The Department of Homeland Security (DHS) recently announced a formal partnership with the Federal Motor Carrier Safety Administration (FMCSA) to investigate 75 CDL driver training schools suspected of fraudulent practices—including improper certifications, falsified training records, and failure to train applicants to the required standard.¹ This announcement marks the latest development in now eighteen months of aggressive federal oversight of CDL issuing practices and training providers. Between December 2025 and July 2026, the FMCSA removed or issued notices of proposed removal to approximately 10,000 training providers from its Training Provider Registry.² The scope and momentum of these enforcement actions signal a fundamental shift in federal oversight of commercial driver licensing and training integrity with consequences for both motor carriers and freight brokers.

Executive Summary

• The DOT, FMCSA, and DHS have significantly expanded enforcement of entry-level driver training (ELDT) providers and CDL schools, targeting alleged fraud in training documentation, certifications, and driver preparation.
• The heightened regulatory scrutiny creates practical implications for carrier hiring procedures and broker liability mitigation strategies.
• Motor carriers should review driver qualification practices to ensure adequate documentation of ELDT completion through a registered provider, particularly for recently licensed drivers.
• Brokers should consider whether standard carrier agreement language adequately addresses training compliance and driver qualification documentation — a question sharpened by the Supreme Court’s recent Montgomery decision confirming that brokers can be sued under state law for negligent carrier selection.

The Enforcement Landscape: FMCSA and DHS Expansion of CDL Training Oversight

ELDT requirements, established under the Moving Ahead for Progress in the 21st Century Act (MAP-21), took effect on February 7, 2022.³ These requirements mandate that individuals seeking to obtain a commercial driver license for the first time, upgrade a license class, or add certain endorsements complete standardized training through a provider listed on the FMCSA’s Training Provider Registry (TPR).

From 2022 through late 2025, the TPR operated primarily as a self-certification system: training providers attested to their own compliance with federal curriculum requirements upon registration. Accordingly, the registry grew to approximately 16,000 listed providers without a systematic federal verification program. That changed abruptly in December 2025.⁴ Secretary of Transportation Sean Duffy announced the removal of nearly 3,000 training providers from the TPR for failing to meet federal safety standards, with an additional 4,500 placed on notice of potential noncompliance.⁵

Removals accelerated through early 2026. In February 2026, FMCSA issued notices of proposed removal to more than 550 additional schools.⁶ By July 2026, the agency had removed or placed on notice approximately 10,000 providers.⁷

The July 2026 announcement of a DHS/FMCSA partnership signals further escalation. DHS Homeland Security Investigations will now participate in federal investigations of approximately 75 entry-level driver training schools suspected of specific violations: improper driver certifications, falsification of training records, and failure to properly train CDL applicants. This represents a shift from administrative removal and oversight to coordinated civil and criminal investigations.

Motor Carrier Hiring: Documentation and Risk Mitigation

Although federal enforcement is directed at training providers, motor carriers face practical implications in two areas: hiring procedures for recently licensed drivers and potential exposure in serious crash litigation where training provider fraud becomes part of the factual narrative.

1. Training Provider Verification and Documentation

The TPR, a public database maintained by FMCSA, enables carriers to verify whether a driver’s training provider was registered and active at the time of training completion. For drivers hired in 2026 or later, carriers should verify ELDT completion through the following methods: (1) review the driver’s copy of the ELDT completion certificate issued by the training provider; (2) confirm that the training provider appears on the TPR as of the date of training completion; and (3) retain documentation of this verification as part of the driver’s qualification file.

Adopting TPR verification into the hiring process will help address potential negligent hiring claims against motor carriers, which turn on whether the carrier knew, or in the exercise of reasonable care should have known, of a driver’s unfitness at the time of hiring. A dated TPR verification record is direct evidence bearing on that element — it documents what the carrier could have discovered from official government sources at the time of hiring, regardless of what could be later learned about the training provider.

2. Driver Qualification Files and Audit Readiness

Continued and heightened enforcement efforts have also increased the importance of complying driver qualification file requirements. Scrutiny of CDL training programs means that motor carriers should ensure driver files, particular for new hires, contain: (1) a copy of the ELDT completion certificate; (2) documentation of TPR verification; and (3) the hiring manager’s notes regarding the verification process.

3. If a Carrier’s Newly Hired Driver Was Trained by a Provider Later Subject to Investigation

Unfortunately, given the increased scrutiny of ELDT programs and CDL schools, it is inevitable that motor carriers will confront a scenario in which a driver’s ELDT or CDL school is later removed from the TPR or receives a notice for noncompliance. While the driver’s CDL and qualifications remain valid, the carrier may face questions about its hiring practices. In anticipation of this scenario, driver file completeness is essential and carriers should: (1) preserve all hiring documentation, including the verification of training provider status at the time of hiring; (2) verify the driver’s current license and medical certification with the relevant state DMV and FMCSA systems; and (3) document any additional safety or skills assessment conducted as part of the onboarding process and continued employment. By taking these steps, the carrier can demonstrate that it took all reasonable steps to ensure the driver has compliant training documentation and that regardless of the ELDT or CDL school’s changed status, the carrier had no prior notice of any training deficiencies.

Broker Considerations for Carrier Agreement Language Ensuring CDL Training Compliance

The current enforcement environment intersects with a separate and more consequential development for brokers: on May 14, 2026, the Supreme Court held in Montgomery v. Caribe Transport II, LLC that the FAAAA does not preempt state-law negligent hiring and selection claims against freight brokers.⁸ Brokers are now exposed to state tort claims premised on a failure to exercise “ordinary care” in selecting a motor carrier, and the current CDL training enforcement wave supplies one more category of information a broker’s selection process might reasonably be expected to consider.

Most broker-carrier agreements contain general representations that the carrier “maintains compliance with all applicable federal, state and local laws,” including “qualification, licensing and training of drivers.” This language is broad and captures ELDT compliance.

Brokers may consider adding explicit reference to training provider registration. For example: “Carrier warrants that all drivers performing services under this Agreement have completed Entry-Level Driver Training, where required, through a provider listed on the FMCSA’s Training Provider Registry at the time of training completion. Carrier shall maintain and produce, upon reasonable request, documentation of such training completion and provider registration.”

This clause is deliberately framed as a representation the carrier makes about its own compliance, not as an instruction from the broker directing how the carrier performs its hiring or training verification. That distinction helps ensure that brokers do not trigger vicarious liability while attempting to avoid negligent selection liability as addressed in the Montgomery decision. Requesting a representation and supporting documentation asks what the carrier already knows about its own compliance with driver qualification requirements; it does not direct the carrier’s internal hiring, training, or administrative process. Properly drafted, such provisions support the broker’s own reasonable-care record without supplying the kind of operational control that has supported vicarious liability findings in other cases.

Brokers should consider updating carrier onboarding documents to confirm that the carrier has policies and procedures in place for verifying ELDT completion for newly hired drivers. Brokers should also consider maintaining records of when they requested and received documentation of carrier compliance procedures. In litigation, such records help demonstrate that the broker exercised reasonable care in carrier selection and monitoring.

Recommended Actions

For Motor Carriers:

• Review hiring procedures for drivers hired since February 2022 (when ELDT became mandatory). Confirm that applications and hiring documentation include ELDT completion evidence.
• Verify a sample of recently hired drivers through the TPR database. Screenshot and date-stamp verification results for inclusion in driver qualification files.
• Audit existing driver qualification files to ensure they contain ELDT documentation for applicable drivers.
• Train recruiting and hiring personnel regarding ELDT requirements and the importance of verifying training provider status at the time of hiring.
• Document the verification process and preserve records demonstrating compliance for at least three years, consistent with FMCSA record retention requirements.

For Brokers:

• Review standard broker-carrier agreement language to confirm it addresses driver qualification and training compliance as a carrier representation, not a broker-directed procedure.
• Consider adding explicit reference to ELDT compliance and Training Provider Registry verification in onboarding documents.
• Request carriers to confirm that they have procedures in place for verifying ELDT completion for newly hired drivers, and document the carrier’s response as part of the selection record.
• Maintain records of any compliance representations or certifications provided by carriers in carrier files.

Conclusion

Federal enforcement of entry-level driver training standards has shifted from administrative oversight to coordinated investigation and aggressive removal of non-compliant providers. While the target is the training provider, not the motor carrier or broker, the enhanced federal scrutiny creates new negligent hiring and selection liability risks.

This is an emerging front against which carriers and brokers must defend when asked by the court what the carrier or broker knew, or should have known, at the time of selection. A documented practice of verifying ELDT completion through official government sources answers that question directly, for carriers and brokers alike.

---

¹ U.S. Dep’t of Transp., Trump’s Departments of Transportation & Homeland Security Team Up to Crack Down on Fraud in CDL Schools (July 16, 2026); U.S. Dep’t of Homeland Sec., DHS Announces Partnership with Department of Transportation to Crack Down on Fraud in CDL Schools (July 16, 2026)

² Supra note 1 (reporting that, as of July 16, 2026, nearly 10,000 schools had been removed from the TPR).

³ Minimum Training Requirements for Entry-Level Commercial Motor Vehicle Operators, 81 Fed. Reg. 88,732 (Dec. 8, 2016) (codified at 49 C.F.R. pt. 380); Extension of Compliance Date for Entry-Level Driver Training, 85 Fed. Reg. 6,088 (Feb. 4, 2020) (extending compliance date to Feb. 7, 2022).

⁴ U.S. Dep’t of Transp., Trump’s Transportation Secretary Sean P. Duffy Cracks Down on Illegal Providers of Commercial Driver’s License Test Training Centers (Dec. 1, 2025), (stating the review covered the 16,000 training providers then listed on the TPR).

⁵ Id. (removal of nearly 3,000 training providers; an additional 4,500 placed on notice of potential noncompliance).

⁶ U.S. Dep’t of Transp., Trump’s Transportation Secretary Sean P. Duffy Moves to Shut Down Hundreds of CDL Mills Violating Federal Regulations (Feb. 18, 2026)

⁷ “DOT expands CDL school enforcement to combat training fraud,” FleetOwner, July 22, 2026

⁸ Montgomery v. Caribe Transport II, LLC, 608 U.S. _, No. 24-1238, slip op. at 1 (May 14, 2026).