CDLIS vs FMCSA Clearinghouse: two federal systems, two different jobs
CDLIS is the AAMVA-operated pointer database that lists every state where a CDL driver has been licensed since 1996, used by carriers and screening agents to fan-out MVR requests for the §391.23(a) multi-state lookback. The FMCSA Clearinghouse is the federal database of drug-and-alcohol testing program violations under 49 CFR Part 382, recording positive tests, refusals, and return-to-duty status. Both are CDL-only and both are required for pre-employment, but they answer entirely different questions: CDLIS answers "which DMV records do I need to pull?" while the Clearinghouse answers "is this driver currently prohibited from safety-sensitive functions?" The §382.701(a) Clearinghouse pre-employment full query requires per-driver electronic consent through the FMCSA portal and returns detailed violation history; the CDLIS pointer pull is documented under FCRA and DPPA. Both are mandatory under 49 CFR §391.23 before a CDL driver can be hired.
Side-by-side comparison
| Dimension | CDLIS | Clearinghouse |
|---|---|---|
| Operator | AAMVA (under contract to FMCSA) | FMCSA directly |
| What it tracks | CDL license events: issuance, conviction, withdrawal, disqualification | Drug & alcohol testing program violations under 49 CFR Part 382 |
| Population | Every CDL holder since 1996 | Every CDL holder subject to 49 CFR Part 382 testing |
| CFR anchor | §391.23(a) | §382.701(a) + §382.701(b) |
| Consent | DPPA + state DMV access rules + FCRA | Driver-specific Clearinghouse consent (full or limited) |
| Pre-employment requirement | Indirect - needed to know which state DMVs to query under §391.23(a) | Direct - full query required before any safety-sensitive function |
| Annual requirement | Not required annually | Limited query required annually under §382.701(b) |
| Cost | ~$2-$5 per pull (bundled with state MVRs) | $1.25 per query (FMCSA fee) |
When to choose CDLIS
CDLIS is the only practical way to satisfy the §391.23(a) requirement to investigate the driver's license history in every state where the driver held a license during the prior 3 years. Without CDLIS, the carrier has no way to know which states to query - drivers do not always self-report cross-state CDL history accurately on the application.
The CDLIS pull returns the list of states; the carrier then orders an MVR from each listed state to assemble the actual conviction record. CDLIS itself does not contain conviction detail - only pointers.
When to choose the Clearinghouse
The Clearinghouse is the only source for federal drug-and-alcohol testing program violations. A pre-employment full query under §382.701(a) is required before the driver performs any safety-sensitive function for the new carrier. The query returns whether the driver has any unresolved testing violations on file (positive test, refusal, return-to-duty pending, etc.).
An annual limited query under §382.701(b) is also required for every CDL driver in the carrier's pool - it returns "information present" or "no information present." If information is present, the carrier has 24 hours to obtain driver consent for a full query.
Why both are required for CDL pre-employment
The two reports answer non-overlapping questions. CDLIS plus state MVRs covers conviction history; the Clearinghouse covers drug-and-alcohol testing history. The §391.23 file is not complete without both. The bundled DOT Pre-Employment package adds PSP for the on-road inspection record so the four-report stack covers the full §391.23(d) investigation surface in a single intake.
Frequently asked questions
Are CDLIS and the Clearinghouse the same database?
No. CDLIS is operated by AAMVA and tracks every state where a driver has held a CDL since 1996. The Clearinghouse is operated by FMCSA and tracks federal drug-and-alcohol testing program violations under 49 CFR Part 382. Different operators, different scopes, different consent flows.
Do non-CDL drivers appear in either system?
Non-CDL drivers do not appear in CDLIS (it is CDL-only by design) and are not in scope for the Clearinghouse (which only covers drivers operating CMVs that require a CDL under 49 CFR Part 383). Non-CDL screening typically uses MVR + PSP only.
Which one is required for pre-employment?
Both are required for CDL drivers under different rules. CDLIS is required under §391.23(m)(2) and is also how the carrier knows which state DMVs to query for the prior-3-year license history under §391.23(a). The Clearinghouse pre-employment query is required under §382.701(a) before the driver performs any safety-sensitive function.
Run CDLIS + Clearinghouse together
The DOT Pre-Employment package bundles MVR + CDLIS + PSP + the §382.701(a) Clearinghouse pre-employment query for $100, with one driver-consent form covering all four sources.
Run a report - from $40