When FMCSA unveiled its Interim Final Rule (IFR) on non-domiciled commercial driver’s licenses in late September 2025, the agency portrayed it as an urgent safety measure—one that needed to take effect immediately, without the usual notice-and-comment process and without the statutory consultation with state licensing agencies. By sharply narrowing which foreign-domiciled drivers could obtain or renew a CDL in the United States, the rule had the potential to immediately resha