Medical certificate expiry: the rules and the common mistakes

A DOT medical certificate is good for up to 24 months under §391.45(b), or less when the examiner certifies for a shorter period because a condition needs watching. Since 23 June 2025, medical examiners no longer hand a paper certificate to CDL and CLP holders. The result goes from the examiner to FMCSA, from FMCSA to the driver's state licensing agency, and onto the driver's driving record, which is now the document that shows medical status. Non-CDL drivers still get and carry the paper card. An exemption in force until 11 October 2026 lets a carrier rely on a copy of the certificate for 60 days while the state record catches up. This page covers what expires when, what the carrier has to keep, and where carriers get it wrong.

How long a certificate lasts

§391.45 lists who has to be examined and certified. Paragraph (a) covers anyone who has never been certified. Paragraph (b) is the one that sets the clock: any driver who has not been medically examined and certified during the preceding 24 months. That is where "every two years" comes from. The exam itself must be done by a medical examiner listed on the National Registry of Certified Medical Examiners, under §391.43(a).

Twenty-four months is a ceiling, not a term. The examiner sets the period, and for some conditions the rule sets it for them. A driver who is treated with insulin is examined at least every 12 months under §391.45(e), and a driver certified under the vision standard in §391.41(b)(10)(i) likewise under §391.45(f). Examiners routinely certify for a year, or three months, for blood pressure that is high but not disqualifying. The date on the certificate, or on the driving record, is the date that counts, whatever the calendar says about two years.

Two other triggers in the same section are easy to miss. §391.45(g) requires a new examination for any driver whose ability to do their normal duties has been impaired by a physical or mental injury or disease, whatever the certificate says. A driver back from surgery with a year left on the card may still need to see an examiner before driving. And §391.45(h), effective 23 June 2025, covers a driver an examiner has found not qualified, who has to be examined and certified again before operating.

What changed on 23 June 2025 for CDL drivers

The National Registry II rule, published in 2015 and delayed several times, finally took effect on 23 June 2025. Under §391.43(g)(2)(ii), from that date the examiner completes a paper certificate only for a driver who is not a CDL or CLP holder. For CDL and CLP holders the examiner reports the result to FMCSA through the National Registry, FMCSA transmits it to the state driver licensing agency, and the state posts it to the driver's CDLIS driving record. The driver does not submit anything to the state, and under §391.41(a)(2)(i)(B) no longer has to carry the certificate at all. The 15-day carry rule that used to cover the gap between the exam and the state posting was written to end on 22 June 2025, and it did.

For the carrier, the record in the driver qualification file changed with it. §391.51(b)(6)(i) still names the medical examiner's certificate or a legible copy, and that is the record for a non-CDL driver. §391.51(b)(6)(ii) is the CDL paragraph: the carrier obtains the CDLIS motor vehicle record from the driver's current licensing state and keeps that in the file, and a copy of the certificate served as a stand-in for up to 15 days after issue, a period the rule wrote to end on 22 June 2025. The registry verification note in §391.51(b)(8) follows the same split. Sub-paragraph (i) requires the note for non-CDL drivers. Sub-paragraph (ii) required it for CDL drivers only through 22 June 2025, because from then on FMCSA does the verification before the result ever reaches the state. The matching inquiry paragraphs are in §391.23(m).

The practical effect: for a CDL driver, a card in the folder proves nothing on its own. The driving record showing a medical status of "certified" and an expiry date is the record. For a non-CDL driver operating a vehicle over 10,001 pounds, nothing changed. The examiner still issues the card, the driver still carries it, and the carrier still files a copy. The full list of what sits in the file is in the guide on the driver qualification file.

The exemption in force until 11 October 2026

The transfer from examiner to state did not work smoothly everywhere, and a driver whose result had not yet posted could look, on the driving record, like a driver with no medical certification. In docket FMCSA-2026-0265 the agency granted a six-month exemption, effective 11 April 2026 and expiring 11 October 2026, covering CDL holders, CLP holders and motor carriers in every state and the District of Columbia.

What it does is simple. The old rules let a copy of the certificate stand in for the driving record for 15 days after the examination. The exemption stretches that to 60 days from the date of certification, by waiving the 15-day periods in §391.23(m)(2)(iii) and §391.23(m)(3)(i)(C) for the carrier's inquiry, in §391.41(a)(2)(i)(A) and §391.41(a)(2)(ii) for the driver carrying a copy, and in §391.51(b)(6)(ii) for the copy in the qualification file. Two conditions attach: the driver must have on their person a current, valid certificate issued within the prior 60 days, and the carrier must hold a copy of that same certificate. A photocopy of a card issued 70 days ago meets neither.

As of the notice, five states had not implemented the electronic transfer: Alaska, California, Kentucky, Louisiana and New Hampshire. The other 45 and DC had. A CDL driver licensed in one of the five is still on the paper certificate, and the carrier's file record for that driver is still the card, until that state switches over. Check the National Registry site for the current list rather than this page, because the list changes.

This exemption expires on 11 October 2026. FMCSA said in the notice that it does not anticipate granting further nationwide waivers or exemptions after the six months. Unless something changes, the 15-day periods come back on 12 October 2026. This page will be re-reviewed after that date and the section above rewritten to match whatever is then in force.

Non-CDL drivers still carry the card

Everything above about driving records applies to CDL and CLP holders. A driver of a vehicle between 10,001 and 26,000 pounds, or a driver otherwise outside CDL requirements, is still on the paper system. Under §391.41(a)(1)(i) that driver must have a current medical examiner's certificate while on duty, and under §391.43(g)(2)(ii) the examiner issues one, on Form MCSA-5876, to a driver found qualified. The carrier files the certificate or a legible copy under §391.51(b)(6)(i) and, before the driver's first trip, verifies the examiner was on the National Registry on the issue date and files a note saying so under §391.51(b)(8)(i).

A mixed fleet has both systems running at once. The sprinter van driver has a card in the file, and the tractor driver has a driving record in the file, and the safety director needs to know which is which. A driver who holds a CDL but drives a non-CDL vehicle for you is still a CDL holder, and their status is still on the driving record.

What happens when it lapses

On the day after the certificate's date the driver is no longer physically qualified under §391.41(a), and a carrier may not require or permit an unqualified driver to operate a commercial motor vehicle. There is no grace period in Part 391. The obligation not to dispatch starts at midnight, and the driver can only be put back to work when a new certification is on record, which for a CDL driver means posted to the driving record, or covered by the 60-day copy rule while the exemption lasts.

The licence follows a slower clock. Under §383.73(o) the state must update the driver's medical certification status to "not-certified" within 10 calendar days of the certificate or variance expiring, and must then complete a downgrade of the CDL within 60 days of the status changing. So a driver whose certificate lapsed can keep a valid CDL in their pocket for a couple of months. That is a licensing timeline. It has nothing to do with whether the driver may drive for you, which ended the day the certificate did.

A driver whose CDL has been downgraded needs a new examination and then a trip to the licensing agency to have the class and endorsements restored, which in some states means retesting. That is the expensive version of a missed date, and it is entirely avoidable.

The common mistakes

• Trusting the card instead of the driving record. For a CDL driver the card is not the record and has not been since June 2025. A safety director who files the copy and never pulls the driving record has no idea whether the result posted. Pull the record after every examination and again before the 60 days run out.
• Filing the card and forgetting the short period. The examiner certified for three months for blood pressure. Whoever filed it wrote "2 years" on the tracker because that is what medical cards are for. The date on the certificate is the date. Read it every time.
• Missing the self-certification category. Every CDL holder declares to the state, under §383.71(b)(1), which of four categories they drive in. A driver who declared excepted interstate or intrastate has told the state no federal medical certificate is required, and the state will not carry a medical status for them. If that driver is actually running interstate for you in a non-excepted operation, the driving record will show nothing useful and the driver needs to correct the declaration. The carrier's check of that declaration is in §391.23(m)(2)(i).
• The 90-day drift. The physical is 90 days out and everyone knows it. Then it is 30 days out and the driver is on a run. Then the examiner cannot fit them in until the week after the date. Nobody owned the reminder, so nobody moved when it was cheap to move. A certificate that expires on a Thursday with the driver in another state is a driver who is parked on Friday.
• Assuming a variance travels with the certificate. A driver with a vision or diabetes exemption, or a skill performance evaluation certificate, must still carry that document under §391.41(a)(2)(iii) even after the card went electronic, and the carrier files a copy under §391.51(b)(6)(iii). Variances have their own expiry dates, usually shorter than the certificate's.
• Treating the five states as history. A carrier that hires a driver licensed in California or Kentucky and expects to find medical status on the driving record will find nothing, because those states were still on paper as of the April 2026 notice. Check the state before you decide which record you are looking for.

Do you need software for this?

With one or two drivers, no. A phone calendar with a reminder 90 days before each date, and a note to pull the driving record after each exam, is a working system. The mistake in this area is not that people don't know the rule. It is that ten drivers means ten dates, four of them fall in the same month, and the person who set the reminders left in March. Ledger Road holds the date from the driving record or the card for every driver and warns 90, 60 and 30 days before it, which is the whole of what it does for this problem. If your calendar already does that and someone reads it, you don't need anything else. The retention guide covers how long the old certificates and records stay in the file after they are replaced.