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To comply with the ELDT regulations, drivers seeking a Class A or Class B commercial driver's license (CDL), a passenger (P) endorsement, or a school bus (S) endorsement must successfully complete applicable entry-level driver training (theory and behind-the-wheel (BTW) instruction) from a training provider listed on FMCSA’s Training Provider Registry (TPR) before taking the State-administered skills test(s). A driver seeking the hazardous materials (H) endorsement must successfully complete entry-level driver training (theory only) prior to taking the State-administered knowledge test. The State must not administer the test(s) until verifying that the applicant has completed the required entry-level driver training. The ELDT regulations also impose minimum qualification standards for training providers and instructors conducting entry-level driver training.

As discussed in the preamble to the final rule establishing ELDT requirements (81 FR 88732 (Dec. 5, 2016)), FMCSA’s ELDT regulations establish minimum training standards for entry-level drivers. The CDL regulations do not directly preempt State law. Accordingly, the Federal ELDT requirements generally do not replace or otherwise supersede State-based ELDT requirements that exceed the minimum Federal standards for entry-level drivers. A State may also impose more stringent qualification requirements for training providers and training instructors conducting entry-level driver training in that State. FMCSA noted in the preamble to the 2016 final rule that questions would likely arise concerning the relationship between Federal and State ELDT requirements and the Agency would provide post-rule guidance as necessary. Answers to frequently asked questions are set forth below.

Can a CDL applicant domiciled in State A receive entry-level driver training (BTW range and public road) and pass the skills test in State B?

Yes. In accordance with 49 CFR 383.79(a), if a driver domiciled in State A obtains training in State B and passes the skills test administered by State B, State A must accept the skills test results from State B in fulfillment of the driver’s skills testing requirement and of State A’s skills testing administration requirement.

An applicant for a Class B CDL with school bus (S) and passenger (P) endorsements, domiciled in State A, obtains entry-level driver training (BTW range and public road) for Class B and S and P endorsements and passes the skills test in State B. Can State A require the applicant to meet additional standards to obtain the S endorsement?.

Yes. For example, some States require drivers seeking the S endorsement to obtain a State-issued certification related to the operation of school buses, which may include, for example, requirements for completion of a CPR or first aid course, a minimum number of BTW training hours in a school bus, a minimum number of classroom training hours, or specified training topics that exceed the ELDT curricula requirements.

Even if the driver obtained skills training in another State (the training State) and passed the S endorsement skills test in that State, nothing in the ELDT regulations prohibits the State of domicile from requiring the driver to obtain a State-based certification for school bus drivers as a condition of receiving a CDL with the S endorsement, or meeting other requirements as a condition of receiving a CDL. In accordance with § 383.79(a), the State of domicile cannot require the driver to re-take skills tests successfully completed in the training State.

An applicant, domiciled in State A, completes BTW training and passes the skills test in State B. State A accepts the skills test results from State B, but has a State law requiring applicants to complete a minimum number of BTW training hours in order to obtain a CDL (the ELDT regulations do not impose a required minimum number of BTW hours). Can State A impose additional BTW requirements as a condition of receiving a CDL in that State?.

Yes. The State of domicile may require the applicant to meet State-based requirements, such as a minimum number of BTW training hours, prior to receiving a CDL or a P, S, or H endorsement, even if the applicant obtained ELDT in another State and passed the skills test in that State. In accordance with § 383.79(a), the State of domicile cannot require the driver to re-take skills tests successfully completed in the training State.

The ELDT regulations require BTW instructors to meet certain qualification requirements, such as having at least 2 years of experience driving a CMV for which ELDT is to be provided or 2 years of experience as a BTW training instructor. Can a State require ELDT instructors to have more than 2 years of relevant experience or more than 2 years of training experience?

Yes. The ELDT qualification requirements for instructors are minimum standards. As set forth in the definitions of “theory instructor” and “behind-the-wheel (BTW) instructor” in § 380.605, instructors must comply with State-based instructor qualification requirements. A State may therefore impose more stringent qualification requirements on instructors who provide ELDT in that State, except for online theory instructors; this exception is set forth in the definition of “theory instructor” in § 380.605.

The ELDT regulations require training providers to follow a curriculum meeting the applicable criteria set forth in 49 CFR part 380, Appendices A-E. Can a State require a training provider to offer additional training topics or impose other additional requirements on the provider?.

Yes. As provided in § 380.703(a)(5)(i), training providers must comply with additional requirements imposed by a State in which the provider offers entry-level driver training.

Last Updated : September 27, 2022

Yes. If the applicant obtains a CDL before the CLP or renewed CLP expires, the applicant is not subject to the ELDT requirements.

Last Updated : September 27, 2022

Training providers listed on the Training Provider Registry are the only entities that can provide training required by the entry-level driver training (ELDT regulations). To comply with the ELDT regulations, drivers must select a training provider from those listed in the Training Provider Registry.

Last Updated : February 07, 2022

Yes. As of February 7, 2022, applicants must complete the training required in 49 CFR part 380, prior to obtaining any of the following commercial license credentials for the first time: a Class A or Class B commercial driver’s license (CDL); an upgrade to a Class B or a Class A CDL; or a hazardous materials (H), passenger (P), or school bus (S) endorsement for the first time. Driver applicants must obtain training from a training provider listed on the Training Provider Registry.

Last Updated : September 27, 2022

No. There is no minimum number of hours that driver-trainees must spend on the theory (i.e., knowledge) portions of any of the individual curricula. The regulations prescribe specific topics for each of the five theory curricula, requiring the training provider to cover all topics, and requiring that driver-trainees demonstrate their understanding of the material by achieving an overall minimum score of 80 percent on the written (or electronic) theory assessment.

Last Updated : May 20, 2020

The ELDT requirements are aligned with the existing commercial driver’s license (CDL) regulations in 49 CFR § 383.3.

The ELDT regulations do not create any new exceptions; therefore, any individual who is currently excepted from taking a skills test in order to obtain a Class A or Class B CDL or a passenger (P) or school bus (S) endorsement, is not subject to ELDT requirements. This includes:

Last Updated : September 12, 2022

Training schools, educational institutions, rural electric cooperatives, motor carriers, State and local governments, school districts, joint labor-management programs, owner-operators, and individuals may be listed on the Training Provider Registry. Eligible providers may provide training either on a “for-hire” or “not-for-hire” basis. Any training provider meeting the eligibility requirements could be qualified to provide entry-level driver training, regardless of whether they fall within a category specifically identified in the regulations.

Last Updated : September 27, 2022

No. Drivers applying for a removal of a restriction from their CDL in accordance with 49 CFR 383.135(b)(7), which includes the no air brake (L), no full air brake (Z), and no manual transmission (E) restriction, are not subject to the Entry-Level Driver Training regulations.

Last Updated : September 27, 2022

The regulations fulfill a statutory requirement imposed on FMCSA by Congress under Section 32304 of the “Moving Ahead for Progress in the 21st Century Act” (MAP-21). The ELDT regulations are intended to enhance the safety of commercial motor vehicle (CMV) operations on our Nation’s highways by establishing more uniform requirements for both behind-the-wheel (BTW) and theory training, thereby resulting in more qualified CMV drivers.

Last Updated : May 20, 2020

No. The entry-level driver training (ELDT) regulations do not permit BTW training to be conducted by using a driving simulation device, and a driver-trainee may not use a simulation device to demonstrate proficiency for any of the BTW curricula. However, simulators may be used in theory training.

Last Updated : May 20, 2020

Yes, if the driver is applying to obtain the S, P, or H endorsement for the first time, he or she must complete the entry-level driver training required for the endorsement.

Last Updated : September 27, 2022

Yes. The regulations generally do not replace or otherwise supersede State ELDT requirements that exceed these minimum Federal standards when an entry-level driver obtains training in that State. Whether additional State ELDT-related requirements apply to the applicant is determined by where they obtain their behind-the-wheel (BTW) and/or theory training for the Class A or Class B commercial driver’s license (CDL) and/or the passenger (P), school bus (S), or hazardous materials (H) endorsements.

For example, if a State requires that entry-level drivers complete a CDL training program with a prescribed minimum number of BTW hours, a driver-trainee who obtains BTW training in that State must comply with that requirement. Similarly, driver-trainees are required to comply with any additional State-based requirements applicable to theory training in the State where they obtain their training. The regulations do not prohibit driver-trainees from obtaining training outside their State of domicile if they so choose.

Last Updated : September 27, 2022

To be eligible to take the Class A or Class B CDL skills test, the S or P skills test, or the H knowledge test, commercial driver’s license (CDL) applicants must have completed applicable entry-level driver training from a registered training provider. The type of training required depends on the type of license or endorsement for which the driver is applying. Below is a summary:

License/Endorsement ELDT Verification Occurs Before: Is Theory Training Required? Is Behind-the-Wheel Training Required?
Class A CDL (new or upgrade) CDL skills test Yes Yes – Range and Public Road
Class B CDL CDL skills test Yes Yes – Range and Public Road
Passenger (P) endorsement P skills test Yes Yes – Range or Public Road
School bus (S) endorsement S skills test Yes Yes – Range or Public Road
Hazardous materials (H) endorsement H knowledge test Yes No

Last Updated : September 27, 2022

Anyone who is the victim of a sexual assault should immediately report such incidents to local law enforcement authorities for criminal investigation. For drivers who experience sexual harassment or discriminatory actions in the workplace, the U.S. Equal Employment Opportunity Commission (EEOC) is the Federal agency charged with investigating such claims. The EEOC also has authority to pursue settlements, or file lawsuits against companies or individuals found to have violated the law. More information on employees’ rights and how to file a complaint with the EEOC can be found on their website, https://www.eeoc.gov/youth/how-file-complaint. State or local fair employment practice agencies would be another potential resource for drivers subject to workplace sexual harassment or discrimination.

Last Updated : March 14, 2022

No. There is no mandatory order in which the theory, BTW-range, and BTW-public road training must be administered, nor do the regulations require that theory training be completed before obtaining a commercial learner’s permit (CLP). However, BTW training must be completed before taking the skills test(s).

Last Updated : May 20, 2020

SDLAs must verify that an entry-level driver has completed the required training before allowing the driver to proceed with testing. The point at which the SDLA must verify completion of entry-level driver training depends on the type of license or endorsement the applicant is seeking. See the table below for a summary of these requirements.

This table indicates the point at which the CDL skills or knowledge test examiner must verify a driver's completion of required training for each license or endorsement.
Type of license or endorsement SDLA must verify completion prior to allowing
Class A or Class B commercial driver’s license (CDL)
Passenger (P) endorsement
School bus (S) endorsement
Skills test
Hazardous materials (H) endorsement Knowledge test

Last Updated : September 27, 2022

Yes. This unit of instruction requires that driver-trainees be informed about the right of employees to question the safety practices of an employer without risk of losing their job or being subjected to other forms of retaliation. These protections extend to an employee who has filed a complaint with an employer alleging a violation of a security standard and to a driver who refuses to operate a CMV due to a “reasonable apprehension of serious injury” due to “the vehicle’s hazardous safety or security condition” (49 U.S.C. 31105(a)(B)(i),(ii)).

If a CMV driver is subject to sexual harassment, threat of sexual assault, or sexual assault by the employer, another driver, or a training instructor employed by the employer, the employer has violated basic security standards for a safe working environment. Allegations of sexual assault and threat of sexual assault should be investigated as crimes and constitute “a hazardous security condition” that could impair the driver’s ability to safely operate a CMV. The FMCSA strongly recommends that entry-level driver training providers address the whistleblower and coercion protections available to drivers facing these issues.

Last Updated : March 14, 2022

Yes. Theory (knowledge) and BTW training may be delivered by separate training providers. Both types of training providers must be listed on the Training Provider Registry, and both would submit driver-specific training certification information (i.e., proof of training) to the Federal Motor Carrier Safety Administration (FMCSA).

Last Updated : May 20, 2020

Yes. If an individual successfully completes the entry-level driver training required for the Class A CDL, they are eligible to take the skills test for the Class B CDL, as well as the Class A CDL.

Last Updated : January 11, 2022

No. Per § 380.603(b), if the driver was issued a CDL before February 7, 2022, the driver is not subject to the ELDT requirements if the driver chooses to re-obtain a CDL of the same class, even if the previously-issued CDL is not currently valid.

Last Updated : February 07, 2022

Yes. A State may schedule a CDL skills test before the entry-level driver has completed the required training. A State may also choose to require completion of entry-level driving training prior to scheduling a skills test. In any event, the State may not administer the skills test or knowledge test until a driver-trainee completes the training for the CDL or endorsement for which they are applying.

Last Updated : February 07, 2022

Driver-trainees are not able to submit information to the Training Provider Registry. Only training providers who have registered with FMCSA and been issued a TPR Identification number have the ability to submit driver training certification information.

Last Updated : February 07, 2022

Yes. Per 49 CFR § 380.603(c)(1), an applicant who obtains a CLP before February 7, 2022 is not required to complete the entry-level driver training for obtaining a CDL, so long as the applicant obtains a CDL before the CLP or renewed CLP expires.

Last Updated : December 17, 2020

The ELDT regulations establish minimum training requirements for entry-level commercial motor vehicle (CMV) operators in interstate and intrastate commerce who are applying for:

  • A Class A or Class B commercial driver’s license (CDL) for the first time;
  • An upgrade of their CDL (e.g., a Class B CDL holder seeking a Class A CDL); or
  • A hazardous materials (H), passenger (P), or school bus (S) endorsement for the first time.

The requirements do not apply to individuals holding a valid CDL or an H, P, or S endorsement issued prior to February 7, 2022. Individuals who obtained a commercial learner’s permit (CLP) before February 7, 2022 are not subject to ELDT requirements as long as they obtain a CDL before the expiration date of the CLP or renewed CLP.

Last Updated : September 27, 2022

No. The entry-level driver training (ELDT) regulations do not require a minimum number of hours for the completion of BTW training (e.g., Class A, Class B and the passenger (P) and school bus (S) endorsements). The proficient completion of the BTW portions of the various curricula is based solely on the training instructor’s assessment of each driver trainee’s individual performance of the required elements of BTW training on the range and public road. All BTW training must be conducted in a representative vehicle for the commercial driver’s license (CDL) class or endorsement being sought.

Last Updated : May 20, 2020

The contents of these frequently asked questions do not have the force and effect of law and are not meant to bind the public in any way. The documents are intended only to provide clarity to the public regarding existing requirements under the law or agency policies.