What 383.25A2 means in plain language
FMCSR 383.25A2 covers a specific licensing violation: operating a commercial motor vehicle while holding only a Learner's Permit (CLP) instead of a full, valid state driver's license. This is distinct from not having a CDL at all—it's about the foundational state license requirement.
When you're in the learning phase and hold a CLP, you're not yet authorized to operate a CMV independently on public roads. The regulation requires that any person operating a CMV must have a valid state driver's license. A CLP does not satisfy that requirement. The violation occurs the moment you operate that vehicle without the valid underlying state license.
What our enforcement data actually shows
Across 13 million inspections in our database, 383.25A2 appears 220 times all-time, with 140 citations in the last 12 months and 22 in the last 90 days. This ranks it #1195 out of 3,036 FMCSR codes by citation volume—relatively uncommon overall, but when it does occur, the enforcement response is swift and severe.
Our inspection records show a 98.6% out-of-service rate for this violation. That means of the 220 all-time citations, 217 resulted in the vehicle being placed out of service at roadside. Compare that to the all-FMCSR average out-of-service rate of 31.4%: this code is enforced nearly three times more aggressively than the typical violation. When you're cited for operating without a valid state license, you're almost certainly not driving that truck away from the inspection.
Who gets cited most
Over the last 180 days, our data shows Georgia leads with 8 citations, followed by Tennessee with 7, and Washington with 6. All three states maintained 100% out-of-service rates across their citations. Kentucky, Pennsylvania, Florida, Mississippi, Nevada, Delaware, and New York rounded out the top ten, each with between 2 and 5 citations, all at 100% OOS.
The consistency is striking: every state in the top ten had a 100% out-of-service rate, indicating uniform and immediate enforcement across the country. Our data shows fleets such as Family Logistics LLC and Martinez A&C Trucking LLC appear in historical records with 2 citations each, though the low overall volume means most carriers experience this violation zero or one time.
How severe is this compared to similar codes
Two peer codes in the Driver Fitness category show the severity context:
383.23A2-LCDLN (License - Operate a CMV and does not possess a valid CDL) has been cited 47,123 times with a 98.6% OOS rate—identical to 383.25A2 but orders of magnitude higher citation volume. This suggests CDL violations are far more common, yet when the underlying state license itself is the issue, enforcement is equally stringent.
391.41APC (Medical Certificate - Operating without valid medical certificate) shows 49,539 citations with a 97.1% OOS rate. The similar OOS rate reflects that both violations involve a disqualifying licensing or certification status that immediately removes authority to operate.
Compare these to 391.41(a) (Physical qualification - general) with 42,270 citations but only a 16.2% OOS rate. That lower rate reflects cases where drivers are found non-compliant on medical qualifications but still permitted to continue under certain conditions. The 383.25A2 violation allows no such discretion—the license is either valid or it isn't.
How to avoid it
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Verify your state license status before any shift. Check with your state DMV to confirm your license is valid and not expired. A CLP is explicitly not sufficient, regardless of your CDL status. If your state license renewal is coming due, complete it before it lapses.
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Understand your state's CLP restrictions. Some states impose a time limit on CLPs or require specific supervising conditions. Know your state's rules and follow them exactly. Operating outside those conditions—especially without a valid underlying state license—triggers this violation.
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If you're in a training or transition phase, coordinate with your employer. Do not assume someone else has verified your licensing status. Confirm in writing that your state license is current and valid before accepting a driving assignment.
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Watch for medical certificate lapses alongside license issues. Our data shows 391.41APC (Medical Certificate violations) co-occurs 6 times in the last 90 days with 383.25A2 citations. If your medical certificate or license is expiring, renew both at the same time to avoid compound violations.
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Pre-trip inspection includes YOU. Just as you inspect the vehicle, inspect your documents. Carry proof of a valid state license. Roadside inspectors will ask for it immediately. Having it present and valid is your first line of defense.
The 98.6% out-of-service rate tells you everything: this is not a warning citation. It is an immediate stop, and it will take significant time and effort to resolve. Prevention means confirming your state license is valid before you ever get behind the wheel.