The Entry-Level Driver Training regulations did not require a minimum number of instructional hours, leaving the training instructor's assessment of each driver trainee's individual performance as the sole basis for determining proficiency. This has led to a system in which providers self-certify their compliance with federal requirements, and the FMCSA maintains a registry that provides little more than an appearance of verification.
The absence of minimum hours was seen as a feature by the American Trucking Associations when the rule was finalized, noting there were no new exorbitant costs. However, this lack of oversight has created an environment in which drivers are being issued commercial licenses without demonstrating they can safely operate an 80,000-pound vehicle.
The self-certification model that the ATA celebrated in 2022 meant the registry was only as legitimate as the providers willing to attest to their own compliance. This has led to a situation in which ghost schools with no digital presence or state license can produce a CDL that is accepted by states and carriers, putting drivers at risk.
The lack of effective regulation has created an environment in which corrupt examiners are able to pass students who have never taken exams. In Washington, for example, independent tester Jason Hodson was paid bribes averaging $520 to $530 in gold envelopes to enter passing scores for students who had never taken exams. This has resulted in at least 110 licenses being revoked.
In California, the not-for-profit school classification allows a school to serve as its own third-party examiner through the employer school framework. This creates a conflict of interest and can lead to fraudulent CDLs being issued. In 2025, an audit found systemic failures persisting in California, with Secretary Duffy pulling $160 million in federal funding.
The third-party examiner model is a structural conflict-of-interest problem. States outsourced CDL testing to reduce costs, creating a system where private contractors are paid per exam. This creates a market incentive that runs directly against public safety.
The degradation of CDL training programs over time has been measurable. In some states, the minimum training hours have been reduced from 320 hours in 1992 to just 120 hours by 2025. This lack of oversight has created an environment in which drivers are being issued commercial licenses without demonstrating they can safely operate a large vehicle.
The absence of effective regulation has also led to a situation in which drivers are being issued CDLs for equipment they have limited preparation to handle. The shift to automatic transmissions in commercial equipment has removed a competency filter that existed precisely because manual transmission operation is technically demanding.
The current system is not designed to ensure training quality or prevent fraud. A registry that 3,000-plus providers self-certify into annually does not produce verified competency. Resources directed toward actual enforcement and provider auditing would produce measurable safety outcomes.
The lack of effective regulation has created an environment in which ghost schools, corrupt examiners, and lax enforcement have become commonplace, putting the safety of drivers and passengers at risk.
