The US Inland Regulatory Cliff: How CDL Crackdowns Could Reshape Truck Capacity in 2026

In 2025, most supply chain conversations stayed focused on ocean: alliances, reliability splits, and shifting port congestion.

Meanwhile, something much quieter started happening inland.

The U.S. Department of Transportation (DOT) and Federal Motor Carrier Safety Administration (FMCSA) launched an aggressive campaign to:

Tighten rules on non-domiciled commercial driver’s licenses (CDLs), and
Purge thousands of CDL training providers from the federal Training Provider Registry (TPR).

On their own, these moves look like compliance housekeeping.

Taken together, they create a new kind of risk for logistics service providers (LSPs), importers, and exporters:

A regulatory “cliff” that can shrink effective truck capacity in specific states and corridors, and quietly raise the floor on how flexible and cheap inland transport can be.

This post doesn’t predict a collapse. Instead, it explains:

What the new rules actually do
How big the capacity risk might be (best-, base-, and worst-case)
Where LSPs are likely to feel it first
What to monitor in 2026
How to fold this into practical capacity planning, with TRADLINX as the visibility backbone

1. What Actually Changed in 2025

1.1 Non-Domiciled CDLs Move to the Center of Policy

For years, non-domiciled CDLs were a technical category understood by regulators and a subset of fleets:

Licenses issued to non-U.S. citizens or non-permanent residents
Often held by asylum seekers, temporary workers, or others in liminal legal status
Concentrated in certain states and driving segments

In September 2025, FMCSA issued a rule tightening this category. In plain terms, the rule:

Raises the bar on lawful presence and documentation checks
Initially forced many states to pause issuing new non-domiciled CDLs while they proved compliance; although a court has temporarily stayed the rule, most high-risk states have kept that pause in place under audits and corrective action plans
Sweeps in an estimated ~200,000 non-domiciled CDL holders and ~20,000 learner permit (CLP) holders nationwide

At the same time, DOT audits began targeting state licensing practices:

In some states, audits found that a significant share of non-domiciled CDLs had been issued incorrectly under prior rules
DOT then used a familiar lever: threats to withhold tens of millions of dollars in federal highway funds unless those states:
- Revoke or correct the licenses, and
- Bring their issuing processes into line with the new federal standard

Examples that have already gone public:

One large state ordered to address roughly 17,000 non-domiciled CDLs flagged in audit findings
Others told to fix or revoke a substantial fraction (20–30%+) of their non-domiciled licenses within short timelines
Several warned of eight-figure funding losses if they fail to comply

For carriers and drivers, the message is blunt:
this license category is no longer a quiet corner of the CDL universe.

Note: While an FMCSA rule was placed under court stay in November 2025, most high-risk states
(California, Minnesota, Pennsylvania, Colorado, Texas, Washington) continue enforcing pauses on
non-domiciled CDL issuance under separate corrective action plans based on audit findings.
The practical capacity constraints remain in effect regardless of the rule’s legal status.

1.2 The Training Provider Registry Purge

At almost the same time, FMCSA turned to the Training Provider Registry (TPR).

The TPR is the list of schools and providers authorized to deliver entry-level driver training (ELDT). If you’re not on the TPR, your students’ training doesn’t count toward getting a CDL under current rules.

In December 2025, FMCSA:

Removed over 3,000 schools and training providers from the registry
Placed roughly 4,500 more on notice for potential removal
Flagged that approximately 44% of the ~16,000 listed providers may not meet ELDT standards as written

The immediate effects:

Fewer schools are legally allowed to train new truck drivers
Fleets and individuals face fewer options and, in some regions, no nearby compliant providers at all
The pipeline for new drivers becomes more constrained and more geographically uneven

On top of existing issues—aging driver demographics, high turnover, and mixed working conditions—this is not trivial.

2. How Big Is the Capacity Risk, Really?

It’s easy to jump from “200,000 CDL holders + thousands of schools affected” to “catastrophic shortage”. Reality will likely be more nuanced.

2.1 Scale Check: A Slice of the Market, Not the Whole Thing

A bit of context:

The U.S. has roughly 3.0–3.6 million professional truck drivers, depending on how you count categories
Heavy and tractor-trailer drivers (long-haul) are around 2.2 million
Estimates of the “driver shortage” hover in the 60–80k+ range, with significant debate about methodology

Non-domiciled CDL holders:

Represent roughly mid-single-digit % of the total driver pool
Are not evenly distributed; they are more concentrated in:
- Port drayage and intermodal
- Long-haul interstate segments
- States with larger immigrant populations

So:

Even if every non-domiciled CDL disappeared overnight (which is unlikely), national capacity wouldn’t go to zero
But the impact can be intense in specific corridors, ports, and states, especially where trucking already runs tight

2.2 The Pipeline Problem: Fewer Schools, Stricter Eligibility

Even if many existing non-domiciled drivers re-qualify under the new standards, the TPR purge and new rule create a pipeline problem:

Fewer ELDT-compliant schools = fewer places to train new drivers, particularly in smaller markets
Stricter lawful-presence rules for non-domiciled applicants = narrower pool of future drivers, even as overall freight still needs moving

In a market where:

Turnover is high
Many drivers retire each year
Fleets already report difficulty hiring in certain regions

…this combination matters. It may not cause a sudden cliff, but it can flatten or slow the replenishment curve.

2.3 Three 2026 Scenarios (Not Predictions)

To be honest and useful, it’s better to frame scenarios than certainties.

Scenario 1 – Soft Landing

Courts narrow or delay parts of the rule
States work with FMCSA to correct licenses without mass removal
Many non-domiciled drivers re-qualify
TPR issues are resolved for large providers; some smaller schools exit the market
Result: Localised tightness in a few states, but no structural national shock

Scenario 2 – Uneven Squeeze

Some states move quickly to comply; others litigate or resist
Drivers gravitate to states perceived as “friendlier”
Certain corridors (e.g., outbound from key ports or cross-border lanes) see persistent tightness and volatility
Training capacity recovers in larger metros but remains thin in rural areas
Result: Patchy capacity, more volatile pricing and lead times in hot spots

Scenario 3 – Hard Shock

Courts largely uphold the rule
States aggressively revoke non-compliant licenses without rapid re-issuance
Many non-domiciled drivers exit faster than they can be replaced
TPR cleanup and stricter rules permanently reduce annual new-driver throughput
Result: National tightening on top of local hot spots, more frequent spot spikes, and structurally higher inland rates

No LSP can choose which scenario plays out. But any LSP can plan for all three and watch which indicators reality starts to resemble.

3. Where LSPs and BCOs Will Feel It First

This is not an abstract policy story. It shows up in operations.

3.1 Port Drayage and Inland Terminals

Non-domiciled drivers are heavily represented in drayage and port-adjacent trucking in many regions.

If licensing gets aggressively enforced in a given state, early symptoms can include:

Longer lead times to secure trucks for import pickups
Higher drayage rates and stricter appointment rules at terminals
More frequent “we can’t cover that load at that rate” responses during peak weeks
Rising demurrage because containers can’t be picked within free time even when they’re physically available

For an LSP whose core business is ocean, this can feel like a sudden disconnect:

“Sailing was on time. The container discharged on schedule.
But the truck didn’t show, and the customer still blames us.”

3.2 Long-Haul Flex Capacity

Many carriers will protect their contracted volumes first. If their driver base shrinks:

They keep their best-paying, most stable freight
They trim spot capacity, ad-hoc coverage, and marginal lanes

For LSPs running asset-light models:

The risk is not necessarily that “trucks disappear”
It’s that overflow, rush, and re-routed loads become harder and more expensive to cover, especially in certain regions

This matters when:

You divert containers from one port to another due to congestion
Customers request late changes to destinations
You need to rescue a delayed shipment with premium inland routing

3.3 Training Dependencies for 3PLs and Private Fleets

If you operate your own fleet or rely on external schools to onboard drivers:

Fewer compliant TPR providers mean longer wait lists and potentially higher costs
In some markets, there may be no local ELDT-compliant schools left after the purge
Expansion into certain regions becomes slower or more expensive because you can’t staff trucks quickly

That’s not a 2025 crisis; it’s a 2026–2027 strategic drag on growth.

4. What LSPs Should Monitor in 2026

Rather than doomscrolling every policy headline, LSPs can work from a focused watchlist.

4.1 Policy and Regulatory Signals

On a quarterly basis, track:

FMCSA / DOT updates
- Any changes to the non-domiciled CDL rule
- Litigation outcomes and enforcement guidance
- Updates to ELDT and TPR requirements
State-specific actions
- Which states are flagged publicly for non-compliance
- Announced revocation campaigns or large correction programs
- Legislative responses that might soften or harden the impact
TPR health in your recruiting markets
- Number and location of active TPR providers where your key drivers live
- School closures or new openings in those regions

4.2 Market and Operational Signals

By corridor and metro area, watch:

Time to secure trucks
- How many days in advance you must book to reliably get capacity
- Any trend of carriers asking for longer lead times
Spot vs Contract behaviour
- Spot rate volatility vs prior years
- Tender rejections or declines on certain lanes
D&D and storage trends
- Increasing demurrage/detention linked to late truck arrivals, not port performance
- Rising storage charges at inland terminals or DCs

Patterns to pay attention to:

If one state or port area consistently shows deteriorating inland performance across multiple customers
If D&D is rising even when vessels and terminals are performing reasonably well
If carriers begin pushing back on contract durations or volumes in specific regions, citing driver availability

Those are classic early signs that regulatory decisions are turning into operational constraints.

5. Turning Regulatory Noise into Capacity Planning (with TRADLINX as the Backbone)

The goal isn’t to become a legal expert. It’s to translate policy into route design, lead times, and customer promises.

5.1 Pull Inland Risk into Your International Planning

For cross-border and ocean-centric LSPs, one key shift is:

Stop treating “container discharged” as the finish line
Start designing door-to-door plans that explicitly factor inland risk by state and corridor

Practical moves:

For high-risk states, evaluate alternative gateways (different ports, ramps, or transload locations) with healthier truck capacity
Build different lead-time templates:
- Conservative door-to-door timings in hot-spot states
- More aggressive timings where inland networks are stable
- Make inland risk part of carrier and corridor selection, not just ocean rate and schedule

5.2 Use Event Data as Your Early-Warning System

TRADLINX already gives you a unified event timeline from pickup to empty return:

Gate-in / gate-out
Loaded / departed / arrived / discharged
Available, delivered, empty returned

You can use this to:

Track discharge-to-gate-out and gate-out-to-delivery times by port and state
See when inland legs in certain regions begin to stretch systematically
Compare inland performance before and after key regulatory dates

Instead of relying on anecdotes (“trucks are harder to get in X”), you work from:

Measurable changes in dwell and transit
Linked to specific ports, ramps, and states

5.3 Build a Simple 2026 Inland Capacity Playbook

You don’t need a 50-page strategy. You need something your teams can use.

Consider:

Watchlist Corridors
- Identify 5–10 lanes where your mix of volume, regulatory risk, and driver dependency is highest
- Refresh performance monthly (or weekly at peak)
Service Options for Key Customers
- Offer “standard” vs “buffered” door-to-door designs:
  - Standard: lower cost, tighter timing, less buffer
  - Buffered: slightly higher cost, more lead time, alternative routing baked in
Let customers choose their risk appetite explicitly
Internal Alignment
- Make sure commercial, operations, and procurement teams share one view of:
  - Which states and ports are most exposed
  - What inland performance looks like in data, not just stories
  - How you’ll adjust contracts and commitments if scenarios worsen