Last Updated November 26, 2025
With federal agencies tightening immigration-related rules in trucking, such as an increasingly strict English-speaking mandate, non-domiciled CDLs have become a hot topic.
These licenses are crucial for drivers who are legally in the U.S. but don’t yet qualify for a standard state-issued CDL.
For carriers, schools, and new entrants, understanding how non-domiciled CDLs work is key to staying compliant.
Key Takeaways
- Non-domiciled CDLs let legally present non-citizens drive commercially in the U.S. even if they don’t meet a state’s full residency requirements.
- Drivers face the same testing and medical standards as regular CDL holders, but states add extra immigration verification through systems like SAVE.
- Carriers must stay organized with documentation since immigration-related audits, inspections, and enforcement have become much stricter.
- Inconsistent state rules and ongoing legal disputes make renewals, transfers, and verification slow, creating real compliance challenges for both drivers and fleets.
What Is a Non-Domiciled CDL?
A non-domiciled Commercial Driver’s License is a credential issued to individuals who reside legally in the U.S. but cannot meet a state’s standard domicile or residency requirements. Typically, these are drivers who hold temporary visas or are awaiting adjustment of immigration status.
FMCSA created this classification to ensure that qualified non-citizen drivers can still contribute to the trucking industry.
The credential looks similar to a regular CDL, as it simply includes markings that identify it as non-domiciled. For example, some states denote “Non-Domiciled” or “ND” on the license, while others include a special code in the license number or display the holder’s immigration status next to the license class. These markings allow law enforcement and carriers verify that the driver is legally allowed to operate a commercial vehicle.
There are about 200,000 non-domiciled CDL holders in the United States, which includes both full CDLs and commercial learner’s permits (CLPs).
Who Qualifies for a Non-Domiciled CDL?
While eligibility varies by state, a driver may qualify for a non-domiciled CDL if they:
- Are legally in the United States
- Do not meet the state’s full residency or domicile requirements
- Provide acceptable immigration documents
- Meet all federal CDL testing and medical standards
States may request additional verification such as employment authorization documents, proof of lawful temporary residence, or passport and visa information. Drivers hoping to obtain non-domiciled CDLs often include seasonal agricultural workers, long-term temporary visitors, and people in the process of obtaining permanent residency.
Requirements for Obtaining a Non-Domiciled CDL
Documentation requirements also differ from state to state, though the process for obtaining a non-domiciled CDL is similar to that of getting a regular CDL.
Drivers must complete:
- A knowledge test for the desired class and endorsements
- A behind-the-wheel skills test
- A DOT medical exam
- A background check if applying for hazardous materials
The key difference lies in which identification and residency documents are required. Applicants for non-domiciled CDLs must have the immigration paperwork that the state verifies through electronic systems such as SAVE (Systematic Alien Verification for Entitlements).
How Non-Domiciled CDLs Affect Carriers
For carriers, non-domiciled CDLs are proof that the driver has passed all required testing and may legally operate commercial vehicles in interstate commerce. It’s important for trucking business owners to stay on top of updates and requirements if they’re hiring their own drivers.
Employing non-domiciled drivers must be compliant with FMCSA regulations. This includes keeping accurate copies of license credentials, employment authorization documents, and I-9 verification records.
When records aren’t up-to-date, serious violations can be imposed during audits or roadside inspections. Therefore, make sure to stay on top of your drivers’ immigrant documentation in case it’s set to expire.
Additionally, some carriers see non-domicile CDLs as an important tool for addressing ongoing truck driver shortages, especially in regions with strong immigrant labor involvement. Alternatively, other carriers might be cautious due to the additional compliance oversight and paperwork required.
Common Challenges With Non-Domiciled CDLs
Drivers and trucking business owners often come across challenges related to non-domiciled CDL documentation and processes, including:
- Limited DMV appointment availability for SAVE verification
- Delays in federal immigration processing that slow renewals
- Restrictions on H-2A, H-2B, or other temporary visa holders
- General confusion around who qualifies for this type of CDL
Throughout 2025, non-domiciled CDL-holders nationwide have been impacted by legal disputes between states and the federal government, such as FMCSAs recent emergency ruling cracking down on non-domiciled CDLs.
Some individual states have tightened requirements in recent years, creating inconsistencies across jurisdictions. A driver who easily obtained a license in one state may face more complex steps when transferring it to another.
As regulations increase, carriers will likely see more frequent checks during compliance reviews, especially for fleets with a high percentage of non-citizen drivers.
Non-Domiciled CDL Restrictions & Renewals
Unlike standard CDLs, which often remain valid for several years, non-domiciled CDLs typically have shorter validity periods aligned with the driver’s immigration status. Renewals usually require updated immigration documentation, proof of continued legal residence, and added verification via federal databases.
If a driver’s legal status changes, they can become eligible for a full state-issued CDL. In these cases, the process involves visiting the DMV to update documentation and swap-in the non-domiciled CDL for a standard CDL.
Non-domiciled restrictions vary by state. It’s important to note though that many states allow non-domiciled CDL holders to operate in both intrastate and interstate commerce as long as federal requirements are met.
In Summary: Non-Domiciled CDLs
Non-domiciled CDLs give legally present non-citizens a chance to participate in the U.S. trucking workforce while complying with FMCSA safety standards. Although the licenses come with additional verification requirements and shorter renewal periods, they are useful for an industry that faces ongoing driver shortages and regulatory changes.
For carriers, staying informed is essential. If you have non-domiciled CDL-holders on your team, it’s vital to be organized when it comes to documentation to avoid potential penalties.
For drivers and prospective non-domiciled CDL-holders, understanding the requirements and staying ahead of immigration paperwork deadlines can help avoid delays and tedious challenges holding you back from employment opportunities.
Michael McCareins is the Content Marketing Associate at altLINE, where he is dedicated to creating and managing optimal content for readers. Following a brief career in media relations, Michael has discovered a passion for content marketing through developing unique, informative content to help audiences better understand ideas and topics such as invoice factoring and A/R financing.
