The Paper Medical Card Waiver Ended October 11: What Your Driver Files Need Now

FMCSA granted the exemption in a notice published April 14, 2026 (91 FR 19255). It covered CDL holders, CLP holders and motor carriers in every State and the District of Columbia from 12:00 a.m. on April 11, 2026 through 11:59 p.m. on October 11, 2026 (section VI.A). It let a paper copy of the medical examiner's certificate stand as proof of medical certification for up to 60 days from the date of certification, by waiving the June 22, 2025 end date and the 15-day limit in three places:

When it was granted, 45 States and the District of Columbia had implemented NRII; Alaska, California, Kentucky, Louisiana and New Hampshire had not (section III). FMCSA wrote that it did not anticipate granting more nationwide NRII waivers or exemptions after the six months (summary and section V). The exemption followed a string of waivers: 15 days from July 14, 2025, 60 days from August 21, 2025, reissued October 13, 2025 and January 11, 2026.

On October 8, 2026, FMCSA published a provisional one-year renewal for Alaska only (91 FR 64454). By then 49 States and the District of Columbia had implemented NRII; Alaska had not. The renewal covers drivers whose CDL or CLP was issued by Alaska, and their motor carrier employers, from 12:00 a.m. on October 12, 2026 through 11:59 p.m. on October 12, 2027, on the same 60-day terms (section IV). For everyone else the notice is plain: drivers licensed in all other States and the District of Columbia, and their employers, may no longer rely on the paper certificate as proof of medical certification for any period of time as of October 12, 2026 (FMCSA's notice page).

For a CDL holder, 391.51(b)(6)(ii) says that when the CDLIS motor vehicle record contains medical certification status, the carrier meets the medical certificate requirement by obtaining that record from the current licensing State and placing it in the driver qualification file. For that driver, the paper card is not the file document. The same paragraph designates a non-excepted, interstate CDL holder whose CDLIS record carries no medical certification status as "not-certified" to operate a commercial motor vehicle in interstate commerce.

The last sentence of the paragraph, the one that let a carrier use a copy of the certificate for up to 15 days after it was issued, ran through June 22, 2025. The exemption stretched that window to 60 days until October 11, 2026. Outside Alaska, nothing stretches it now.

FMCSA's guidance for carriers says the same thing in working terms: a motor carrier must obtain the CDLIS driver record from the current licensing State with the driver's medical certification information and keep it in the driver's qualification file (NRII Learning Center). The rest of the qualification file is unchanged; the full list is in the driver qualification file checklist.

Before a CDL driver operates a commercial motor vehicle, 391.23(m)(2) requires the carrier to use the CDLIS record from the current licensing State to verify and document in the driver qualification file two things: the type of operation the driver self-certified, and, for a driver who certified interstate operation, that the driver has a valid medical examiner's certificate and any required medical variances (391.23(m)(2)(ii)(B)). For a CLP holder, 391.23(m)(3)(i) asks the same.

The note verifying that the examiner was on the National Registry, which carriers once filed for CDL drivers, ran through June 22, 2025 (391.23(m)(2)(ii)(A) and 391.51(b)(8)(ii)). When a paper certificate and the electronic record disagree, the electronic record controls (391.23(m)(4)).

On or after June 23, 2025, a CDL or CLP holder with a current medical examiner's certificate no longer needs to carry it (391.41(a)(2)(i)(B)). A driver certified on the strength of a medical variance still carries the variance document on duty (391.41(a)(2)(iii)), and in a conflict between the paper certificate and the electronic record, the electronic record controls (391.41(a)(2)(iv)).

For an Alaska CDL or CLP holder the renewal keeps the 60-day rule: a copy of a current, valid certificate issued by a certified examiner within the prior 60 days, carried on the driver's person, counts as proof while the renewal runs (91 FR 64454, sections IV.A.2 and IV.B.1).

Since June 23, 2025, 391.43(g)(2)(ii) has the examiner complete the paper certificate, Form MCSA-5876, and hand the original to the driver when the driver will not operate a vehicle that requires a CDL or CLP. For CDL and CLP drivers the paper is no longer required. FMCSA recommends that examiners keep issuing one to every driver until further notice, so a driver has something to troubleshoot with (FMCSA bulletin of April 10, 2026), but the electronic record is the official one (National Registry II Requirements for Motor Carriers, question 10).

One change carriers miss: since June 23, 2025, when an examiner finds a driver not physically qualified, every certificate previously issued to that driver stops being valid (391.43(g)(3)). An unexpired card in the file can be dead paper.

NRII does not apply to drivers who hold no CDL (National Registry II Requirements for Motor Carriers, question 12). A commercial motor vehicle starts at 10,001 pounds (390.5T) and a CDL at 26,001 pounds (383.5), so the driver of a 14,000-pound box truck hauling no placarded load keeps the paper loop:

• the examiner issues the paper certificate (391.43(g)(2)(ii));
• the driver carries the original or a copy on duty (391.41(a)(1)(i));
• before the driver drives, the carrier files the certificate or a legible copy (391.51(b)(6)(i)) with a note verifying that the examiner was on the National Registry on the date of issue (391.51(b)(8)(i) and 391.23(m)(1)).

The waiver never applied to these drivers, and its end changes nothing for them.

Every paper card under the exemption ran on two clocks at once. The first started on the day the medical examiner issued the certificate, not the hire date and not the expiry date on the card, and ran 60 days. The second was the exemption's own end, 11:59 p.m. on October 11, 2026. Whichever came first ended the paper's value.

Take a CDL driver licensed outside Alaska and examined on September 15, 2026. Sixty days from issue is November 14, 2026. The exemption ended first, so on October 12 the copy in the file stopped proving anything, more than four weeks before its own 60 days ran out. From that morning the proof is the CDLIS record. If the record still shows an earlier certification that has not expired, the driver stays certified under it. If it shows no certification status at all, the driver is designated not-certified for interstate driving under 391.51(b)(6)(ii), whatever the card says, and FMCSA's guidance says a driver whose new exam has not posted and whose current certificate has expired should not operate in interstate commerce (question 11).

Now an Alaska CDL driver examined on October 1, 2026. The renewal applies, so the paper copy counts through November 30, 2026, 60 days after issue. After that the file needs the CDLIS record too.

Then the two copies. Section VI.B of the April notice set two separate conditions. The exemption did not apply to a driver who lacked a copy of his or her current, valid certificate, issued within the prior 60 days, on his or her person (VI.B.1). It did not apply to a carrier that lacked its own copy of that certificate (VI.B.2). A copy in the office did not cover a driver stopped without one, and a copy in the cab did not cover a file without one. The Alaska renewal repeats both conditions word for word (IV.B.1 and IV.B.2).

Last, the expiry date. A certificate issued for 24 months on August 20, 2026 runs into 2028 as a medical certificate, but outside Alaska it has not been the proof of certification for a CDL driver since October 12, 2026. The CDLIS record is.

1. Sort every driver into three groups: CDL or CLP from a State other than Alaska, Alaska CDL or CLP, and no CDL.
2. For each CDL or CLP driver outside Alaska, obtain the CDLIS record from the current licensing State, confirm it shows medical certification status and any variance, document the self-certified type of operation, and place the record in the qualification file (391.23(m)(2), 391.51(b)(6)(ii)).
3. For a driver whose new exam has not posted, follow the steps in FMCSA's carrier guidance (question 7): the driver asks the examiner to check the National Registry account for an error task and correct the driver's details, then confirms with the State licensing agency that the status posted, then contacts the National Registry technical support helpdesk at fmctechsup@dot.gov or (617) 494-3003. Outside Alaska, the paper copy is not proof while that runs.
4. For each Alaska CDL or CLP driver examined in the last 60 days, keep a copy of the certificate in the file and make sure the driver carries one.
5. For each driver without a CDL, keep the paper certificate and the National Registry note in the file, as before.

Related: how long a DOT medical card lasts, what to do when a card has expired and the physical qualification standards. Hiring this week? The new driver's file, step by step.