A Notice of CDL Downgrade is time-sensitive. Request a hearing or submit additional documentation immediately under your state licensing agency’s instructions — you generally have 30 days under 49 CFR §383.73(f)(5). Under FMCSA’s 2026 Non-Domiciled CDL Final Rule (91 FR 7044, effective March 16, 2026), non-domiciled CLP/CDL eligibility after March 16, 2026 is generally limited to drivers who can show qualifying employment-based nonimmigrant status, such as H-2A, H-2B, or E-2, verified through Form I-94/I-94A. Employment Authorization Documents (EADs) alone are no longer accepted for new or reissued non-domiciled CDL eligibility under FMCSA’s current rule. If your state notice lists specific documents, follow the notice carefully and submit whatever the state requests by the deadline. Our compliance specialists can help organize the response file and hearing documentation.