Do you still need a paper medical card in the DQ file in 2026?

Usually you don't need it, and two things decide whether you're in the usual case: which state licensed the driver, and how recently they were examined.

For a CDL or CLP driver licensed in one of the 45 states that have implemented FMCSA's electronic system, the record you keep in the driver qualification file is the driver's CDLIS motor vehicle record showing medical certification status. The paper card is no longer the record.

For a driver licensed in Alaska, California, Kentucky, Louisiana, or New Hampshire, the paper card is still the record, because those five states had not implemented the electronic system as of FMCSA's most recent notice. And for any driver examined in the last 60 days, a paper card may be the only proof that exists yet, which is why FMCSA has an exemption in place through October 11, 2026.

Get this wrong in either direction and you can fail an audit over a document you thought you didn't need, or put a driver out of service over one you thought was optional. Here is what changed and exactly what a compliant file holds now.

What changed with National Registry II?

FMCSA's Medical Examiner's Certification Integration rule, known as National Registry II or NRII, moved medical certification from paper to an electronic record. The rule was published in April 2015 and its compliance date, after several extensions, landed on June 23, 2025.

Here is the flow. A certified medical examiner completes the exam and submits the result to FMCSA's National Registry. FMCSA transmits the result and any medical variance information to the state driver licensing agency. The state posts it to the driver's CDLIS motor vehicle record, the Commercial Driver's License Information System MVR.

Two changes took effect for CDL and CLP holders on that date:

• Medical examiners are no longer required to issue the paper Medical Examiner's Certificate, Form MCSA-5876, to CDL and CLP holders.
• CDL and CLP holders no longer submit a paper certificate to their state licensing agency, under 49 CFR 391.43(g)(2)(ii).

Note what did not change. Drivers still have to be medically qualified under 49 CFR 391.41, and driver qualification files are still governed by 49 CFR 391.51. The obligation is identical. Only the form of the proof moved.

What does a compliant DQ file need now for CDL drivers?

In a state that has implemented NRII, the record you keep is the CDLIS MVR showing the driver's medical certification status and expiration date. That document does the job the paper card used to do.

In practice:

1. After each exam, pull the driver's CDLIS MVR showing the updated certification status and expiration date.
2. Keep that MVR in the driver's DQ file as your proof of medical certification.
3. Track the expiration date so you pull a fresh MVR when the driver re-certifies.

The work is the same as it always was. You are proving the driver is medically certified and current. You are just proving it with the state's electronic record.

Do I still have to verify the medical examiner is on the National Registry?

For CDL and CLP drivers, no. That requirement ended on June 22, 2025.

The DQ file rule at 49 CFR 391.51(b)(8)(ii) required a note verifying the medical examiner's listing on the National Registry only "through June 22, 2025" for drivers required to have a CDL. The date was written into the regulation, so it expired on its own without a new rulemaking. The text is still sitting there in the CFR, past tense buried in a present-tense list, which is why plenty of DQ file checklists still tell you to do it.

Two things this does not mean:

• Non-CDL drivers still need the note. 49 CFR 391.51(b)(8)(i) requires it for drivers not required to have a CDL, referencing 49 CFR 391.23(m)(1), and no sunset date is attached to it. If you run non-CDL CMV drivers, keep verifying and keep the note.
• The exam still has to come from a certified examiner. The verification paperwork went away. The underlying requirement that the examination be performed by a medical examiner listed on the National Registry did not. And if you are relying on the paper card exemption, its terms require the certificate to have been issued by a certified medical examiner within the prior 60 days.

One judgment call. The sunset in the regulation is a flat date with no state condition attached. But the provision that puts the MVR in the file, 49 CFR 391.51(b)(6)(ii), applies only if the CDLIS motor vehicle record actually contains medical certification status information. In the five states that have not implemented NRII, it doesn't, so you fall back to keeping the certificate itself. Read strictly, that means you keep the paper card in those states but no longer need the verification note. That is a thin position to defend in an audit for something that takes one line to document, so in those five states we would keep generating the note.

Then nothing has changed for that driver, and the paper card is still your record.

As of FMCSA's April 2026 exemption notice, 45 states and the District of Columbia had implemented NRII. Alaska, California, Kentucky, Louisiana, and New Hampshire had not, and were continuing to rely on the paper Medical Examiner's Certificate. California has the largest CDL driver population in the country, so this is not a rounding error.

That list has been shrinking. It was twelve states in August 2025, nine in January 2026, and five in April 2026. Because it moves, do not work from a list you read somewhere, including this one. FMCSA maintains the current status on its NRII Learning Center, and that is the source to check before you change a driver's file.

If you run drivers licensed in more than one state, you are running two processes at once, and the dividing line is the state on the license, not where the truck is based.

What is the paper card exemption running through October 11, 2026?

It is a six-month exemption that lets carriers and drivers rely on a paper Medical Examiner's Certificate as proof of medical certification for up to 60 days after the certificate was issued. It runs from April 11 through October 11, 2026, and it applies in every state and the District of Columbia.

The reason it exists is the gap. A driver gets examined and qualified, the examiner files the result, and the data takes days or sometimes weeks to appear on the state's CDLIS record. During that gap the driver is genuinely certified but the record does not show it. Without relief, a qualified driver gets written up for a delay they had no control over.

Where the 60 days comes from is worth knowing. Before NRII, carriers and drivers could rely on a paper certificate for 15 days. That 15-day allowance expired on June 22, 2025. FMCSA then issued a waiver in July 2025 restoring it, stretched it to 60 days in August 2025, reissued it twice, and in April 2026 converted it to this exemption. Same relief, different legal instrument. The Commercial Vehicle Safety Alliance applied for it, and it carries binding terms and conditions rather than being a courtesy.

For the DQ file, treat it as a clock rather than a permanent arrangement:

• Days 1 to 60 after the exam. A copy of the paper certificate in the DQ file works as your proof.
• By day 60. The CDLIS MVR showing the certification needs to be in the file. The paper copy stops carrying you.

Keeping the paper copy in the file after the MVR arrives does no harm and is reasonable practice. Just know the MVR is what has to be there.

Does the driver still have to carry a paper card?

If you are relying on the exemption, yes, and this is the condition carriers overlook.

The exemption has two terms. It does not apply to a driver who does not have a copy of their current, valid certificate on their person, issued by a certified medical examiner within the prior 60 days. And it does not apply to a motor carrier that does not have a copy of that certificate. Both have to be true.

So during the exemption window, a driver whose certification has not yet posted to their MVR and who left the card at home is not covered. That is a roadside problem, not a paperwork problem. If your drivers are inside that 60-day window, the card rides with them.

One more detail that matters at a scale house: while the exemption is in effect, no state may enforce a law or regulation applicable to interstate commerce that conflicts with it. States can extend the same relief to intrastate operations, but they are not required to.

What happens after October 11, 2026?

The exemption expires and the CDLIS MVR becomes the proof of medical certification for CDL and CLP drivers in states that have implemented NRII.

FMCSA was unusually direct about what comes next. In granting this exemption, the agency stated that it does not anticipate granting additional nationwide NRII waivers or exemptions after the six-month period, and told states, carriers, and drivers not to expect them. That is a change in tone from the last year, which produced four rounds of relief in a row.

Take that at face value and plan for the deadline. Also stay honest about the track record: the dates in this transition have moved repeatedly, and this is the sixth deadline in eighteen months. Confirm the current status on FMCSA before you change your process. If something has shifted again, FMCSA is the source of truth, not an article.

What about non-CDL CMV drivers?

This is the part carriers miss most often. The electronic transition applies to CDL and CLP holders. It does not apply to non-CDL CMV drivers.

Non-CDL CMV drivers still receive the paper Medical Examiner's Certificate, and you still keep a copy in their DQ file the way you always have. No MVR, no electronic record, no change.

So a mixed fleet in 2026 runs three patterns at once, and it is worth writing them down before your next audit:

• CDL driver, NRII state. CDLIS MVR in the file, plus the paper card during the first 60 days after an exam. No National Registry verification note.
• CDL driver, one of the five non-NRII states. Paper card in the file, as before. The verification note is no longer required by rule, though keeping it is the safer call.
• Non-CDL CMV driver. Paper card in the file, and the National Registry verification note, both as before.

What if the MVR doesn't show the driver's certification?

Do not assume the driver is unqualified, and do not assume your file is fine either. Verify before you act.

Even among states that have implemented NRII, the data exchange has produced incompatibility and transmission errors, and CVSA raised this with FMCSA directly. A missing or stale certification on an MVR can mean the driver is not certified, or it can mean the record has not caught up.

What to do when the MVR comes back wrong:

1. Confirm the exam itself. Get the exam date and the examiner's information from the driver.
2. If the exam is inside 60 days and the exemption is still in effect, keep the paper copy in the file and keep the driver carrying theirs.
3. Pull the MVR again on a schedule until the certification posts.
4. If it does not post and the exam is well outside 60 days, treat it as a qualification problem and take the driver off dispatch until it is resolved.

The wider lesson holds beyond this one rule. When the proof of compliance lives in someone else's system, you still own the consequence of it being wrong. Keep your own records and check that the official record matches them.

The bottom line

For most CDL drivers, the paper card is no longer the record. The CDLIS MVR is. For CDL drivers licensed in Alaska, California, Kentucky, Louisiana, or New Hampshire, and for every non-CDL CMV driver, the paper card is still the record. And through October 11, 2026, any driver examined in the last 60 days should have a card in hand and a copy in the file.

This is the kind of change that quietly breaks a DQ file. The rule moved, the document moved with it, the deadline moved four times, and a file that was complete last year can be short one record this year without anyone noticing until an auditor asks. Nobody built a trucking company to track waivers in the Federal Register.

Dotra keeps every DQ file complete as the rules move, including which record each driver actually needs. Start your free trial or book a demo to see it.

This article explains public FMCSA requirements as of August 5, 2026 and is not legal advice. Confirm current NRII state status and exemption dates with FMCSA before changing your process.