As of midnight October 11, 2026, FMCSA's temporary waiver tied to the National Registry II (NRII) rollout has officially expired. That waiver, which allowed interstate CDL and CLP drivers and their carriers to rely on paper Medical Examiner's Certificates (MECs) for up to 60 days from issuance as proof of physical qualification, is no longer in effect.
For most carriers and drivers, this marks the beginning of a new era in medical certification compliance. But for operations involving Alaska-based CDL drivers, a specific exemption remains in place, one that carriers need to understand clearly before assuming full compliance is achievable.
A Long Road to This Point
The NRII waiver didn't come out of nowhere. It was a direct response to state driver licensing agencies' (SDLAs) inability to implement the electronic systems required under FMCSA's Medical Examiner's Certification Integration Rule, which went into effect June 23, 2025. That rule requires certified medical examiners to transmit exam results for CDL drivers electronically to FMCSA, which then relays that information to SDLAs to be posted to CDL drivers' motor vehicle records (MVRs).
The rollout didn't go smoothly. Shortly after the rule took effect, FMCSA issued a temporary waiver on July 14, 2025, recognizing that many states simply weren't ready. The agency then modified and extended that waiver multiple times:
July 14, 2025: Initial waiver issued — paper MECs valid for 15 days post-issuance
August 21, 2025: Waiver modified — paper MECs valid for up to 60 days post-issuance
December 30, 2025: Waiver extended through April 10, 2026
April 2026: Waiver extended again through October 11, 2026
October 11, 2026: Waiver expires — NRII process now applies
For a full breakdown of the new process and what it means for your fleet, see our prior article: https://trucksafe.com/post/changes-in-store-for-cdl-medical-examiner-certification-process
The Alaska Exception: One State Still Can't Support NRII
While the waiver has ended nationally, Alaska remains the single state that cannot support the NRII electronic certification process. According to information published on the NRII website, Alaska is specifically carved out from the standard post-waiver process.
The Alaska-specific exemption referenced on the NRII website states:
The Federal Motor Carrier Safety Administration (FMCSA) issued a temporary exemption allowing interstate commercial driver’s license (CDL) holders, commercial learner’s permit (CLP) holders, and motor carriers in the state of Alaska only to continue relying on a paper copy of the medical examiner’s certificate as proof of a driver’s medical certification for up to 60 days after the date the medical examiner’s certificate is issued. The exemption is in effect October 12, 2026 – October 12, 2027.
This means that for Alaska-licensed CDL drivers, the old paper-based process remains the required compliance method. Carriers with Alaska-based CDL drivers should continue to:
Collect and retain paper MECs in the driver qualification file for up to 60 days after their issuance
Ensure drivers are physically submitting their MECs to the Alaska DMV
Monitor compliance through MVR checks, understanding that electronic posting may not occur for several days
How the New Process Works (For Everyone Else)
With the waiver now expired, the NRII process becomes the standard for CDL drivers in all other states. Here's a quick summary of how it works for CDL drivers (NOTE: the process for non-CDL drivers has not changed):
Medical examiner submits results electronically. Certified medical examiners are required to transmit completed exam results to FMCSA electronically by midnight of the next calendar day following the examination.
FMCSA relays results to the SDLA. FMCSA automatically transmits the driver's certification status, including any restrictions, to the driver's state licensing agency.
State posts certification to the driver's MVR. The SDLA updates the Commercial Driver's License Information System (CDLIS) and the driver's MVR to reflect current medical certification status.
Carriers verify status via MVR. Carriers no longer need to collect paper MECs from CDL drivers. Instead, medical certification status is verified through regular MVR monitoring. The MVR is now the only source of truth for a CDL driver's medical qualification.
License downgrade for non-compliance. SDLAs must downgrade a CDL or CLP if a driver's medical certification lapses or expires without renewal.
What Carriers Should Be Doing Now
The end of the waiver shifts the compliance burden from paper to electronic verification, but it doesn't reduce carrier responsibility. Here's what fleet safety directors and compliance officers should be doing:
Update your driver qualification procedures. For CDL drivers (outside Alaska), MECs no longer need to be collected and retained in the DQ file. MVR monitoring becomes your primary verification tool.
Confirm your MVR monitoring service is active and reliable. Medical certification status must now be confirmed through the MVR. Gaps in monitoring create compliance and litigation exposure.
Identify any Alaska-licensed CDL drivers in your fleet. These drivers require continued paper-based processing and physical submission to the Alaska DMV until FMCSA says otherwise.
Treat documentation gaps as audit and litigation risk. A driver who is medically qualified but not properly reflected in the system can still create significant exposure during a compliance review or post-accident litigation.
Educate your drivers. Make sure CDL drivers understand they are responsible for using a certified medical examiner registered with FMCSA's National Registry, and that failure by their examiner to transmit results can lead to a license downgrade.
The Bigger Picture
The NRII system was designed to solve a real and longstanding problem: paper medical cards are easy to lose, easy to falsify, and difficult to verify across jurisdictions. A centralized electronic system makes sense, and when it works, it will reduce fraud, improve road safety, and simplify compliance for carriers.
As always, Trucksafe will continue to monitor FMCSA's guidance and update you as the situation develops.
