The CSA update and FMCSA's 2025 changes: where they stand
FMCSA announced a wave of changes in 2025. Some took effect, one was withdrawn, and the CSA scoring overhaul is still waiting on a launch date.
Written by Rigo Diaz
The changes in numbers
As of September 2026, the CSA update FMCSA approved in November 2024 still hasn't launched, so the seven BASICs still score you. Digital medical certification is in force, non-domiciled CDLs are limited to three visa types, the speed limiter proposal was withdrawn, and the HOS pilots are set for 2027.
In July 2025 we answered carriers' questions about what we called FMCSA's compliance overhaul. A year later, some of those changes are in force, one was withdrawn, and the biggest one, the CSA update, still has not launched.
I spent more than six years in risk management before I founded Simplex. The lesson that applies here: a rule that has been announced and a rule that is in effect are different risks, and you manage them differently. Here is where each one stands as of September 2026.
The full briefing, read aloud
7 chapters. Select one to jump to it.
Generated with AI text-to-speech from this article's key insights, in order, rather than reading it word for word. Chapter times come from a transcript of the audio. The article itself was written and reviewed by Rigo Diaz.
Key takeaways
The CSA update hasn't launched
FMCSA approved it in November 2024, and it is still "Coming Soon" in September 2026. The seven BASICs still decide your scores.
Your SMS results still change monthly
Violations lose weight at 6 and 12 months and drop off after 24. The next update is the week of October 5, 2026.
Medical status lives on the MVR
Since June 23, 2025, CDL and CLP exam results post electronically to the driver record. The paper-copy exemption ends October 11, 2026.
Fewer drivers qualify for non-domiciled CDLs
Since March 16, 2026, only H-2A, H-2B, and E-2 status holders qualify, for no more than one year at a time.
Speed limiters are off, HOS pilots come in 2027
The speed limiter proposal was withdrawn on July 24, 2025. The two HOS pilots finished small pre-tests in 2026.
In this articleContents
Has the CSA update taken effect?
No. As of September 24, 2026, FMCSA still ranks carriers with the seven BASICs, under SMS methodology version 3.21 revised in May 2026. The CSA update it approved on November 20, 2024 has not launched.
FMCSA said a follow-up Federal Register notice would announce the launch date, and none has been published. Its Prioritization Preview still reads "Coming Soon" and tells carriers to keep using the current SMS website until the new system is in effect. Our July 2025 FAQ said the scoring changes were expected by late 2025. They did not arrive then, and no date has been set since.How often do CSA scores change?
FMCSA recalculates SMS results once a month. The SMS website's data is current as of August 28, 2026, and the next update is scheduled for the week of October 5, 2026. Your percentiles can move even without a new inspection. A violation counts three times in its first six months, twice from 6 to 12 months, and once from 12 to 24 months, then drops out. For what each category measures, see our guide to the 7 CSA BASICs.What will the CSA update change?
The approved changes are published, just not in effect. FMCSA's side-by-side guide lists them.
| Area | SMS today | After the CSA update |
|---|---|---|
| Categories | Seven BASICs | Seven "compliance categories": Controlled Substances/Alcohol and operating-while-out-of-service violations move into Unsafe Driving, and Vehicle Maintenance splits in two |
| Violations | More than 2,000 violation codes | About 100 violation groups of similar safety behaviors |
| Severity weights | 1 to 10 | 1 or 2; a 2 for out-of-service violations, or for driver-disqualifying ones in Unsafe Driving |
| Peer comparison | Safety event groups | Proportionate percentiles based on each carrier's exact number of inspections and crashes |
| 12-month rule | A percentile only with a recent violation in Unsafe Driving and Controlled Substances/Alcohol | Extended to Hours of Service, both Vehicle Maintenance categories, Hazardous Materials, and Driver Fitness |
| Thresholds | Driver Fitness and HM Compliance at 80% for general carriers | Driver Fitness 90% for general carriers; Hazardous Materials 90% for all carriers |
What is Vehicle Maintenance: Driver Observed?
It is a new category for violations a driver could reasonably observe, or an officer could find in a walk-around (Level 2) inspection. All other maintenance violations stay in Vehicle Maintenance. Both keep today's Vehicle Maintenance thresholds: 80% for general carriers, 75% for hazmat carriers, and 65% for passenger carriers.Is there a new CSA points chart?
Not yet. Today's chart is still the 1-to-10 severity scale in SMS Appendix A, and our Unsafe Driving BASIC guide shows how those weights add up. Under the update, a violation weighs 1, or 2 if it is out-of-service or disqualifying. FMCSA's reasoning is the part to act on. Its analysis found that noting a violation occurred mattered more than weighting it precisely, and that carriers with strong safety management have fewer violations per inspection. That makes violations per inspection the number to manage.What changed for driver medical cards?
Since June 23, 2025, CDL and CLP holders' exam results go electronically from FMCSA's National Registry to the state, which posts them to the driver's CDLIS motor vehicle record. Drivers with a current certificate no longer have to carry the paper card.
For carriers, the check moves to the MVR. Under 49 CFR 391.23(m)(2), you verify an interstate CDL driver's valid medical certification on the CDLIS record before letting them drive, a step our guide to hiring drivers safely walks through.Can drivers still use a paper medical card?
Only until October 11, 2026. While states caught up, FMCSA let carriers and drivers rely on a paper copy: for 15 days after the exam under a July 14, 2025 waiver, for 60 days from August 21, 2025, and since April 11, 2026 under a six-month exemption. FMCSA says it does not expect more nationwide waivers or exemptions after that. When the exemption was granted, five states had not implemented the electronic system: Alaska, California, Kentucky, Louisiana, and New Hampshire. The National Registry now lists only Alaska.What if a driver's medical status doesn't update?
The state marks the driver "not certified" within 10 days of the certificate expiring or becoming invalid, and must complete the CDL downgrade within 60 days. Check the MVR after every new exam, not only at renewal.Can you still hire drivers with non-domiciled CDLs?
Yes, if the driver holds a current, validly issued CDL, but far fewer drivers now qualify. Since March 16, 2026, a state may issue or renew a non-domiciled CDL for a foreign-domiciled driver only with an unexpired foreign passport and an I-94 showing H-2A, H-2B, or E-2 status. Employment authorization documents no longer qualify, and states must verify status through the federal SAVE system.
The path there took four steps. FMCSA announced a nationwide audit of state non-domiciled CDL practices on June 27, 2025, issued an interim rule on September 29, 2025, saw it stayed by the D.C. Circuit in November 2025, and published a final rule on February 13, 2026. The audit has teeth. In New York, FMCSA found 107 of 200 sampled records issued in violation of federal law, and in April 2026 it moved to withhold $73.5 million from the state for not revoking them. If a state revokes or downgrades a driver's license, that driver can't drive a CMV for you.- A non-domiciled CDL is now valid only until the driver's I-94 date or for one year, whichever is sooner
- If a federal agency tells the state the holder has lost qualifying status, the state must downgrade the license within 30 days
- Pull the MVR at hire and at every renewal, and track each expiration date
What happened to the HOS pilots, speed limiters, and DataQs?
Are the HOS pilot programs running?
Not for most drivers yet. FMCSA proposed both pilots on September 17, 2025, ran pre-tests with nine drivers each between April and July 2026, and plans the full launch in 2027 with 256 drivers per pilot.
- Flexible Sleeper Berth: split the 10 hours off duty into two periods in any combination, as long as one includes at least five consecutive hours in the berth
- Split Duty Period: pause the 14-hour window for 30 minutes to 3 hours of off-duty, sleeper berth, or on-duty time at a pickup or delivery
What happened to the speed limiter rule?
It was withdrawn. On July 24, 2025, FMCSA and NHTSA withdrew the 2016 proposal to require speed limiters on trucks over 26,000 pounds, and FMCSA withdrew its 2022 follow-up notice, citing policy and safety concerns and gaps in the data.What changed in DataQs?
For requests submitted on or after September 18, 2026, states must use a three-stage review with deadlines: 21 days for the initial review, 21 for reconsideration, and 45 for the final review. The issuing officer can no longer be the only one to deny a correction, per FMCSA's announcement.What about English language proficiency?
Since May 2025, drivers who fail FMCSA's English language proficiency requirement are placed out of service. On August 10, 2026, FMCSA proposed writing that into the regulations, with comments due October 9, 2026. Our English proficiency FAQ covers the details.
What should carriers do now?
Each step manages a rule that is in force today, or gets you ready for the one that isn't.
Step 1: Keep watching your SMS results monthly
The BASICs still drive warning letters and investigations. Check after each monthly update, and if a category is climbing, our CSA program team can help find the violations behind it.Step 2: Preview your results under the CSA update
Log in to the Prioritization Preview to see whether you would be prioritized under the new method. Look hardest at the new Driver Observed category, where walk-around defects will land.Step 3: Check every CDL driver's medical status on the MVR
Do it before the paper-copy exemption ends on October 11, 2026, and after every new exam.Step 4: Track non-domiciled license dates
Record each driver's CDL expiration, which can be no more than a year out, and re-pull the MVR at every renewal.Step 5: Challenge bad data through DataQs
A wrong violation can weigh on your scores for up to 24 months. File with your evidence; under the new process, states have fixed deadlines to answer.How Simplex helps you keep up with FMCSA changes
Some of these rules score you every month, others take a driver off the road. We help with both.
Help with a high CSA score
Our CSA program team monitors driver performance and designs and implements the policies and training behind a better score.
Compliance that keeps checking
Our compliance programs include driver qualification file management, CSA monitoring, mock audits, and HOS management.
Your scores and expiring documents in one place
SimplexHub shows your BASIC scores and 24 months of inspections and violations linked to drivers and equipment, and helps manage expiring documents.
Frequently asked questions
What is the latest CSA update?+
How often do CSA scores change?+
Is there a new CSA points chart for 2025 or 2026?+
What happened to the FMCSA speed limiter rule?+
Can brokers and shippers see my CSA scores?+
Will these changes affect my insurance premiums?+
Where this information comes from
The status of each change below comes from FMCSA's own notices, rules, and websites, checked on September 24, 2026.
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1
Federal Register — Enhanced Carrier Safety Measurement System (89 FR 91874)
The November 2024 approval of the CSA update, and the promised launch notice.
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2
FMCSA — Approved Changes to the SMS Methodology
Side-by-side comparison: categories, violation groups, 1-or-2 weights, thresholds, 12-month rule.
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3
FMCSA — CSA Prioritization Preview
"Coming Soon" status and the instruction to keep using the current SMS until launch.
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4
Federal Register — NRII paper certificate exemption (91 FR 19255)
The June 23, 2025 change, the 2025 waivers, and the exemption ending October 11, 2026.
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5
eCFR — 49 CFR 383.73
Medical status downgrade deadlines and the one-year limit on non-domiciled CDLs.
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6
Federal Register — Non-domiciled CDL final rule (91 FR 7044)
H-2A, H-2B, and E-2 eligibility, the March 16, 2026 effective date, and the court stay of the interim rule.
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7
Federal Register — Speed limiting devices withdrawal (90 FR 34822)
Withdrawal of the 2016 speed limiter proposal and the 2022 follow-up notice.
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8
FMCSA — HOS pilot programs update (Aug 27, 2026)
Pre-test dates, pilot rules, and the planned 2027 launch.
Written by
Rigo Diaz
Founder & CEO, Simplex Group
Founder and CEO of Simplex Group, with more than 25 years leading the company and helping trucking entrepreneurs navigate compliance, insurance, and the day-to-day demands of running a carrier. Before founding Simplex, he spent more than six years in risk management, experience that continues to shape how he approaches insurance, compliance, and carrier risk today.
Published · Updated
Related articles and services
Manage the rules in force, and preview the one that's coming
The BASICs still score you every month, medical status lives on the MVR, and non-domiciled licenses carry new limits. The CSA update will arrive with its own notice, and you can see its effect on you today.
If you want a second set of eyes on your SMS results or your driver records before these dates arrive, talk to our team.