FMCSA Grants Another Extension for National Registry II Medical Certification Compliance

Waiver allows continued use of paper medical certificates through January 2026

Gemini Sparkle

Key Takeaways:

  • FMCSA has again extended the deadline to January 10, 2026, for states to fully implement the National Registry II electronic medical certification system, which has been in development for over a decade.
  • The National Registry II system, designed to replace paper medical certificates for CDL holders and enhance safety and efficiency, is still not implemented by 12 states.
  • The article criticizes the "double standard" where states receive repeated extensions for failing to adopt basic technology, contrasting it with the strict and immediate compliance demands placed on carriers.
  • It recommends that FMCSA enforce the upcoming deadline rigorously and suspend federal Motor Carrier Safety Assistance Program (MCSAP) funding for non-compliant states to compel implementation and accountability.
See a mistake? Contact us.

The Federal Motor Carrier Safety Administration issued a waiver on October 9, 2025, extending the deadline for full implementation of the National Registry II electronic medical certification system. The waiver, effective October 13, 2025, and expiring January 10, 2026, allows interstate CDL holders, CLP holders, and motor carriers to continue relying on paper copies of medical examiner’s certificates as proof of medical certification for up to 60 days after issuance.

FMCSA is recommending that medical examiners continue issuing paper Medical Examiner’s Certificates (Form MCSA-5876) to drivers at the time of examination while also submitting physical qualification examination results electronically.

If you’re a driver, nothing changes for now. You’ll still get your paper DOT medical card from your examiner, and you’ll still need to provide it to your state DMV and your employer. The waiver just gives everyone more time to get the electronic system fully up and running.

The idea behind National Registry II is simple. Instead of relying on paper certificates that can get lost or take weeks to reach your state licensing agency, medical examiners would upload your exam results directly to FMCSA’s database. That information would then flow to your state’s CDL system automatically. It’s supposed to make things faster, more reliable, and harder to fake.

The National Registry II system has been in development and rollout for more than a decade. It has taken over 10 years to get states set up to receive electronic medical certification uploads.

Twelve states still can’t do it.

This isn’t even the first extension beyond the original deadline. States have already gotten extra time, multiple times, and now they’re getting another 90 days. Let’s be honest about what we’re talking about: uploading a PDF or electronic form from a doctor’s office to a government database. This isn’t rocket science. This isn’t artificial intelligence or blockchain or some bleeding-edge technology. This is the digital equivalent of sending a fax, except it’s 2025 and we figured out how to do this in the ’90s.

Your local pizza place can take online orders, process payment, and send you text updates. Amazon can deliver a package to your door in 24 hours with real-time tracking, but after 10 years, twelve states still can’t set up a system to receive medical exam results electronically.

If you’re a carrier or driver, you know how this story usually goes. Miss your medical certification deadline by one day? You’re parked. Screw up your logbook? Here’s a fine. Let your registration lapse? Out of service.

FMCSA doesn’t give you extensions because “it’s complicated” or “we need more time to figure out our systems.” You either comply or you face consequences. That’s how regulation works, at least for the regulated. When states can’t meet federal requirements after a decade? Extension granted. Need more time? Sure, take another 90 days. Having trouble with implementation? No problem, we’ll push the deadline again. It’s hard not to see the double standard here.

Carriers operate in an environment where safety is supposedly the top priority, and compliance isn’t optional. CSA scores can destroy your business. One bad inspection can sideline your trucks. The enforcement apparatus is real, immediate, and unforgiving. That same urgency apparently doesn’t apply when the government can’t get its own house in order.

States collectively receive over $400 million annually through the Motor Carrier Safety Assistance Program (MCSAP). That’s federal money, your tax dollars, specifically designated to help states enforce federal motor carrier safety regulations.

To get MCSAP funding, states have to adopt federal motor carrier safety regulations as state law and agree to enforce them. It’s a pretty straightforward deal: we’ll give you money, you implement the rules.

Except we’re seeing repeated failures:

  • States issuing non-domiciled CDLs where the work authorization expires before the CDL does
  • Inconsistent enforcement of English language proficiency requirements
  • Failure to implement basic electronic systems after 10 years
  • Continued paper processes that are slower, less secure, and more prone to errors

These aren’t minor administrative hiccups. These are fundamental compliance failures by the very entities collecting hundreds of millions in federal funding to prevent these exact problems. If a carrier took federal money and then didn’t comply with the terms, there would be issues. 

Tie MCSAP funding to actual compliance. If you can’t implement National Registry II after 10 years and multiple extensions, your MCSAP funding gets suspended until you do. If you’re not enforcing the federal CDL standards you adopted to get federal money, you won’t receive the money anymore. This isn’t complicated. The funding exists for a specific purpose. If that purpose isn’t being met, cut the funding until it is.

FMCSA should:

  • Make January 2026 the hard deadline. No more extensions after this one, period
  • Publish monthly compliance reports. Show everyone which states are compliant and which aren’t
  • Suspend MCSAP funding for non-compliant states. Money follows performance
  • Create real consequences. States that continue to miss deadlines should face escalating financial penalties.

The National Registry II system exists for real safety reasons. Paper DOT medical cards can get lost. They can be forged. They can sit in a mailbox or on someone’s desk for weeks while a driver is operating the vehicle. They create gaps where a driver might be medically unqualified, but nobody knows it yet because the paperwork hasn’t caught up.

Electronic transmission fixes all of this. The medical examiner uploads your results immediately. Your state licensing agency gets them in real-time. Your carrier can verify your status instantly. It’s faster, more reliable, and more secure. We can’t get the benefits of this system if we can’t actually implement it. We can’t implement it because after 10 years, twelve states still haven’t figured out how to receive an electronic file.

This comes down to accountability and credibility. FMCSA’s entire regulatory framework is built on the premise that safety is paramount and compliance isn’t negotiable. That’s the standard applied to every carrier and every driver, every single day. When that same standard isn’t applied to government agencies, when states get extension after extension for failures that would put a carrier out of business, it undermines the whole system.

How can you enforce strict compliance in the industry when you can’t enforce basic compliance on your own state partners? How can you argue that safety is the top priority when you keep extending deadlines for safety-related systems? Carriers and drivers are right to ask these questions. If a small trucking company can figure out ELDs, e-logs, electronic fuel tax reporting, and a dozen other mandated technologies. Why can’t a state government figure out how to receive a PDF after 10 years?

We’ve had a decade. We’ve had extensions before this one. Now we’re getting another 90 days. The technology isn’t the problem. The question is whether there’s any real consequence for not implementing it. January 2026 needs to be the end of the line. No more waivers. No more extensions. Either the States comply or they lose MCSAP funding until they do. Simple as that.

Safety is supposed to matter at every level, not just at the carrier and driver level, where enforcement is swift and harsh, but at the federal and state level, where accountability has been conspicuously absent. At some point, you have to mean what you say. FMCSA says safety comes first. 

Rob Carpenter

Rob Carpenter is an independent writer for FreightWave "The Playbook", TruckSafe Consulting, Motive, and other companies across the freight industry. He is an expert in accident analysis and safety compliance and spends most of his time as a rist control consultant. Rob is a CDL driver with all endorsements and spent over 2 decades behind the wheel of a truck. He is an adviser to the Department of Transportation and a National Safety Council driving instructor.