Clarifying CDL and ELDT Requirements

There has always been some confusion surrounding Commercial Driver’s License (CDL) requirements. Since the Federal Motor Carrier Safety Administration (FMCSA) implemented the Entry-Level Driver Training (ELDT) mandate in 2022, significant changes have only added

to that uncertainty—for both employers and individuals. To assist MML members in better understanding and complying with these regulations, we've compiled answers to some of the most frequently asked questions about CDL requirements and ELDT compliance.

Question: When is a CDL required?

Answer: A Commercial Driver's License (CDL) is required when operating certain types of vehicles for commercial purposes or when transporting specific materials. Specifically, a CDL is required for vehicles with a Gross Vehicle Weight Rating (GVWR) of 26,001 pounds or more, or those towing vehicles with a GVWR of more than 10,000 pounds, and vehicles designed to transport 16 or more passengers. Additionally, a CDL is necessary for vehicles carrying hazardous materials or operating in interstate commerce. 

Question: What are the different classes of a CDL?

Answer: There are 3 classes:

1. Class A is for combination vehicles meeting the GVWR previously described.

2. Class B is for single vehicles meeting the GVWR. You can tow a unit weighing 10,000 lbs. or less.

3. Small vehicles carrying 16+ passengers or hazardous materials.

Question: What is an endorsement and how many types are there?

Answer: An endorsement is an extra certification required for specific types of vehicles.

T: Double/triple trailers

P: Passenger transport

S: School Bus

N: Tank Vehicles

H: Hazardous materials

X: Combo of tank and hazardous materials

Question: Are there exemptions for firefighters or other first responders?

Answer: In Missouri, firefighters and first responders are exempt from requiring a CDL when operating fire or rescue apparatus during emergency operations and related functions.

Question: Is there liability to the city employee if they operate a vehicle that requires a CDL without having one?

Answer: Yes, a city employee operating a CDL-required vehicle without a valid CDL can face personal or criminal charges, job-related discipline, and shared or sole liability in civil suits, especially if an accident occurs. The city itself may also bear liability, particularly if it was negligent in overseeing or verifying employee’s qualifications.

Question: Is there a shortage of licensed CDL holders?

Answer: Yes, as of the summer of 2025, there is a significant shortage of qualified CDL holders, particularly experienced ones eligible for interstate long-haul driving. These companies are desperate for drivers and recruit all over the U.S. The American Trucking Association (ATA) estimated a shortage of 80,000 in 2022 and projected the gap doubling

by 2030.

Question: What options does a city have to get a legally licensed employee on board?

Answer: A city can hire an already licensed CDL driver or sponsor a new CDL driver with a hire to train program. The fastest and simplest route would be to hire a licensed CDL driver; however, the recruiting costs, wage requirements, and turnover are extremely higher with this option. Hiring an employee with the intent to train may be a better long-term investment by providing the training in exchange for a work contract.

Question: What are the options cities can adopt to assist current employees in obtaining a CDL?

Answer: There are three distinct options:

1. A city can send an employee to a truck driving school, which generally takes 4 to 6 weeks and are heavily recruited by the driver needy trucking companies.

2. Build an internal training program and become an approved FMCSA CDL training provider complying with all regulations.

3. Outsource your training to DLTS, which will train your employees at your location

using your equipment on your schedule. Cities need to research the total cost of each option and decide which best fits their budget.

Question: What are the requirements to obtain a CDL?

Answer: To obtain a CDL, you must meet federal and state-specific requirements. An applicant must be 18 (intrastate) or 21 (interstate) years old, have a valid regular driver’s license, proof of U.S. citizenship or lawful residency, possess a medical examiner’s certificate, completed ELDT, has a CDL learner’s permit, and pass CDL skills test. The FMCSA requires applicants to read and speak English well enough to understand traffic signs, communicate with officials, and complete required reports.

Question: Is a medical card required?

Answer: Individual states are authorized to exempt government worker, and most municipalities are granted a medical exception waiver. The CDL applicant must be able to provide proof to the licensing issuer of their municipal employment. MO government

workers are exempt from obtaining a medical certificate.

Question: What does ELDT consist of?

Answer: ELDT includes two parts:

1. Theory instruction is taught in classroom or online and covers topics such as vehicle inspection, basic operation, safe operating procedures, and more.

2. Behind-the-wheel training must be conducted on a range and public road and must be

   provided by a certified training provider.

Question: Is ELDT required for those renewing a CDL or an endorsement?

Answer: No, ELDT is only required for those first-time CDL applicants, CDL upgrades, and adding specific endorsements (H, P, S).

Question: Does the chauffer’s license still exist?

Answer: No, a chauffer’s license applied to those that typically drive people around or transport luxury vehicles. Any licensed driver can transport up to 15 individuals; however, a CDL class C with a P endorsement to transport 16 or more individuals and school bus drivers

require a class B with a S endorsement.

Question: How long does it take to train someone to get their CDL?

Answer: The length of time varies based on the type of training selected. Typically, most CDL schools’ range for 4 to 6 weeks to train. Employers training their own employees average between 4 and 8 weeks. DLTS offers a unique one-on-one training approach combined with online ELDT Theory, allowing behind-the-wheel (BTW) training to be completed efficiently—approximately three (3) days for a Class B license and around five (5) days for a Class A license. A municipality needs to investigate to determine the total cost to train as wages make up a significant portion.

Question: Will traffic violations result in the loss of a CDL?

Answer: Yes, certain traffic violations can result in the suspension or revocation of a CDL, but not all violations lead to that outcome. The severity and frequency of the offenses matter. Major offenses, such as DUI, Leaving the scene, driving a commercial motor vehicle with a

suspended or revoked CDL usually result in a 1-year disqualification on the first offense. Two serious traffic violations, such as speeding 15+ mph over the limit, improper lane changes, following too closely, driving without a CDL or with the wrong class of license, in three years

will result in a 60-day disqualification. Driving a commercial vehicle after it has been placed Out-Of-Service (OOS) can lead to a 180-day to 2-year disqualification. Daily pre-trip inspections are necessary to avoid OOS violations, reduce more serious maintenance violations, potentially lower insurance rates, and operate the vehicle safely.

Question: Do cities need to keep track of whether their employees maintain CDL? If so, how are they notified?

Answer: Yes, cities do need to keep track of whether their employees maintain a valid CDL if those employees are required to operate a commercial motor vehicle as part of their job duties. MO does not notify employers. Cities manually track or use software that flags

upcoming license expiration dates and tracks certifications and endorsements. Employees are required to self-report and CDL suspensions, revocations, or disqualifications within one (1) business day of learning about it. Cities can perform regular manual checks through the state’s Department of Motor vehicles (DMV). Finally, the DOT requires employers to conduct annual MVR reviews for each driver.

Question: Cities provide CDL training to their employees at great expense and often they quit just a few months after they receive their CDL. What can cities do to protect themselves?

Answer: Municipalities can protect their investment in CDL training by implementing training reimbursement agreements or work commitment contracts. These agreements typically require employees to remain employed with the city for a set period (e.g., 12 to 36

months) after receiving their CDL training. If the employee leaves before the agreed-upon time, they may be required to repay some or all the training costs. It’s important to have these agreements reviewed by legal counsel to ensure enforceability under Missouri labor laws. Additionally, cities can enhance retention by offering career development opportunities, recognition, and competitive wages and benefits to CDL holders.

This information is provided by DLTS – Your CDL Training Solution.

As a proud member of the Missouri Municipal League (MML), DLTS has successfully trained over 20 municipalities and government entities across the state of Missouri.

We’re here to assist you—whether you choose to do business with us.

If you have any questions or need additional information, please don’t

hesitate to reach out.

Contact Us:

www.dltscareers.com/contact

David Smith – david@dltscareers.com

(913) 568-5873

Thank you for your time and interest!