Since February 7, 2022, anyone obtaining a Class A or Class B CDL for the first time, upgrading to Class A or B, or seeking a passenger, school bus, or hazardous materials endorsement for the first time must complete entry-level driver training from a provider listed on FMCSA's Training Provider Registry before taking the relevant test (49 CFR 380.609 and 383.71). ELDT sets no minimum number of behind-the-wheel hours — the instructor must evaluate and document proficiency (380.715), and the trainee must score at least 80 percent on the theory assessment. Drivers issued the credential before February 7, 2022 are grandfathered for that credential.
Part 380 contains two separate federal training mandates that happen to share a part number. Subpart F is entry-level driver training (ELDT) — the training a person must complete before a State will let them test for certain CDL credentials — and Subparts A through D are the longer combination vehicle (LCV) training rules for drivers of doubles and triples over 80,000 pounds. Subpart G governs the Training Provider Registry that makes ELDT enforceable.
For most carriers, ELDT is the whole story: since February 7, 2022, a driver cannot get a first Class A or Class B CDL, or a first passenger, school bus, or hazardous materials endorsement, without training from a registered provider.
Who must complete entry-level driver training?
49 CFR 380.609 states the rule in two paragraphs. Paragraph (a): an individual who applies, for the first time, for a Class A or Class B CDL, or who upgrades to a Class A or B CDL, must complete driver training from a provider listed on the Training Provider Registry. Paragraph (b): an individual seeking a passenger (P), school bus (S), or hazardous materials (H) endorsement for the first time must complete the training related to that endorsement from a TPR-listed provider.
49 CFR 383.71 is the enforcement hook on the licensing side: the applicant must complete the Part 380 Subpart F training before taking the skills test for a first Class A or B CDL or a first P or S endorsement, or before the knowledge test for a first H endorsement. The State will not administer the test until the completion record appears in the registry.
Five practical points follow from the wording:
- “For the first time” is per credential, not per driver. A driver with a Class B who upgrades to Class A must complete Class A ELDT. A veteran Class A holder adding a first tank endorsement does not — N is not on the list.
- Only four credentials trigger ELDT: Class A, Class B, P, and S by skills test, and H by knowledge test. Tank (N) and doubles/triples (T) do not.
- The H endorsement is knowledge-only, so its ELDT is theory-only. There is no BTW component for hazmat.
- ELDT is a prerequisite to testing, not to hiring. It is completed before the license exists.
- It applies in intrastate commerce too, because it operates through the CDL, and Part 383 reaches intrastate operations.
Who is exempt from ELDT?
49 CFR 380.603(a) excepts four groups:
- Drivers excepted from the CDL requirements under 49 CFR 383.3(c), (d), and (h) — the mandatory military exception, the State-optional farm, firefighter and emergency responder, and snow and ice removal exceptions, and drivers of covered farm vehicles.
- Drivers applying for a restricted CDL under 49 CFR 383.3(e) through (g) — isolated Alaska roads, farm-related service industries, and pyrotechnic operations.
- Certain military drivers with CMV experience who qualify for the skills test substitute in 49 CFR 383.77.
- Individuals applying to remove a CDL restriction under 49 CFR 383.135(b)(7).
Separately, 380.603(b) grandfathers credentials already held: drivers issued a Class A CDL, Class B CDL, or a P, S, or H endorsement before February 7, 2022 are not required to comply for that credential. The grandfather runs with the credential, not the person. A driver grandfathered on Class B who upgrades to Class A after that date must complete Class A ELDT like anyone else, and the same is true of adding a first P, S, or H endorsement.
What does ELDT actually cover, and how many hours are required?
The curricula sit in Appendices A through E to Part 380 and split into theory and behind-the-wheel instruction. 49 CFR 380.715 sets the standards for both:
- Theory (380.715(a)). Providers must use written assessments to determine proficiency in the knowledge objectives of each unit of instruction. The trainee must receive an overall minimum score of 80 percent on the theory assessment.
- Behind-the-wheel (380.715(b)). Instructors must evaluate and document the trainee’s proficiency in the BTW skills in the applicable curriculum.
There is no minimum number of behind-the-wheel hours anywhere in the rule. This surprises people, and it is deliberate: FMCSA made BTW completion proficiency-based rather than time-based, so the standard is what the instructor documents, not what a clock says. Providers still have to report the hours — 380.717 requires the total clock hours of BTW training in the certification submission — but the hours are data, not a threshold.
BTW training divides into range training and public road training, both defined in 49 CFR 380.605 as time when the trainee has actual control of the power unit, explicitly excluding observation time. A trainee sitting in the passenger seat is not accruing BTW training.
Who can deliver ELDT, and what is the Training Provider Registry?
The Training Provider Registry is FMCSA’s public list of entities authorized to deliver entry-level driver training. Training from an entity not on it does not count, no matter how good the training was.
49 CFR 380.703 sets eligibility. A provider must follow a curriculum meeting the criteria in Appendices A through E, use facilities meeting 380.709 and vehicles meeting 380.711, employ instructors meeting 380.713, be licensed, certified, registered, or authorized to provide training under the laws of any State where in-person training is conducted (State requirements for theory instruction do not apply to online-only offerings), allow FMCSA or its representatives to audit or investigate its operations, and submit the Entry-Level Driver Training Provider Registration Form through the TPR website to receive a unique TPR number.
Instructor standards come from the definitions in 380.605. A behind-the-wheel or theory instructor must hold a CDL of the same or higher class with all endorsements necessary to operate the CMV involved, and have either at least 2 years of experience driving a CMV requiring that class and/or endorsement, or at least 2 years of experience as a BTW CMV instructor — plus meet all applicable State qualification requirements for CMV instructors. An instructor who provides range training only need not hold a current CDL if they previously held the required license. And an instructor whose CDL was cancelled, suspended, or revoked for an offense listed in 49 CFR 383.51 may not instruct for two years after reinstatement.
49 CFR 380.707 adds three provider duties worth knowing before you sign a training contract: applicants accepted for BTW training must self-certify that they will comply with Parts 40, 382, 383, and 391 and applicable State and local law on testing, age, medical certification, licensing, and driving records; the provider must verify each accepted applicant holds a valid CLP or CDL; and while theory and BTW may be delivered by different entities, the range and public road portions of BTW must be delivered by the same provider.
Can a motor carrier train its own drivers?
Yes. The definition of “training provider” in 380.605 expressly includes motor carriers, and many carriers run their own registered schools. Registering means accepting the provider obligations: the Subpart G curriculum, facility, vehicle, and instructor standards, the two-business-day reporting deadline, the three-year record retention, and FMCSA’s audit right.
FMCSA may remove a provider from the registry under 49 CFR 380.721 for failing to meet the requirements for continued listing, denying an audit, material deficiencies found in an audit, falsely claiming State authorization, or on the basis of the State-administered CDL test passage rate for its graduates. Any training conducted after the removal date is invalid — which is why a carrier sourcing training from a third party should confirm the school’s TPR listing at the time each trainee attends, not once at contract signing.
What are the Part 380 deadlines and record retention periods?
| Requirement | Citation | Deadline or retention period |
|---|---|---|
| Complete ELDT before the first Class A or B CDL skills test, or an upgrade to Class A or B | 49 CFR 380.609(a); 383.71 | Before the skills test |
| Complete ELDT before a first P or S endorsement skills test | 49 CFR 380.609(b); 383.71 | Before the skills test |
| Complete ELDT before a first H endorsement knowledge test | 49 CFR 380.609(b); 383.71 | Before the knowledge test |
| Minimum theory assessment score | 49 CFR 380.715(a) | 80 percent overall |
| BTW proficiency | 49 CFR 380.715(b) | Instructor evaluates and documents; no minimum hours |
| Provider transmits training certification to the TPR | 49 CFR 380.717 | By midnight of the second business day after completion |
| Provider retains self-certifications, CLP/CDL copies, instructor qualifications, lesson plans, assessment records | 49 CFR 380.725(b), (c) | 3 years from the date each record is generated or received |
| Provider updates its TPR registration form | 49 CFR 380.719(a)(2) | Biennially |
| Provider reports changes to key information (name, address, phone, training types, status, State licensure) | 49 CFR 380.719(a)(3) | Within 30 days of the change |
| Provider produces required documentation to FMCSA on request | 49 CFR 380.719(a)(6) | Within 48 hours of the request |
| LCV Driver-Training Certificate filed in the driver qualification file | 49 CFR 380.401 | On completion; kept in the DQ file |
Note what is not on this list: there is no federal requirement for a motor carrier to keep an ELDT certificate in a driver qualification file. The record lives with the provider and in the registry. The carrier-side record you must keep is the LCV certificate under 380.401.
What does Part 380 require for longer combination vehicles?
Subparts A through D address LCVs. 49 CFR 380.105 defines one as any combination of a truck-tractor and two or more trailers or semitrailers operating on the Interstate System at a gross vehicle weight greater than 80,000 pounds — an LCV double with two trailers, or an LCV triple with three.
Under 49 CFR 380.107, a driver who wants to operate an LCV must first successfully complete an LCV driver-training program covering the knowledge and skills in Appendix F, must present evidence of meeting the Subpart B prerequisites before training begins (the instructor verifies this), and receives an LCV Driver Training Certificate from a certifying official on completion. 49 CFR 380.401 then puts the certificate in your hands: the driver must provide a copy to the employer to be filed in the driver qualification file.
The grandfathering route in 49 CFR 380.111, which let experienced doubles and triples drivers substitute two years of clean qualifying experience for the training, closed long ago — it was available only during the year following June 1, 2004. Do not rely on it for a current hire.
What auditors actually check
ELDT surfaces in an investigation indirectly, because the primary record sits with the training provider rather than with you. What an investigator can and does check:
- That the CDL itself is valid for the class and endorsements the driver is operating under. If ELDT was skipped, the State would not have issued the credential — so an anomalous license is the thread they pull.
- The driver qualification file under Part 391, which is where an LCV Driver-Training Certificate must be filed if the driver operates LCVs.
- Whether a carrier that is itself a registered training provider met the Subpart G obligations: instructor qualifications on file, lesson plans, assessment records, trainee self-certifications and CLP/CDL copies, all retained three years and producible within 48 hours.
- CLP supervision practices for trainees still in training, under 49 CFR 383.25 — the supervising CDL holder must be in the front seat.
- Drug and alcohol program coverage of trainees. A driver-trainee operating a CMV on a public road is subject to Part 382, and 380.707(a) requires the provider to obtain that self-certification.
If you are a carrier-school, the practical difficulty is item 3: five categories of record, three-year clocks, and a 48-hour production window. That is a documents problem more than a training problem, and it is the same document-expiry discipline that compliance tracking exists to handle. The DOT audit preparation walkthrough covers how the driver file should be assembled around it.
Most common Part 380 problems
- Assuming a grandfathered driver is grandfathered for everything. The exemption in 380.603(b) is credential-specific. Upgrading Class B to Class A after February 7, 2022 requires ELDT.
- Using a provider that is not on the registry, or was removed. Training conducted after a removal date is invalid under 380.721, and the trainee will be blocked at the testing stage with no recourse against the State.
- Missing the two-business-day reporting deadline (380.717). The most common operational failure at carrier-run schools, and it directly delays the trainee’s test.
- Treating observation as behind-the-wheel time. 380.605 excludes observation from both range and public road BTW training.
- Splitting range and public road BTW between two providers, which 380.707(c) forbids.
- Letting an instructor’s qualification lapse — the two-year experience basis, State instructor credentials, or the two-year bar after a 383.51-related CDL reinstatement.
- Skipping the biennial registration update (380.719(a)(2)), which is grounds for removal from the registry.
- Assuming ELDT satisfies a hazmat endorsement. ELDT theory training is required for a first H endorsement, but the driver still needs the TSA security threat assessment.
Frequently asked questions
Who has to complete entry-level driver training? Anyone applying for a first Class A or Class B CDL, upgrading to Class A or B, or seeking a first P, S, or H endorsement — from a TPR-listed provider, before the relevant skills or knowledge test (49 CFR 380.609, 383.71).
Is a driver who got a CDL before February 7, 2022 required to take ELDT? No, not for that credential (380.603(b)). But a grandfathered Class B holder upgrading to Class A, or adding a first P, S, or H endorsement, does have to complete ELDT for the new credential.
How many hours of behind-the-wheel training does ELDT require? None specified. 380.715(b) makes BTW completion proficiency-based, evaluated and documented by the instructor. The theory portion requires an overall minimum score of 80 percent (380.715(a)).
What is the Training Provider Registry? FMCSA’s list of entities authorized to deliver ELDT. 380.703 sets the curriculum, facility, vehicle, instructor, State authorization, and audit-access requirements a provider must meet to be listed and receive a TPR number.
Can a motor carrier train its own drivers? Yes — “training provider” in 380.605 includes motor carriers. A carrier that registers takes on the full set of Subpart G provider obligations, including three-year record retention under 380.725.
Who is exempt from ELDT? Under 380.603(a): drivers excepted from CDL requirements under 383.3(c), (d), and (h); restricted-CDL applicants under 383.3(e)–(g); certain military drivers under 383.77; and individuals removing a restriction under 383.135(b)(7).
How quickly must a provider report a completed course? By midnight of the second business day after completion, with the data listed in 380.717 — including total BTW clock hours and the provider’s TPR number.
What training does Part 380 require for longer combination vehicles? An LCV driver-training program covering Appendix F before operating a truck-tractor with two or more trailers over 80,000 pounds GVW on the Interstate System (380.105, 380.107), with the resulting certificate filed in the driver qualification file (380.401).
Where to go next
ELDT feeds directly into Part 383, which defines the license the training unlocks, and into Part 391, which defines the file you keep on the driver afterward. Trainees operating a CMV on a public road are already covered by Part 382. Browse the 49 CFR reference library, the DOT compliance guide, or the FMCSA regulations overview. New CDL holders can start with our driver resources.
This is a plain-English summary of 49 CFR Part 380, not legal advice. Read the current regulation at Cornell LII and check FMCSA’s Training Provider Registry directly for a provider’s current listing status.
Note: This is a plain-English summary of 49 CFR Part 380, current as of the date above, and is general information rather than legal advice. The regulation itself is controlling — read it on the eCFR and confirm current requirements with the FMCSA.