Paper medical-card grace period ends Oct. 11: check every driver's state record

Regulatory
Written By Zorro Risk Management

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Zorro Risk Management banner: Paper medical-card grace period ends Oct. 11. Subline: Check every driver's state record; drivers should keep their paper copy, and what ends at 11:59 p.m. Oct. 11 is the 60-day window to use it as proof. A short orange line adds that Alaska-licensed drivers are extended through Oct. 12, 2027. Beside it, an illustrative clipboard-style driver record card with an Oct. 11 calendar tile, showing medical certification certified, certificate issue date recorded, a future expiration date, filed in the DQ file, and a recheck reminder set.

What changes at 11:59 p.m. on Sunday, October 11, 2026

The Federal Motor Carrier Safety Administration (FMCSA) granted a six-month exemption that lets commercial driver's license (CDL) holders, commercial learner's permit (CLP) holders and motor carriers use a paper copy of the medical examiner's certificate (MEC) as proof of medical certification for up to 60 days after the certificate was issued. It runs from 12:00 a.m. April 11 through 11:59 p.m. October 11, 2026. FMCSA says it does not anticipate granting more nationwide waivers or exemptions after this one: "States, motor carriers, and drivers should not expect additional nationwide waivers or exemptions beyond the six-month duration of this exemption."

Alaska is the one exception. On Oct. 8, FMCSA published a provisional one-year renewal of the exemption for drivers licensed in Alaska only (Alaska-issued CDL and CLP holders and their employers), from Oct. 12, 2026 through Oct. 12, 2027. Drivers licensed in every other state and the District of Columbia lose the paper-copy option at the end of Oct. 11. In FMCSA's words, they "may no longer rely on the paper MEC as proof of the driver's medical certification for any period of time as of October 12, 2026."

Sources: Federal Register, 91 FR 19255, Apr. 14, 2026 (docket FMCSA-2026-0265) · FMCSA newsroom, Apr. 10, 2026 · Federal Register, 91 FR 64454, Oct. 8, 2026 (Alaska renewal, same docket)

What this does not mean: paper medical cards are not banned. FMCSA still recommends that certified medical examiners keep issuing the paper certificate (Form MCSA-5876) "in addition to submitting examination results electronically, until further notice" (FMCSA newsroom). Drivers should keep their copy. What ends is the 60-day window in which that paper copy can stand in as proof while the state record catches up, for every driver except Alaska-licensed drivers.

What applies after Oct. 11 (except Alaska-licensed drivers): the regulation's own 15-day paper-copy allowance already ended on June 22, 2025. For CDL and CLP holders, carriers must verify medical certification on the Commercial Driver's License Information System (CDLIS) motor vehicle record (MVR) from the driver's current licensing state before the driver operates a commercial motor vehicle (CMV), and keep that record in the driver qualification (DQ) file (49 CFR 391.23(m)(2)–(3), 391.51(b)(6)(ii); "CFR" is the Code of Federal Regulations). A non-excepted interstate CDL holder whose CDLIS record shows no medical certification status is designated "not-certified" for interstate commerce. If the electronic information from FMCSA and a paper certificate conflict, the electronic information controls (391.41(a)(2)(iv)). Paper certificates are still issued and still worth keeping, but after Oct. 11 they no longer stand in for the posted record, except for Alaska-licensed drivers.

This applies to non-excepted interstate CDL and CLP holders licensed in states that have implemented National Registry II (NRII), which is every state and the District of Columbia except Alaska. There are three exceptions:

  • Non-CDL drivers: the paper certificate is still the proof.
  • Drivers licensed in Alaska: the 60-day paper-copy exemption continues through Oct. 12, 2027 (see "Who it affects" below).
  • Intrastate-only drivers: state rules apply.

Why there was a grace period

Under FMCSA's NRII rule, which states had to comply with by June 23, 2025, medical examiners send exam results to FMCSA's National Registry. FMCSA transmits them to the state driver licensing agency, and the state posts them to the driver's CDLIS record. In states that have implemented NRII, examiners are no longer required to hand CDL and CLP holders the original paper certificate, and drivers no longer have to take a paper copy to the state licensing agency. The old 15-day paper-copy allowance ended June 22, 2025.

Some states were slow to connect and some records posted late. FMCSA bridged the gap in steps:

  • July 14, 2025: waiver allowing a paper copy for 15 days
  • August 21, 2025: waiver widened to 60 days
  • October 13, 2025 and January 11, 2026: waiver reissued (effective dates)
  • April 11, 2026: six-month exemption takes effect (ends 11:59 p.m. Oct. 11, 2026)
  • October 8, 2026: FMCSA publishes a one-year renewal for Alaska-licensed drivers only, in effect Oct. 12, 2026 through Oct. 12, 2027

Timeline of the paper-copy grace period: June 22, 2025, the 15-day allowance ends; June 23, 2025, NRII compliance date; July 14, 2025, waiver for a paper copy for 15 days; Aug. 21, 2025, waiver widened to 60 days; Oct. 13, 2025 and Jan. 11, 2026, waiver reissued (effective dates); April 11, 2026, six-month exemption takes effect; Oct. 11, 2026, exemption ends at 11:59 p.m. for every state except Alaska; Oct. 12, 2027, the Alaska-only renewal published Oct. 8, 2026 ends. Spacing is not to scale.

Sources: Federal Register, 91 FR 19255 (background section) · Federal Register, 91 FR 64454 (Alaska renewal).

The exemption never changed who has to be medically qualified. Every driver still has to be certified by a medical examiner as physically qualified to drive a CMV (391.41(a)).

Who it affects

  • Interstate CDL and CLP holders: Covered by the exemption until it ends: 11:59 p.m. Oct. 11 if licensed in any state except Alaska, and Oct. 12, 2027 if licensed in Alaska. After Oct. 11, if they are licensed in any state except Alaska, check the state record, not the paper card.
  • Carriers employing them: You must verify medical certification from the CDLIS MVR and document it in the DQ file before the driver operates (391.23(m)(2) for CDL holders, 391.23(m)(3) for CLP holders, 391.51(b)(6)(ii)).
  • Drivers whose certificate was issued in roughly the last 60 days, new hires, and anyone renewing: Most exposed: their new status may not have posted yet.
  • States not yet on NRII: FMCSA's April exemption notice listed five states not yet on NRII: Alaska, California, Kentucky, Louisiana and New Hampshire. FMCSA's Oct. 8, 2026 notice says 49 states and the District of Columbia have now implemented NRII, and Alaska is the only state that has not (91 FR 64454). FMCSA's NRII Learning Center list matches: Alaska only, as of Oct. 8, 2026. Check FMCSA's current list before relying on it.
  • Drivers licensed in Alaska (the only state not on NRII, as of Oct. 8, 2026): FMCSA provisionally renewed the exemption for one year, for Alaska-issued CDL and CLP holders and their employers only. From 12:00 a.m. Oct. 12, 2026 through 11:59 p.m. Oct. 12, 2027, a copy of a current, valid MEC issued within the prior 60 days can still serve as proof, as long as the driver carries a copy and the carrier keeps one in the DQ file (91 FR 64454, Oct. 8, 2026). The renewal is provisional: FMCSA is taking public comments, and it says it will revoke the exemption early if it lowers safety. FMCSA's National Registry information sheet says Alaska drivers must continue to submit the paper medical certificate (Form MCSA-5876) to the state licensing agency, and must make sure the examiner gives them a paper copy (National Registry information sheet, June 2025).
  • Non-CDL CMV drivers: No CDLIS medical status to check. The examiner still issues a paper certificate (391.43(g)(2)(ii)), and the carrier keeps a copy plus a note verifying the examiner was on the National Registry (391.51(b)(8)(i)).
  • Intrastate-only drivers: State rules apply. States could, but did not have to, adopt the exemption for intrastate operations (91 FR 19255). The Oct. 8 Alaska renewal says the same (91 FR 64454). Check with your state.

At roadside: the Commercial Vehicle Safety Alliance (CVSA) publishes general inspector guidance (Inspection Bulletin 2015-04, revised April 23, 2026). For CDL and CLP holders, it bases enforcement on the medical status in the state record:

  • If the record shows no medical information and the driver has no current medical certificate, the driver is cited under 49 CFR 391.41(a)(1) and placed out of service.
  • If the driver has a current certificate in hand, the driver is still cited but is not placed out of service.

This is enforcement guidance, not regulation. As of Oct. 8, CVSA has not issued anything new for Oct. 11: its bulletin is still the April 23 revision, and it tells inspectors to verify there are no active FMCSA waivers before taking enforcement action. On the FMCSA side, the new item is the Oct. 8 Alaska renewal described above.

Step-by-step: check each driver's medical status

Do this for every driver who operates a CMV for you, including leased-on owner-operators. Start with anyone whose certificate was issued since mid-August.

  1. Build the list. For each driver, note: CDL, CLP or non-CDL; licensing state; interstate or intrastate; date of the last Department of Transportation (DOT) physical; and the certificate's issue date.

  2. Pull a current CDLIS MVR from the current licensing state (CDL and CLP drivers). Use your state's process or your MVR provider. The state posts these items (49 CFR 383.73(o)):

    • Medical certification status: "certified" or "not-certified"
    • Self-certified type of driving (for example, non-excepted interstate)
    • Certificate issue date and expiration date
    • Examiner name, phone, license and National Registry number
    • Any medical variance (an exemption or Skill Performance Evaluation (SPE) certificate) and restrictions (for example, corrective lenses)

  3. If it shows "certified" with a future expiration date: put the MVR in the DQ file and put the expiration date on your calendar. That record is how you meet the medical-certificate requirement for CDL holders (391.51(b)(6)(ii)).

  4. If the status is missing, "not-certified," or older than a recent exam:

    • Through 11:59 p.m. Oct. 11 (driver licensed in any state): a copy of a current, valid MEC issued within the prior 60 days can still serve as proof under the exemption's terms. The driver must carry the copy, and you must keep a copy in the DQ file.
    • After Oct. 11 (driver licensed in any state except Alaska): treat the CDLIS record as the answer. A non-excepted interstate CDL holder without certification status on the record is designated "not-certified" for interstate driving (391.51(b)(6)(ii)).
    • After Oct. 11 (driver licensed in Alaska): the exemption continues through Oct. 12, 2027 for Alaska-licensed drivers only. A copy of a current, valid MEC issued within the prior 60 days can serve as proof if the driver carries a copy and you keep a copy in the DQ file (91 FR 64454). The driver still submits the paper certificate to the state.
    • Ask the driver to contact the examiner and the state licensing agency. Examiners must submit results to FMCSA by midnight local time of the next calendar day (391.43(g)(5)(i)(B)). The driver's paper copy helps troubleshoot. Re-pull the MVR once it's fixed.

  5. Check variances. If the certification depends on an FMCSA medical variance, keep a copy in the DQ file (391.51(b)(6)(iii)). The driver must carry a copy on duty (391.41(a)(2)(iii)).

  6. Non-CDL drivers: keep the paper MEC (or a legible copy) and the dated note that you verified the examiner on the National Registry.

  7. Document the check. Record the date, who checked, and what the record showed. Re-check before each expiration date. After a certificate expires, the state has 10 days to mark the driver "not certified" and must complete a CDL or CLP downgrade within 60 days of that status change (383.73(o)(2), (o)(4)).

Flowchart: how to check a driver's medical status. The paper-copy grace period ends 11:59 p.m. Sunday, Oct. 11, 2026, or Oct. 12, 2027 for Alaska-licensed drivers. 1: CDL or CLP holder? If no (non-CDL), keep the paper medical examiner's certificate and a National Registry note in the DQ file. 2: If yes, is the licensing state on NRII? If no (Alaska, the only state not on NRII as of Oct. 8, 2026), the 60-day paper-copy exemption continues through Oct. 12, 2027: up to 60 days after issue, the driver carries a copy and the DQ file has one; after that, use the CDLIS MVR; the driver still submits Form MCSA-5876 to the state. 3: If yes, pull the CDLIS MVR from the current licensing state and check whether it shows certified with a future expiration date. If yes, file it and set a recheck reminder. If no, through Oct. 11 only, a certificate copy can serve as proof for up to 60 days from the certificate's issue date, and only if the driver carries a copy and the DQ file has one. If no after Oct. 11, a non-excepted interstate CDL holder with no status on the record is not-certified for interstate driving; the driver contacts the examiner and the state licensing agency, then re-pull the MVR. Side note: intrastate-only drivers follow state rules.

What to keep in the driver qualification file

  • CDL and CLP (any state except Alaska): CDLIS MVR from the current licensing state showing medical certification status. Rule: 391.51(b)(6)(ii), 391.23(m)(2)–(3)
  • CDL and CLP (any state), through Oct. 11 only: Copy of a current MEC issued within the prior 60 days, if the record hasn't posted (the driver must also carry a copy). Rule: 91 FR 19255
  • CDL and CLP licensed in Alaska: CDLIS MVR showing medical certification status once the state posts it. Until it posts, through Oct. 12, 2027: a copy of a current MEC issued within the prior 60 days (the driver must also carry a copy). Rule: 91 FR 64454, 391.51(b)(6)(ii)
  • Non-CDL: MEC or legible copy, plus a note verifying the examiner's National Registry listing. Rule: 391.51(b)(6)(i), (b)(8)(i)
  • Any driver with a variance: Copy of the variance (SPE certificate or exemption letter). Rule: 391.51(b)(6)(iii), (b)(7)
  • Retention: Keep the DQ file while the driver is employed plus 3 years. The MEC or CDLIS MVR may be removed 3 years after its date. Rule: 391.51(c), (d)

Tools that help

We don't rate or link products on this page. These are categories to look for:

  • DQ-file software: Stores MVRs and certificates per driver and flags upcoming expiration dates
  • MVR monitoring or ordering service: Pulls CDLIS MVRs, or alerts you when a driver's record changes (availability varies by state)
  • National Registry search (FMCSA, free): Confirms an examiner is certified, needed for non-CDL files
  • A simple expiration tracker: A spreadsheet with driver, state, status, certificate issue date, expiration date and re-check date works for small fleets

Official sources (bookmark these)

For fleet safety managers: pull the record before the next dispatch, not after the next inspection.

Stay ahead of the next compliance change.

Subscribers get the free one-page Med-Card Check Sheet.

Printable one-page Medical Certification Check Sheet from Zorro Risk Management, noting that the grace period ends 11:59 p.m. Oct. 11, 2026, or Oct. 12, 2027 for Alaska-licensed drivers. It has a blank 12-row driver table with columns for driver name, type (CDL, CLP or non-CDL), state, state on NRII (yes or no), interstate or intrastate, certificate issue date, MVR or CDLIS status, expiration, recheck date, and a "driver carries copy" checkbox that counts through Oct. 11 only (Alaska-licensed: through Oct. 12, 2027). Below it is a box listing what to keep in the DQ file.

FMCSA revocations, roadside out-of-service risk, driver health, and the automated-vehicle (AV) rules that change what you see on the highway — summarized once a week for people who run trucks, not press releases. The Weekly Beacon is free.

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