revealed that 54% of reviewed non-domiciled CDLs issued to foreign nationals were illegally issued. Federal auditors found missing or unverified lawful presence documentation in more than half of the cases examined.
New York: FMCSA Audit Highlights Gaps
A Federal Motor Carrier Safety Administration (FMCSA) audit in New York uncovered a 53% failure rate among sampled non-domiciled CDL records. Licenses had been issued without verified lawful presence, a direct violation of federal regulations.
Texas: Small Sample, Large Exposure
In Texas, auditors reviewed 123 CDLs issued to foreign temporary workers and found 49% were improperly issued. This prompted the revocation of roughly 6,400 licenses, demonstrating that even a small audit sample can reveal significant statewide exposure.
California: Widespread Compliance Failures
According to our analysis of the AP News report, California’s audit findings were similarly consequential. More than one in four non-domiciled CDL records sampled failed to comply with federal regulations, including licenses that extended beyond the driver’s authorized stay.
In response, state officials announced plans to revoke 17,000 commercial driver’s licenses issued with improper expiration dates.
The Crash Lens: Where Fatal CDL Crashes Concentrate
To understand how licensing compliance intersects with real-world outcomes, we examined fatal crash data involving CDL-required vehicles from 2019 through 2023. Using federal criteria that exclude buses and focus on vehicles weighing 26,001 pounds or more, we identified 15,753 fatal crashes nationwide.
Geographically, these crashes are not evenly distributed. Texas leads with 2,123 fatal CDL crashes, followed by California (1,146), Florida (947), and Georgia (677).
These states combine large populations, major freight corridors, and high exposure—not necessarily higher fault rates, but greater interaction between commercial and passenger traffic.
We also examined fatal crashes involving drivers who lacked a proper license status at the time of the crash. From 2019 to 2023, 70 fatal crashes fell into this category. The numbers are small relative to the total, but they represent instances where licensing compliance and fatal outcomes intersected directly. States such as Colorado, Ohio, Oregon, and California appear repeatedly in this subset.
These figures do not establish causation. They do, however, illustrate a risk surface: when license status problems exist, they can and do appear in fatal crash records.
Combined with the finding that most fatal truck crashes occur on non-interstate roads, the data underscore how licensing integrity failures can translate into everyday safety exposure.
English Proficiency Enforcement: A Flashpoint
Enforcement of English language proficiency (ELP) has become one of the most visible developments in commercial driver oversight in recent years. Federal regulations require CDL holders to understand and communicate in English at a level sufficient to follow traffic signs, respond to roadside instructions, and complete safety documentation.
Based on our review of licensing demographics provided by Max Dispatch Service, approximately 3.8% of CDL holders (roughly 130,000 to 140,000 drivers) are classified as limited English proficient. These drivers may not meet federal communication standards.
By contrast, the vast majority, about 96% of U.S. CDL drivers, satisfy the English proficiency requirement. This distinction is critical: limited English proficiency is a subset of drivers, not a reflection of foreign-born status, and the two categories are not interchangeable.
Enforcement Trends
Since June 2025, enforcement agencies have issued approximately 23,000 citations for English–language deficiencies. These actions are concentrated in specific states, including Texas, Wyoming, Tennessee, and Arizona, with Florida ranking eighth nationwide.
An English-related Out-of-Service (OOS) order temporarily removes a driver from operation until compliance is restored; it is not a criminal penalty, but it does have operational consequences for carriers and drivers alike.
Increased enforcement may reflect clarifications in federal rules, heightened inspection priorities, or changes in roadside training and documentation procedures, rather than a sudden surge in unsafe behavior. Enforcement spikes often indicate shifts in oversight focus, not necessarily deterioration in driver performance.
Policy and Labor Reality: System Stress and Unintended Effects
CDL licensing integrity issues cannot be separated from the broader labor realities facing the trucking industry. Trucking is among the most demanding occupations in the U.S., requiring long hours on the road, extended time away from family, and sustained physical and mental effort.
High turnover and ongoing shortages (currently exceeding 80,000 unfilled positions) have reshaped the composition of the workforce and increased pressure on regulatory and oversight systems.
The Role of Foreign-Born Drivers
Based on our review of data presented by the U.S. Committee for Refugees and Immigrants, today, 18–19% of U.S. truck drivers are foreign–born, totaling roughly 650,000.
The largest nationalities include Mexico, Uzbekistan, India, Cuba, and El Salvador, reflecting how international labor complements domestic supply chains.
Non-domiciled CDL holders make up about 5% of all CDL drivers nationwide. These drivers are critical to freight movement, particularly in states like California, where nearly half the trucking workforce is foreign-born.
Regulatory Shifts and Employment Impact
Recent federal rules have tightened eligibility for non-domiciled CDL holders. The regulation titled “Restoring Integrity to the Issuance of Non-Domiciled Commercial Driver’s Licenses” directs states to halt CDL issuance for certain immigrant populations, including refugees and asylees.
Estimates suggest approximately 194,000 drivers may eventually lose their jobs as a result. While the Administration cites fatal crashes involving non-domiciled CDL drivers as justification, research does not establish a clear causal link.
Workforce Pipeline and “Second Chance” Hiring
The industry has also turned to “second chance” hiring programs to address labor shortages. Formerly incarcerated individuals are increasingly recruited for logistics roles, with research suggesting that stable employment can reduce recidivism by more than 50%.
Shadow Fleets and Administrative Complexity
System stress extends beyond labor shortages. A growing “shadow fleet” exists outside formal oversight. In the Drug & Alcohol Clearinghouse, over 190,000 drivers are listed as prohibited, and 62% have not begun the return-to-duty process, effectively exiting regulated trucking rather than re-entering compliance.
Many CDLs are suspended for non-driving-related reasons, such as unpaid child support or missing Medical Examiner’s Certificate uploads, which can remove qualified drivers from active operation despite no evidence of unsafe behavior.
The Bottom Line: What the Data Supports—and What It Doesn’t
The findings by our Atlanta truck accident lawyers support a critical conclusion: CDL safety depends as much on administrative integrity and enforcement consistency as it does on individual driver behavior. Audits across multiple states show that verification failures are common, persistent, and consequential.
What the data does not support are broad claims that any single demographic group is inherently unsafe, or that increased enforcement alone will resolve systemic issues. According to the study we conducted at Bader Law Injury Lawyers, licensing failures are institutional, not individual.
When licensing standards are ignored or unevenly applied, unsafe drivers can legally operate heavy commercial vehicles. Ensuring that the CDL system functions as designed is a shared-road safety imperative that affects everyone who travels America’s roads.
