The FMCSA Audit Just Called. It Wants Its CDL Back.

The FMCSA Just Sent an Audit. It Has a Funny Way of Saying ‘Hello.’

“Hey boss, my buddy Carl says he can drive the truck. He doesn’t technically have a CDL yet, but he’s good at Mario Kart.”

Remember that driver? The one who swore his learner’s permit was “totally fine” for that 26-foot rig full of priceless heirlooms? Yeah, the FMCSA remembers him, too. In fact, they just dropped a bombshell (announced Sept. 19, 2025) – a full-on audit of the entire national Commercial Driver’s License (CDL) program.

This isn’t a drill. It’s a bureaucratic smackdown, and if you’re not paying attention, your business could be the next thing on their “Unsatisfactory” list.

In FY2023 and FY2024, the number one driver-related violation was operating a CMV without a CDL – a whopping 53,317 and 57,764 times. That’s over 100,000 trucks parked roadside while drivers tried to explain why their “learner’s permit” should count. Hint: it doesn’t.

If Carl’s only credential is a U-Haul keychain, the only thing he should be driving is his own car back home.

The Numbers Don’t Lie. Or Laugh. They Just Fine You.

FMCSA violation code 383.23A2 (“Operating a CMV without a CDL”) was the top driver OOS violation in 2023 and 2024. That includes 24,000 violations for “no valid license for the CMV being operated.” This isn’t a rounding error – it’s an epidemic. And every single one is a fast track to an out-of-service order.

Let that sink in for a minute. That’s enough violations to put a parking ticket on every single one of your competitors. It’s the number one driver-related offense, dwarfing other classics like “False Report of Driver’s Record of Duty Status” and “ELD-related issues“.

Why so many? The feds have been sniffing around for a while, and it turns out there might be a few weak spots in how CDLs are issued in the first place. The new audit is aimed at the state agencies and third-party testers to make sure everyone is playing by the rules, including the one that says the skills test has to be in English.

This means the days of your driver getting a CDL with the help of a guy who “knows a guy” are coming to an end.

Your Business on a Tightrope: The Fines and the Final Knockou

The only thing heavier than a grand piano? The fine when Carl drives it without a CDL.

• The Fines: Want to let “Buddy Carl” drive that truck? That’ll be an average of $3,410. Feeling extra rebellious? Fines can skyrocket to over $17,000. And if the FMCSA can prove you
  knowingly let it happen, you could be looking at a criminal penalty of up to $10,000. Drivers themselves can get slapped with fines, license suspensions, and even jail time. 
• The Ratings: A “Satisfactory” safety rating is your golden ticket. A “Conditional” rating is a warning shot across the bow. But a single “no CDL” violation can be an automatic failure of your New Entrant Safety Audit. This can lead to an “Unsatisfactory” rating, which is the regulatory equivalent of a “Game Over” screen. With an Unsatisfactory rating, you have 45 days to cease all interstate operations. Yep, the government can literally slam the brakes on your business.

This isn’t just about a few violations. It’s about a cascading failure that starts with one bad decision and ends with a closed sign on your door.

The Mover’s Playbook: How to Be Smarter Than the System

Look, compliance is a pain. We get it. But it’s also your shield.

• Check licenses like you check straps on the load – tight enough that nothing falls off.
• Verify CDLs, endorsements, and medical cards before assigning a driver.
• Use the Drug & Alcohol Clearinghouse to make sure your driver isn’t on the “naughty list” and the Pre-employment Screening Program (PSP) to check a driver’s crash history and catch red flags.  
• Keep driver qualification files neat (not stuffed in the glove box).
• Train your crew that “SC” means “scratch,” not “safe to claim I have a CDL.”

The government is cracking down on the shadier side of the industry, running “sting” operations to catch unlicensed movers. They’re even getting rid of paper checks . The message is clear: they’re getting faster and more ruthless. So should you.

By being the moving company that does things by the book, you don’t just avoid fines; you get a huge competitive advantage. Your “Satisfactory” rating is a badge of honor that tells customers you’re the safe, professional choice, and you win trust with customers, outshine the shady operators, and keep the trucks rolling.  

Or as your dispatcher might say: “Licenses before liftgates, people.”

Compliance Isn’t a Chore – It’s Your Shield

Regulators aren’t out to ruin your day – they’re out to keep unqualified drivers off the road. Play by the book, and you don’t just avoid fines: you win trust with customers, outshine the shady operators, and keep the trucks rolling.

Or as your dispatcher might say: “Licenses before liftgates, people.”

Works cited

1. Audit Announcement | FMCSA’s Oversight of State … – DOT OIG, accessed September 21, 2025, https://www.oig.dot.gov/sites/default/files/library-items/Announcement%20Letter%20FMCSA%20Oversight%20CDL%20Knowledge%20and%20Skills%20Testing.pdf
2. Audit Initiated of FMCSA’s Oversight of State Commercial Driver’s License Knowledge and Skills Testing Programs | DOT OIG – Department of Transportation, accessed September 21, 2025, https://www.oig.dot.gov/library-item/46949
3. Watchdog targets FMCSA on English proficiency testing – FreightWaves, accessed September 21, 2025, https://www.freightwaves.com/news/watchdog-targets-fmcsa-on-english-proficiency-testing
4. Improving the Testing and Licensing of Commercial Drivers | DOT OIG, accessed September 21, 2025, https://www.oig.dot.gov/library-item/29042
5. Commercial Driver’s Licensing: Federal Oversight of State Programs Could Be Improved, accessed September 21, 2025, https://www.gao.gov/products/gao-15-607
6. FMCSA Has Gaps and Challenges in Its Oversight of CDL Disqualification Regulations – DOT OIG, accessed September 21, 2025, https://www.oig.dot.gov/sites/default/files/FMCSA%20Oversight%20of%20CDL%20Disqualification%20Process%20Final%20Report_07-14-21.pdf
7. audit of the data integrity of the commercial driver’s license information system (cdlis) – DOT OIG, accessed September 21, 2025, https://www.oig.dot.gov/sites/default/files/00CDLIS_Final_7-30-2009.pdf
8. OVERSIGHT OF THE COMMERCIAL DRIVER’S LICENSE PROGRAM – DOT OIG, accessed September 21, 2025, https://www.oig.dot.gov/sites/default/files/mh2006037.pdf
9. Top 10 Most Common FMCSA Driver Violations for 2023 – UNICO Group, accessed September 21, 2025, https://unicogroup.com/top-10-most-common-fmcsa-driver-violations-for-2023/
10. Common Violations, accessed September 21, 2025, https://csa.fmcsa.dot.gov/safetyplanner/documents/Forms/Common%20Violations_508.pdf
11. Fines for Common FMCSR Violations – North American Transportation Association, accessed September 21, 2025, https://www.ntassoc.com/fines-for-common-fmcsr-violations
12. What is the Penalty for Driving a Commercial Vehicle Without a CDL? – Ktenas Law, accessed September 21, 2025, https://ktenaslaw.com/driving-a-commercial-vehicle-without-a-cdl/
13. What FMCSA Safety Fitness Means for Movers – MOD24, accessed September 21, 2025, https://www.mod24.com/blog/what-fmcsa-safety-fitness-means-for-movers
14. Safety Audits – Department of Transportation, accessed September 21, 2025, https://ai.fmcsa.dot.gov/test/NewEntrant/SafetyAudits.aspx
15. Federal Motor Carrier Safety Administration | US Department of Transportation, accessed September 21, 2025, https://www.transportation.gov/briefing-room/safetyfirst/federal-motor-carrier-safety-administration
16. Commercial Driver’s License Drug and Alcohol Clearinghouse | FMCSA, accessed September 21, 2025, https://www.fmcsa.dot.gov/regulations/commercial-drivers-license-drug-and-alcohol-clearinghouse
17. Drug & Alcohol Clearinghouse, accessed September 21, 2025, https://clearinghouse.fmcsa.dot.gov/
18. FMCSA Updates 2025: What Motor Carriers Need to Know – Triumph.io, accessed September 21, 2025, https://triumph.io/blog/carrier/fmcsa-updates-2025-what-motor-carriers-need-to-know/
19. ODOT Urges Hiring Only Licensed Movers: Stay Safe & Legal – You Move Me, accessed September 21, 2025, https://youmoveme.com/the-odot-stresses-the-importance-of-hiring-only-licensed-movers-as-required-by-state-law/
20. Seven household goods moving companies cited for violations – GovDelivery, accessed September 21, 2025, https://content.govdelivery.com/accounts/ORDOT/bulletins/3e6d631