The enforcement record of the past year is real. The audits that would make it stick are still open, and that is the argument for keeping the pressure on.
More than 28,000 commercial drivers have been placed out of service for English language proficiency violations since June 2025, and states have been required to cancel more than 30,000 licenses that federal regulators determined were illegally issued to foreign drivers. FMCSA has pulled nearly 10,000 training locations from its registry since December 2025, and removed another 110 training providers outright while proposing to remove 160 more whose graduates are linked to 239 commercial vehicle fatalities.
That is a genuine enforcement record, built in about a year, and by the agency's own account it is nowhere near closed out. The distinction that matters is between licenses that states have been ordered to cancel and licenses that states have actually canceled, because the gap between those two numbers is where the remaining risk sits.
The nationwide audit that started this found more than 30 states issuing non-domiciled credentials out of compliance with the rules on the books at the time. In New York, FMCSA sampled 200 records and found 107 issued in violation of federal law, a failure rate above 53%, with the state's systems defaulting to eight-year licenses for foreign drivers regardless of when their legal status expired. In California, more than one in four sampled records failed, largely because licenses were issued with expiration dates running years past the driver's lawful presence. The two reviews used different periods and selection methods, so they do not rank the states against each other. Both describe a licensing process that could not verify the driving histories it was certifying.
An unverifiable driving history behind the wheel of an 80,000-pound vehicle is a live risk on every highway that truck touches.
The federal response has leaned on funding. FMCSA withheld roughly $160 million from California in January after the state missed an agreed January 5 deadline to cancel more than 17,000 improperly issued credentials, and in April it withheld more than $73 million from New York after that state failed to complete the corrective actions its audit required. Other states moved the other direction, with Colorado, Idaho and Michigan all halting non-domiciled issuance rather than defend their programs, though the reasons differ: Idaho acted by statute, while Colorado's program sits on hold pending the outcome of litigation.
That litigation is the part of this story the enforcement-first argument tends to skip, and it should not. A California court ruled in March that the DMV could not summarily revoke roughly 20,000 credentials without affording drivers due process, and ordered that they be allowed to reapply. A separate challenge to the final rule is pending in the D.C. Circuit. Anyone arguing for sustained enforcement has to take those rulings seriously rather than treat them as obstruction, because a revocation that gets reversed on process grounds removes nobody from the road and hands the other side a reason to doubt the whole effort.
Closing the loophole for new applicants does not retire the licenses that already slipped through it.
The instinct now is to treat the school closures and the license cancellations as the finish line, and FMCSA's own guidance says otherwise. The agency advises states that credentials issued before the March 16 effective date may still have to be revoked and reissued under current standards as part of a corrective action plan, which means an audit that stops at the complaints already on file leaves the rest of a state's noncompliant inventory exactly where it was.
Critics of the enforcement push argue the underlying numbers do not justify the intensity, and that argument deserves a straight answer rather than a dismissal. FMCSA's own rulemaking cites 17 fatal crashes in 2025, causing 30 deaths, involving non-domiciled CDL holders who would not have qualified under the current standard. Set against the 5,478 fatalities involving large trucks NHTSA recorded in 2023, 30 deaths is a small number, and non-domiciled credentials were always a small share of the CDL population. The case for enforcement was never that this group causes most crashes. It is that each of these licenses represents a verification process the government has since admitted failed, on a credential authorizing someone to operate the heaviest vehicles on the road, and a system that cannot tell you whose driving record it is looking at is not made safe by the fact that most people in it never caused a wreck.
What is left is not a question of federal authority, which is now settled in rule, but of whether enforcement holds its pace once the easy cases are closed and the litigation grinds on. Gulf Relay's position has not moved, and we said the same thing when this was costing the industry capacity. License integrity is a floor rather than a negotiating position, and the agencies that let it slip for four years do not get a leisurely schedule to fix it.
License integrity is a floor rather than a negotiating position.
The rule is written. The audits that would make it mean something are not finished.
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