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

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

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. 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:

Last Updated : September 27, 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

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. 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