Medical Fitness - US DOT Card vs Canadian Rules

United States

The medical examiner’s certificate (often called the DOT medical card) is a cornerstone of Part 391 qualification. Certificates can be issued for up to 24 months, or shorter when the examiner sets conditions. CDL holders must keep medical certification status current with the state driver licensing agency processes that apply.

A driver with an expired medical card is not qualified - even if the plastic CDL is still in their wallet. Fleets that only track licence expiry miss medicals constantly.

The paper card is being replaced - what changed on June 23, 2025

This is the largest change to a US driver qualification file in a decade, and a great many checklists have not caught up with it.

Under the Medical Examiner’s Certification Integration rule - National Registry II - a certified medical examiner now transmits the completed exam result to FMCSA electronically, by midnight of the calendar day after the exam. FMCSA passes it to the driver’s state driver licensing agency, where it attaches to the CDLIS record. For CDL and CLP holders, the carrier’s evidence of medical certification is therefore the CDLIS MVR showing current status, rather than a photocopy of a card the driver handed over.

What that means in practice: the thing you retain changes, and the thing you verify changes. You are no longer confirming that the examiner appears on the National Registry, because FMCSA has already done that before the result was transmitted. You are confirming that the certification actually landed on the driver’s record.

• CDL and CLP holders: pull the CDLIS MVR and file that as the medical evidence. A card in the folder with nothing on the record is the new failure mode.
• Non-CDL CMV drivers: unchanged. They are not in CDLIS, so the medical examiner’s certificate itself is still the document you collect and keep.
• The certification can lapse on the record while the driver still holds a card that looks valid - which is why the record, not the card, is the thing to track.

The rollout is not finished, and where the driver is licensed decides your method

Twelve states had not implemented National Registry II as of August 2026: Alaska, California, Florida, Iowa, Kentucky, Louisiana, New Hampshire, New Jersey, New York, Oklahoma, Vermont and Wyoming. Thirty-eight states and the District of Columbia had. In a state that has not implemented it, the paper certificate is still how the process works.

FMCSA has also run temporary exemptions through the transition, letting a paper medical examiner’s certificate stand as proof of medical qualification for up to 60 days after the examiner issued it. The current window runs April 11, 2026 to October 11, 2026.

For a single-state fleet this is one decision. For a fleet hiring across state lines it is per driver, decided by the state that issued their licence - so the same safety office runs both methods at once. Record which method applies to each driver rather than inferring it, because the answer changes as states come online and the exemption windows move.

Canada

Provinces require medical examinations for certain commercial classes on schedules that can differ by age and class. Evidence of fitness lives with the licensing authority and often as copies in the carrier file. Do not assume a US DOT card satisfies a provincial medical requirement or vice versa.

Nothing in the 2025 US change touches the Canadian side. There is no Canadian equivalent of the CDLIS medical transfer, so a Canadian driver’s fitness evidence stays where it was: with the province, and as copies in your file. A cross-border driver can therefore be on the electronic method for their US qualification and the paper method for their provincial one, at the same time.

Operational practice

Store issue date, expiry date, examiner identity when relevant, and any restrictions (corrective lenses, hearing aids, time-limited certificates). Alert 60-90 days before expiry. Block dispatch when medical status is expired - paper reminders alone are not enough for multi-terminal fleets.

FAQ

More in US driver qualification files and Canadian driver files · short answers on the FAQ · terms on the glossary.

Putting this into practice? Explore the Driver Files workflow and see the standalone plan inclusions.

Regulatory notes verified 2026-08-28 against FMCSA NRII implementation status and temporary paper-certificate exemption. Rules move — confirm before you act.

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