What ELDT Requirements Mean for Truckers

As of February 2022, anyone who wants to obtain a commercial driver's license (CDL) will be required to complete a specific program of instruction. This requirement, known as the Entry-Level Driver Training (ELDT) rule, is intended to improve safety on the roads by ensuring that all CDL holders have the necessary skills and knowledge to operate their vehicles safely.

The ELDT requirement applies to any driver who wants to:

• Obtain a Class A or Class B CDL for the first time.
• Upgrade their existing Class B CDL to a Class A CDL.
• Obtain an S (school bus), P (passenger), or H (hazardous materials) endorsement for the first time.

This requirement is not retroactive, meaning existing CDL holders do not need to complete an ELDT program unless they wish to upgrade or add an endorsement. ELDT requirements also do not apply to existing CDL holders who wish to renew their licenses.

For more information on the ELDT rule and what it means for truckers, read on.

What Are the ELDT Requirements?

ELDT rules are included in 49 CFR § 380.600 and require entry-level truckers to complete training under a federally compliant program, registered with FMCSA, that incorporates both theory and behind-the-wheel instruction. These instructors are listed on the FMCSA Training Provider Registry (TPR).

Drivers will be equipped with invaluable knowledge related to safe operating techniques, basic procedures such as docking or coupling, and more complex practices like skid recovery and jackknife prevention. The ELDT requirement is a huge improvement over previous methods that mostly consisted of earning a learner's permit, minimal coursework, and a few hours out on the highway with an experienced driver in the passenger's seat. Curricula also differed by state, which led to truckers with inconsistent skill sets.

By implementing these updated standards, FMCSA aims to ensure that all new truckers receive the comprehensive training they need to stay safe on the road.

Who Is—and Isn’t—Exempt from ELDT?

ELDT rules apply to almost everyone, but FMCSA carved out three narrow exemptions:

• Military Waiver: Active-duty and recently separated service members who drove comparable tactical vehicles may skip ELDT if they meet each state’s Troops-to-Trucks criteria.
• Farm & Ag Haulers: Drivers of Covered Farm Vehicles (CFVs) operating wholly within 150 miles of the farm are exempt when hauling agricultural commodities or machinery.
• Seasonal CDL Holders: States may issue restricted CDLs for custom harvest seasons; those drivers must stay within state lines and meet tight calendar limits.

Everyone else—new entrants, hazmat applicants, school bus drivers, and Class B-to-Class A upgraders—must log into the TPR, pick an approved provider, and complete the full curriculum before they can even schedule a skills test.

Lessons Taught by the I-70 Accident & Rogel Aguilera-Mederos

ELDT rules were put in place to prevent accidents like the one caused by Rogel Aguilera-Mederos in April 2019. Mederos, just 23 years old, was an inexperienced trucker who was traveling on I-70 in Colorado. Mederos' unpreparedness for the Colorado mountain passes, where even experienced truckers have difficulty, directly led to a fatal crash and his 110-year prison sentence. Mederos likely received minimal training in Texas, unaware of the potential dangers of attempting the mountainous terrain of Colorado. More rigorous instruction would have allowed Mederos to prepare for the specific problems he would face traveling through dangerous mountain passes and steep grades.

After his sentencing, trucking advocates pointed out that the real failure was the system that offered no real instruction to Mederos and drivers like him.

The ELDT rules are a pivotal step toward treating truckers like skilled professionals rather than replaceable parts. By mandating training rules at the federal level, FMCSA is setting up a nationwide standard for drivers to be properly prepared and qualified to operate commercial vehicles. That's a positive step.

Theory vs. Behind-the-Wheel: What ELDT Actually Teaches

ELDT divides training into two buckets—theory and behind-the-wheel (BTW)—and a driver must pass both to sit for a state CDL exam. The theory side covers more than 30 federally mandated topics, from basic vehicle control and shifting gears to fatigue countermeasures, hazardous materials awareness, and crash scene procedures. Trainees finish with a written proficiency exam (minimum score of 80 percent) that instructors must document in the FMCSA Training Provider Registry.

BTW training happens on a closed range and public roads. While FMCSA stopped short of mandating a minimum number of driving hours, it does require instructors to grade each student on critical skills: straight-line backing, alley dock backing, up- and downhill starts, lane changes, safe speed management, emergency stops, and more. A candidate can’t “time out” of BTW. They move forward only when the instructor attests—in writing—that every skill can be performed safely and consistently. In short, ELDT emphasizes mastery over mileage, eliminating the old practice of checking a box after a few laps around the yard.

The Serious Weakness with EDLT Requirements

However, a key problem remains. In Mederos' case, a major issue was that he simply didn't have enough time behind the wheel to successfully navigate steep Colorado passes. The reason for this is simple: FMCSA standards establish no minimum hours for behind-the-wheel training. In many states, the amount of training required to get a barber's license is 1,000 hours or more. To operate clippers to cut someone's hair, a barber needs months of supervised training. To operate an 80,000-pound behemoth, a trucker only needs a couple of weeks of classroom training and a few afternoons of supervised driving.

The ELDT rules might have established a minimum amount of training before a trucker receives a CDL, but there remains a huge loophole in the CDL qualification process. CLD instruction facilities might have the most rigorous training programs ever conceived, but without a minimal standard for behind-the-wheel training, drivers might still be sent onto our highways without the experience they need to keep themselves (and everyone around them) safe.

Carrier & Driver Consequences for Skipping ELDT

Operating outside the new rules is not a slap-on-the-wrist offense. Drivers caught behind the wheel without ELDT-verified CDLs can be charged with a Class B misdemeanor in Texas, Louisiana, and most other states, with fines up to $2,000 and possible jail time.

Carriers that dispatch those drivers face:

• FMCSA civil penalties—up to $16,864 per violation, per day.
• Out-of-service orders that sideline equipment until compliant drivers are seated.
• Negative CSA points that raise insurance premiums and trigger federal investigations.

From an injury claim standpoint, noncompliance is a landmine. When a crash occurs, plaintiff’s counsel will subpoena the driver’s TPR record. If it’s missing or incomplete, the carrier’s negligence case writes itself—opening the door to punitive damages.

What Happens If a New Trucker Doesn't Comply with ELDT?

With the new requirement for prospective CDL-holders to complete specialized training, truckers need to make sure they are compliant, or they can face serious consequences. It is essential to be aware of recent changes and get the necessary certification from an instructor on the FMCSA's Training Provider Registry. If a trucker skips out on earning a CDL, they can expect hefty fines and possible jail time since driving without one is a misdemeanor in most states. Plus, all graduates have their records kept in a national database, so it'll be easier for employers to double-check any applicant's qualifications.

How the Training Provider Registry Locks in Compliance

Every approved school or carrier-run academy must appear on the FMCSA Training Provider Registry (TPR). Within 48 hours of a student’s final exam, the provider uploads proof of completion—test scores, instructor attestations, and date-stamped records—directly to the TPR. States pull that data in real time; if the student’s record isn’t there, the DMV examiner won’t schedule a CDL skills test. The system closes a major loophole that once allowed unvetted schools to churn out poorly prepared drivers.

Providers that falsify results or skip uploads face civil penalties, removal from the TPR, and potential federal audits that can sideline an entire fleet. For carriers, that means vetting partner schools and keeping electronic copies of each graduate’s TPR certificate in the driver qualification file—no record, no keys.

The Requirements for Registering as a CDL Instructor

Qualifications for being a CDL training instructor are more or less the same as most states' standards prior to the ELDT rules. FMCSA estimates that roughly 85% of training curricula complied with the new rules prior to February 2022. That said, some state-compliant training facilities needed to upgrade their training programs and staff in order to meet ELDT standards.

To be an instructor for a TPR-certified training facility, an instructor must:

• Possess the same or higher class of CDL certification with appropriate endorsements (or possessed said CDL in the past).
• Have two years of on-road commercial driving experience OR two years of behind-the-wheel instruction experience.
• Never had their CDL revoked, cancelled, or suspended.

As trucking accident lawyers, our main concern is ensuring that truckers and other motorists are safe. The trucking industry has long been criticized for running drivers through CDL mills to get them behind the wheel as quickly as possible. This isn't good for trucking as a profession, and it's disastrous for highway safety. The ELDT rules are a step in the right direction, but until there are standardized minimums for hours of behind-the-wheel training, there's a massive gap between what CDL training is and what it could be.