The Federal Motor Carrier Safety Administration (FMCSA) has extended its temporary waiver tied to the National Registry II (NRII) rollout, allowing carriers to continue relying on paper medical certificates through October 11, 2026 for CDL drivers for up to 60 days after their exams as proof of their physical qualifications.
This is not a new policy shift; rather, it’s yet another extension of the same relief framework FMCSA has relied on since the NRII transition began in mid 2025—further confirming that the system still is not functioning as intended across all states.
Same Relief, Extended Timeline
Under the waiver, interstate CDL and CLP drivers—and the motor carriers that employ them—may continue using a paper Medical Examiner’s Certificate (MCSA-5876) as proof of medical qualification for up to 60 days from the date of issuance.
As we covered in our prior article, “FMCSA Modifies Temporary Waiver for Paper Medical Certificates Amid NRII Transition,” FMCSA has repeatedly justified this relief based on delays outside the control of drivers and carriers.
That explanation remains unchanged.
NRII requires certified medical examiners to transmit results electronically, with FMCSA then passing that information to state driver licensing agencies (SDLAs) for posting to the driver’s record. The system was designed to eliminate paper cards entirely for CDL drivers, with their state driving record being the single source of truth regarding their medical certification status. Instead, persistent delays at the state level have forced FMCSA to keep paper as a fallback.
A Transition That Still Hasn’t Landed
NRII was supposed to close the loop on medical certification. Instead, the industry is operating in a hybrid environment:
Medical examiners submit results electronically
States are supposed to post those results to CDL systems
Drivers and carriers are still relying on paper as a backup
That creates a gap between being medically qualified and being recorded as medically qualified—a gap that continues to create operational and compliance risk.
FMCSA’s decision to extend the waiver through October 11 is a clear acknowledgment that the system still is not consistently closing that gap, with five states still not compliant with the new rule: Alaska, California, Kentucky, Louisiana, and New Hampshire.
What the Waiver Allows
The current waiver remains narrow but important:
Paper medical certificates are valid for up to 60 days from issuance for CDL drivers
Drivers must still hold a valid, current certificate
Carriers should retain a copy in the driver qualification file
Certification is still expected to appear on the MVR within that window
Paper is still temporary. The system is still expected to catch up.
But repeated extensions suggest that expectation is not being met in practice.
The Bigger Issue: Execution vs. Design
NRII addresses a real problem. Paper medical cards are easy to lose, easy to falsify, and difficult to verify across jurisdictions. A centralized electronic system makes sense. But execution matters.
When a system intended to eliminate paper requires ongoing federal waivers just to function, it creates uncertainty for carriers and drivers—and shifts the compliance burden back onto the industry.
What Carriers Should Be Doing Now
Until NRII is fully operational, carriers should continue to:
Collect and retain paper MECs
Monitor whether medical certification is properly posted to the MVR
Identify and resolve posting delays quickly
Treat documentation gaps as both a compliance issue and a litigation risk
A driver who is medically qualified but not properly documented can still create exposure in an audit—and even more so in litigation.
Bottom Line
The extension of the NRII waiver through October 11 is another signal that the transition is still incomplete.
Until the system works reliably across all states, carriers must juggle both paper and electronic records—and assume responsibility for bridging the gap between them.
