Possibly yes. The DOL FAQ released on May 14, 2026, clarifies that even where certain agricultural drivers may be exempt from CDL requirements, they may still be subject to FMCSA’s driver-qualification rules — including the ELP requirement under 49 CFR §391.11(b)(2) — when operating a commercial motor vehicle in interstate commerce. The CDL exemption does not automatically exempt the driver from the broader driver-qualification framework. Agricultural H-2A employers should review their CMV operations carefully and ensure the ELP qualification is explicit in their job orders before the June 13, 2026, effective date.