DMV EPN: Enrollment, Driver Reports, and FMCSA Rules

The Employer Pull Notice program, run by the California DMV, is an automated monitoring service that alerts an enrolled employer whenever one of its drivers has a change to their motor vehicle record. Instead of running periodic manual record checks, the employer receives DMV-generated reports whenever a conviction, accident, suspension, or other action hits a driver’s file, plus a routine report each year on the driver’s enrollment anniversary. Enrollment is mandatory for employers of most commercial and for-hire drivers under California Vehicle Code Section 1808.1, and as of April 1, 2026, all EPN transactions must be handled electronically.¹

What Reports You Receive and When

Once a driver is enrolled under your requester code, the DMV monitors that license continuously. A driver record report is generated automatically when any of the following posts to the record: a traffic conviction, a failure to appear in court, a reported accident, a license suspension or revocation, or any other action taken against the driving privilege.¹ That is the core value of EPN: an employee could lose driving privileges on Monday and you know within days, not at the next annual review.

On top of the event-triggered reports, the DMV sends an annual report for every enrolled driver on the anniversary of their enrollment date, whether or not anything changed during the year.² Treat that annual report as a baseline confirmation rather than your primary compliance tool.

Who Has to Enroll

California Vehicle Code Section 1808.1 makes EPN enrollment mandatory based on the license, endorsement, or certificate a driver needs, not the vehicle the company happens to own. Enrollment is required if your driver holds or needs any of the following:³

A Class A or Class B license, covering most commercial trucks, buses, and heavy equipment transport.
A Class C license with an endorsement issued under Vehicle Code Section 15278, including hazmat and passenger endorsements.
A special certificate under Vehicle Code Sections 12517 through 12527, such as school bus, youth bus, or farm labor vehicle operator certificates.
Authority to operate a for-hire passenger vehicle, including charter-party carriers and passenger stage corporations under a Public Utilities Commission certificate or permit, and permitted taxicab companies.

If someone drives one of these vehicles for your organization, they must be enrolled. That means obtaining a requester code from the DMV and enrolling every applicable driver under that code.

Voluntary Enrollment for Other Fleets

Employers outside the mandatory categories can enroll drivers voluntarily. Companies operating standard passenger vehicles, delivery vans, or other non-commercial fleets often do this, and insurance carriers sometimes require it as a condition of fleet coverage. The monitoring works the same way. For non-mandated drivers, the employer must keep a signed waiver on file at the worksite authorizing the record access.

How to Enroll

The application is the DMV form INF 1104, the Employer Pull Notice Program Application. It asks for the company’s legal name, physical and mailing addresses, a designated account contact person, billing information, the Federal Employer Identification Number, and a statement of purpose. Mandatory enrollees under Section 1808.1 must indicate that status; voluntary enrollees must confirm they have signed waivers on file for each driver.

For each driver you list, you’ll need the full legal name and California driver’s license number. License number typos are the most common cause of processing delays, so verify against the physical license before submitting.

Electronic Filing Required From April 1, 2026

Under California Code of Regulations Title 13, Section 350.47, all EPN employers must submit documents, request and receive driver records, and pay invoices electronically starting April 1, 2026.¹ New enrollees use the DMV’s EPN Online Requester portal, replacing the old process of mailing paper forms and checks to the Information Services Branch. Employers already enrolled on paper will need to transition to electronic access.

Once the DMV approves your enrollment, you receive a unique requester code that identifies the employer in every future transaction and attaches to each enrolled driver’s license record.¹ Employers can also authorize a DMV-approved EPN agent to manage the account on their behalf.

Keeping Your Driver List Current

EPN only works if the roster is accurate. Employers must notify the DMV in a timely manner whenever they add new drivers or terminate enrolled ones.¹ Under the electronic system, adds and removals go through the DMV portal or an approved agent. If information on the original application changes, such as the company address or the account contact, submit a Notice of Change form (INF 4) within 10 days.

Removing terminated drivers matters for two reasons. You’ll keep receiving reports, and paying fees, for people who no longer work for you. And your requester code stays attached to that driver’s license record until you remove it, creating an unnecessary open door to their data. Add the removal step to your offboarding checklist.

What to Do With a Negative Report

Receiving the report is the easy part. Acting on it is where the liability lives.

When an EPN report shows a driver’s license has been suspended, revoked, or restricted, pull that person from all driving duties immediately, before you decide anything else. Document the date you received the report, the action you took, and the date the driver was removed from driving assignments.

California treats inaction here as a crime. Under Vehicle Code Section 1808.1(f), an employer who receives a driving record through EPN and then employs or continues to employ a driver against whom a disqualifying action has been taken is guilty of a misdemeanor, punishable by up to six months in county jail, a fine of up to $1,000, or both.³

The civil side is at least as serious. If a driver you knew was suspended, or had a documented pattern of serious violations, causes an accident in a company vehicle, the employer faces a negligent entrustment claim. In those cases, exposure is not confined to standard insurance policy limits, and plaintiffs can pursue company assets. The whole purpose of EPN is to give you the information you need to make the safe call; the reports themselves eliminate the “we didn’t know” defense.

If the driver later resolves the underlying issue and their license is reinstated, run a follow-up record check to confirm reinstatement before restoring driving duties.

Consent and Privacy Rules Before You Enroll

Accessing someone’s driving record touches federal privacy law. Get these steps right before you send in a single driver.

Fair Credit Reporting Act

When a driving record is pulled through a third-party service or consumer reporting agency, it counts as a consumer report under the FCRA. Before requesting it, the employer must give the driver a clear written disclosure, in a standalone document, that a driving record may be obtained for employment purposes, and the driver must authorize the request in writing.⁴

If the employer then plans to take adverse action based on the report, such as reassigning, suspending, or terminating the driver, the FCRA requires a pre-adverse-action notice with a copy of the report and a summary of rights, a reasonable waiting period (generally at least five business days) for the driver to dispute the record, and a final adverse-action notice identifying the reporting agency. For DOT-regulated positions, disclosure and consent can be handled orally or electronically if the application itself was made by phone, mail, or online.⁴

Driver’s Privacy Protection Act

The federal DPPA restricts what state DMVs can release from motor vehicle records. Employers can access records for commercial driver’s license verification and related employment purposes under a specific exemption.⁵ EPN fits inside that framework because the DMV releases the records directly to an enrolled employer. Do not share, sell, or use the records for any purpose beyond safety monitoring and employment decisions.

How EPN Fits With Federal FMCSA Rules

If you operate commercial motor vehicles, EPN does not replace your federal obligations. Under 49 CFR 391.25, every motor carrier must make an annual inquiry into each driver’s record with the appropriate agency in every state where the driver held a commercial license during the preceding 12 months. The driver’s qualification file must document the name of the reviewer, the date, and the results.⁶

An EPN annual report can satisfy 391.25 for California-licensed drivers, but it says nothing about records held in other states. If a driver held a commercial license in Nevada or Arizona during the preceding year, request records from those states separately.

Federal retention rules also apply. Under 49 CFR 391.51, a driver’s qualification file, including all driving record inquiries, must be kept for the entire duration of employment plus three years after the driver leaves.⁷ The three-year clock runs from the termination date, not from the date of the last record. Destroying files too early is a routine audit finding.

1
California DMV. Employer Pull Notice Program
2
California Highway Patrol. General Order 10.13 – Employer Pull Notice Program
3
California Legislative Information. California Code VEH 1808.1 – Records of Department
4
Office of the Law Revision Counsel. 15 USC 1681b – Permissible Purposes of Consumer Reports
5
Office of the Law Revision Counsel. 18 USC 2721 – Prohibition on Release and Use of Certain Personal Information From State Motor Vehicle Records
6
eCFR. 49 CFR 391.25 – Annual Inquiry and Review of Driving Record
7
eCFR. 49 CFR 391.51 – General Requirements for Driver Qualification Files