CDL Licensing Failures Create Hidden Safety Risks on U.S. Roads, Study Finds

A new analysis by Bader Law reveals widespread breakdowns in the commercial driver’s license system that allow unqualified or improperly vetted drivers to legally operate heavy trucks on American roads. The findings show that licensing failures are not isolated mistakes but recurring structural problems that increase public exposure to risk. The study draws on federal crash data, state audit records, enforcement actions, and training oversight reports to show how gaps in verification, testing, and compliance can place unsafe drivers behind the wheel.

Commercial trucks are essential to the national economy, but their size and weight make them uniquely dangerous when something goes wrong. Federal data shows that thousands of people die each year in crashes involving large trucks, and most of those killed are occupants of other vehicles. When licensing systems fail, the consequences extend far beyond administrative errors. They shape the safety of everyday roads where passenger vehicles, cyclists, and pedestrians share space with commercial trucks.

Fatal Crash Trends Show the Stakes of Licensing Integrity

According to federal transportation data reviewed by Bader Law, 4,909 people were killed in crashes involving large trucks and buses in 2024. The year before, 5,472 people died in large truck crashes, a historically high figure even after an eight percent decline from 2022.

Key findings include:

• About 70 percent of people killed in large truck crashes are occupants of other vehicles.

• Seventy five percent of fatal large truck crashes occur on non interstate roads.

• Seventy six percent of fatal large truck crashes occur on weekdays during peak activity hours.

These patterns show that the risks associated with commercial trucking are concentrated in the same environments where most people travel daily. The study emphasizes that licensing failures directly influence these conditions by allowing drivers who do not meet federal standards to remain on the road.

How the CDL System Should Work

A commercial driver’s license is designed to ensure that only qualified individuals operate heavy or complex vehicles. The system includes several layers of oversight:

• Knowledge and skills testing

• Medical certification

• Verification of identity and lawful presence

• Entry level driver training from approved providers

• Ongoing compliance checks through roadside enforcement

When these layers function properly, unqualified drivers are filtered out. The study by Bader Law focuses on what happens when these layers fail to communicate or are not applied consistently.

Where the Licensing System Breaks Down

The study identifies four major categories of failure: verification, testing integrity, training oversight, and administrative enforcement. Each category contributes to long periods during which unqualified drivers remain legally licensed.

1. Verification Failures

Verification is the foundation of CDL eligibility. States must confirm identity, lawful presence, and work authorization. For non domiciled CDL holders, the license must expire when the individual’s work authorization expires.

Audit findings show:

• States issued CDLs without confirming lawful presence.

• Some licenses were valid for up to eight years despite temporary work authorization.

• Expiration dates often did not match federal requirements.

These failures allow drivers to operate legally long after their eligibility has lapsed.

2. Testing Integrity Failures

The study highlights a major case in Massachusetts, where a former state police sergeant was convicted on nearly fifty charges for participating in a bribery scheme that exchanged passing CDL scores for gifts. At least seventeen drivers received fraudulent passing scores.

This is significant because:

• Massachusetts reported a CDL pass rate of only 41 percent in 2022.

• Fraudulent passes undermine the entire testing system.

3. Training Oversight Failures

Training providers must meet federal Entry Level Driver Training standards. However:

• Nearly 3,000 providers were removed from the federal Training Provider Registry for noncompliance.

• About 4,000 more were placed on notice for failing to meet standards.

Drivers who train through noncompliant programs may hold valid licenses but lack required instruction.

4. Administrative and Enforcement Failures

Roadside enforcement data shows:

• Drivers are frequently cited for suspended, revoked, or expired licenses.

• Many suspensions stem from administrative issues such as missing medical certificates.

• These failures reflect gaps in real time compliance tracking.

State Audit Findings Show Widespread Problems

Audits across multiple states reveal similar patterns of noncompliance. The study highlights several examples.

Audit Failure Rates by State

These findings show that licensing failures are not limited to one region or agency. They reflect systemic weaknesses.

Fatal Crashes Involving CDL Required Vehicles

Bader Law examined fatal crashes involving vehicles requiring a CDL between 2019 and 2023. The analysis identified 15,753 fatal crashes nationwide.

States with the Highest Number of Fatal CDL Crashes

The study also identified seventy fatal crashes involving drivers who lacked proper license status at the time of the crash. While this number is small relative to the total, it shows direct intersections between licensing failures and fatal outcomes.

English Proficiency Enforcement Trends

Federal regulations require CDL holders to understand and communicate in English. According to licensing demographic data reviewed in the study:

• About 3.8 percent of CDL holders, or roughly 130,000 to 140,000 drivers, are classified as limited English proficient.

• About 96 percent of CDL drivers meet English proficiency requirements.

Since June 2025, enforcement agencies have issued approximately 23,000 citations for English language deficiencies. These citations are concentrated in states such as Texas, Wyoming, Tennessee, and Arizona.

An English related out of service order temporarily removes a driver from operation until compliance is restored.

Labor Pressures and Regulatory Shifts

The study notes that licensing failures cannot be separated from broader labor pressures. Trucking faces more than 80,000 unfilled positions, and turnover remains high.

Foreign Born Drivers in the Workforce

Based on data reviewed by Bader Law:

• Eighteen to nineteen percent of U.S. truck drivers are foreign born.

• This equals about 650,000 drivers.

• Non domiciled CDL holders make up about five percent of all CDL drivers.

Some states, such as California, rely heavily on foreign born drivers, who make up nearly half of the trucking workforce.

Regulatory Changes Affecting Eligibility

A recent federal rule titled “Restoring Integrity to the Issuance of Non Domiciled Commercial Driver’s Licenses” directs states to halt CDL issuance for certain immigrant populations, including refugees and asylees. Estimates suggest that about 194,000 drivers may eventually lose their jobs as a result.

Second Chance Hiring and Shadow Fleets

To address labor shortages, many carriers have turned to second chance hiring programs for formerly incarcerated individuals. Research shows that stable employment can reduce recidivism by more than fifty percent.

The study also notes the existence of a “shadow fleet” of drivers who are listed as prohibited in the Drug and Alcohol Clearinghouse. More than 190,000 drivers appear in the database, and 62 percent have not begun the return to duty process.

What the Data Shows and What It Does Not

The study by Bader Law concludes that CDL safety depends on administrative integrity as much as driver behavior. The data supports the finding that verification failures, training gaps, and inconsistent enforcement create long periods during which unqualified drivers remain legally licensed.

The data does not support claims that any single demographic group is inherently unsafe. Instead, the failures are institutional. When licensing standards are ignored or unevenly applied, unsafe conditions emerge for everyone on the road.