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RC Kelly Law Associates is an innovative law firm, working with clients in all stages of business development. We are committed to finding practical solutions for our clients, so they can stay focused on their core business. We work to anticipate our clients' business and industry challenges and provide proactive solutions.

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Non-Domiciled CDL Update

Everyone knows that immigration has been a top priority for the Trump Administration. Recent developments out of Washington D.C. signify a tightening of federal oversight of commercial learner’s permits (CLPs) and commercial driver’s licenses (CDLs) issued to individuals domiciled outside of the United States. For employers in the transportation industry, a new interim final rule proposed by the Federal Motor Carrier Safety Administration (“FMCSA”) will have an effect on employees holding a non-domiciled CDL.

President Trump’s Executive Order 14286, “Enforcing Commonsense Rules of the Road for America’s Truck Drivers” tackles issues such as English language proficiency, and also addresses non-domiciled CDLs by requiring the Secretary of Transportation and FMCSA to review non-domiciled CDLs issued by state agencies for unusual patterns of irregularities. On September 29, 2025, the FMCSA published an emergency interim final rule after finding that a number of states, including Pennsylvania, were out of compliance with licensing standards. As a result, the new system for non-domiciled CDLs makes non-citizens ineligible for a non-domiciled CDL unless they meet more strict criteria. Additionally, some states, such as Pennsylvania, have temporarily paused the issuance, renewals, and transfers of non-domiciled CDLs while they work to bring their non-domiciled CDL program into compliance with the new federal regulation.

For more information on what the Non-Domiciled CDLs and compliance changes mean to Pennsylvania school bus operators, read our Legal Focus article here, or contact us at 215-896-3846 or help@rckelly.com.

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