ELDT Training Provider Registry: How CDL Schools Register

Any school or company that trains entry-level commercial drivers must be registered with the Federal Motor Carrier Safety Administration (FMCSA) and listed on its Training Provider Registry (TPR). Once listed, you must report each driver's completed training by midnight of the second business day, because the driver cannot take the CDL skills or knowledge test until that record reaches the state.

This guide explains who the entry-level driver training (ELDT) rule covers, how to register, what you must report, and the records to keep.

Key takeaways

Since February 7, 2022, ELDT providers must be registered and listed on the TPR.
Each location must register separately.
Report completions by midnight of the second business day after training ends.
Keep required records for three years.
Theory students need an overall minimum score of 80 percent.
FMCSA can remove providers that do not meet the requirements.

Who needs ELDT

The ELDT rule applies to people who obtain a commercial learner's permit (CLP) on or after February 7, 2022 and are seeking:

A Class A or Class B CDL for the first time.
An upgrade from Class B to Class A.
A school bus (S), passenger (P) or hazardous materials (H) endorsement for the first time.

The rule is not retroactive. FMCSA says it does not apply to people excepted from CDL requirements under 49 CFR part 383, and lists other exceptions, including qualifying military personnel.

Who must register as a provider

FMCSA's provider factsheet says any entity that provides training for entry-level drivers must be registered with FMCSA, beginning February 7, 2022. FMCSA's FAQ lists eligible entities including training schools, educational institutions, motor carriers, state and local governments, owner-operators and individuals. Accreditation is not required.

You must also be licensed or authorized under state law wherever you train in person. Many states regulate truck driving schools separately, so check your state first.

Before you register: meet the requirements

FMCSA's implementation checklist lists what you need in place:

Curriculum that meets the criteria in 49 CFR part 380, appendices A through E, as applicable.
Facilities (classrooms and range) that comply with federal, state and local requirements.
Instructors who meet CDL, experience and state requirements.
State licensing in every state where in-person training happens.
Vehicles that meet safety requirements and match the group and type drivers will use on their skills test.

Instructor qualifications in brief

According to FMCSA's FAQ:

Theory instructors need a CDL of the same or higher class with the needed endorsements, and either two years of CMV driving experience, a prior CDL of that class, or two years as a behind-the-wheel instructor. State instructor rules apply too, except for theory-only instruction.
Behind-the-wheel instructors need a CDL of the same or higher class with endorsements, must meet state requirements, and need two years of CMV driving or two years as a behind-the-wheel instructor.

States may set stricter instructor rules.

How to register on the TPR

The factsheet describes the steps:

Register each location separately. A multi-location provider registers every site.
Designate one representative to register. After approval, that person can invite other users, according to the implementation checklist.
Enter your details, including provider and facility names and contact information, provider type, any third-party affiliations or accreditations, average training cost, type of training and average training hours.
Self-certify that you meet all requirements. FMCSA says providers attest under penalties of perjury that they comply with 49 CFR part 380, subpart G.

Because self-certification is under penalty of perjury, make sure every item is true before you submit, not just planned.

Reporting completions

This is where schools most often slip. You must submit each driver-trainee's certification by midnight of the second business day after they complete training. The factsheet lists the data required:

Driver-trainee name, date of birth, and license or permit number and issuing state.
CDL class or endorsement and training type (theory or behind-the-wheel).
Total clock hours behind the wheel, if applicable.
Provider name, location and TPR ID number.
Date of successful completion.

You can enter this by hand on the TPR website or connect your own system through the TPR web service.

FMCSA says drivers are not penalized for late submission, but they cannot take the skills or knowledge test until the information is submitted and the state can access it. A late report means a delayed, unhappy student. Routine noncompliance can also lead to removal from the registry.

Assessing trainees

The implementation checklist says to:

Use written or electronic assessments for the theory objectives in each unit.
Track theory scores. Each driver-trainee needs an overall minimum score of 80 percent.
Have instructors evaluate and document behind-the-wheel skill proficiency.

Records to keep for three years

Under the checklist, keep these records for three years from the date they were created or received:

Self-certifications from accepted behind-the-wheel trainees about drug and alcohol testing, age, medical certification, licensing and driving record rules.
Copies of each trainee's CLP or CDL.
Instructor qualification documents.
Lesson plans for theory and behind-the-wheel (range and public road) training.
Individual trainee assessment records.

FMCSA says that if it audits or investigates a provider, the provider must supply documentary evidence of compliance. Organized files make that a short conversation. For general record-keeping habits, see Driving School Record Keeping: What to Keep and for How Long.

Removal from the registry

FMCSA can issue a notice of proposed removal explaining the problems and corrective actions. According to the FAQ:

Providers can generally keep training during a corrective action period, usually 60 days, but must tell enrolled and scheduled trainees about the proposed removal.
Removal can follow from failing state requirements, falsely certifying compliance, or not responding within 30 days.
Training given after removal is invalid.

That last point is serious: students who train with a removed provider may have to repeat training somewhere else. For real-world examples of what goes wrong in CDL training and testing, see CDL Training and Test Fraud: Real Cases and What They Teach.

A simple compliance routine

Daily: report every completion before the two-business-day deadline.
Weekly: check that every finished student shows as reported in the TPR.
Monthly: confirm instructor licenses are current and files are complete.
Yearly: review your curriculum against appendices A to E and your state's rules.

FAQ

When did the ELDT rule start?

It applies to people who obtain a commercial learner's permit on or after February 7, 2022. Providers have had to be registered on the TPR since the same date.

How fast must I report a completed driver to the TPR?

By midnight of the second business day after the driver completes training. The driver cannot take the CDL skills or knowledge test until the information is submitted and available to the state.

Do I need accreditation to register as a training provider?

No. FMCSA says accreditation is not required, but you must meet federal requirements and be licensed or authorized under state law where you train in person.

What score do theory students need?

FMCSA's checklist says each driver-trainee needs an overall minimum score of 80 percent on the theory assessments.

How long must I keep ELDT records?

Three years from the date each record was created or received, according to FMCSA's implementation checklist.

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