The Dalilah Law: CDL Restrictions That Could Remove 600,000 Drivers and Reshape Freight Broker Capacity

President Trump used his 2026 State of the Union address to call on Congress to pass the Dalilah Law, and Senator Jim Banks (R-Ind.) introduced the bill the same day (U.S. Senate - Banks, Axios). The legislation would restrict CDLs to U.S. citizens, lawful permanent residents, and a narrow set of work visa holders, revoke existing CDLs for all others, and mandate English-only testing. For freight brokers, this is not a distant policy debate. If enacted, the bill could remove over 600,000 drivers from the active workforce within 180 days, creating the sharpest capacity contraction since the pandemic (FreightWaves).

Direct Answer / TL;DR

The Dalilah Law would ban CDLs for undocumented immigrants and most temporary-status holders, require English-only CDL testing, and force states to revoke non-qualifying licenses within 180 days or lose federal DOT funding. FreightWaves estimates over 600,000 drivers — roughly 16% of the active workforce — could be disqualified, with potential rate surges of 50–100% on capacity-constrained lanes. Brokers should begin stress-testing carrier rosters and lane exposure now.

Key Takeaways for Freight Brokers

• The Dalilah Law would disqualify an estimated 600,000+ CDL holders — approximately 16% of active drivers — through citizenship requirements, visa restrictions, and English-only testing mandates.
• If enacted, the bill's 180-day compliance window could trigger the fastest capacity contraction in trucking history, with rate increases of 50–100% on exposed lanes.
• States must comply or lose federal DOT highway funding, which makes enforcement near-certain regardless of local policy preferences.
• Brokers with concentrated carrier exposure in port, border, and high-immigration metro lanes face the highest operational risk.
• The Dalilah Law builds on FMCSA's non-domiciled CDL final rule (effective March 16, 2026), compounding an already tightening driver eligibility environment.
• ARK TMS is designed for small teams (1-25 users) that need fast carrier re-vetting, compliance tracking, and capacity management without enterprise complexity.

What the Dalilah Law Would Do

The bill, named after Dalilah Coleman — a five-year-old severely injured in a June 2024 California crash caused by an undocumented immigrant driving an 18-wheeler on a state-issued CDL — conditions federal DOT funding on states meeting three requirements (U.S. Senate - Banks, DHS):

CDL Eligibility Restrictions

States must limit CDL issuance to U.S. citizens, lawful permanent residents, and holders of three specific work visa categories: E-2 (treaty investors), H-2A (temporary agricultural workers), and H-2B (temporary non-agricultural workers). All other immigration statuses — including asylum applicants, TPS holders, and DACA recipients — would be excluded.

Mandatory License Revocation

States must revoke all existing CDLs held by undocumented immigrants and individuals with temporary or non-qualifying immigration status. The bill provides a 180-day recertification window for current holders to prove eligibility.

English-Only CDL Testing

All CDL knowledge and skills tests must be administered in English only, ending multi-language testing programs in states that currently offer them.

Chameleon Carrier Crackdown

The bill also requires commercial vehicles to display a permanent (non-magnetized) business name, targeting carriers that swap DOT numbers to evade enforcement. A per-VIN special permit would be required for any magnetized DOT display.

The Capacity Math: Why Brokers Should Pay Attention Now

Foreign-born drivers comprise roughly 18–19% of the U.S. trucking workforce — between 630,000 and 720,000 of the 3.5–3.8 million total CDL holders (FreightWaves). FreightWaves analysis breaks down the disqualification risk:

For context, the 2021 freight boom — which produced double-digit rate increases — was driven by demand surges, not supply removal. The Dalilah Law would create a supply-side shock with no relief valve, because the new drivers that historically backfilled capacity gaps would be exactly the population excluded by the law.

FreightWaves warns this could produce "a COVID-like capacity crunch" with potential rate increases of 50–100% on severely affected lanes.

Market Impact: The Super Cycle Scenario

Most freight market swings are demand-driven. Pandemic e-commerce surges, seasonal produce seasons, and holiday retail peaks all push rates up temporarily, then normalize as capacity adjusts. The Dalilah Law would be fundamentally different: a supply-side shock with no natural correction mechanism.

Why This Is Not a Normal Rate Spike

In a typical capacity crunch, rising rates attract new entrants. Owner-operators lease trucks, CDL schools graduate new drivers, and carriers recruit from adjacent labor pools. Within 6–12 months, supply responds and rates stabilize. The Dalilah Law breaks that cycle. The population most likely to enter trucking as new drivers — immigrants willing to pursue CDL training — would be the same population excluded by the law. The supply response that historically dampens rate spikes would be structurally impaired.

FreightWaves CEO Craig Fuller has described this as a potential "trucking rate super cycle" — not a temporary spike, but a sustained period of elevated rates driven by a permanently smaller driver pool (FreightWaves).

The 180-Day Cliff

Unlike gradual regulatory changes that phase in over years, the Dalilah Law's 180-day recertification window creates a hard deadline. States that fail to revoke non-qualifying CDLs within that window risk losing federal DOT highway funding — a consequence severe enough to guarantee compliance. This means the capacity reduction would not trickle in over time. It would arrive as a cliff: one day those drivers are legal, the next they are not.

Spot vs Contract Rate Divergence

The immediate impact would hit spot markets first and hardest. Brokers covering loads on the spot market in affected lanes would see rate increases of 50–100% during the initial contraction, based on FreightWaves modeling. Contract rates would lag but follow, as carriers use newfound leverage to renegotiate committed volumes upward. Brokers locked into fixed-rate contracts without escalation clauses face the worst margin compression — paying market rates to cover loads while billing customers at pre-shock contract prices.

Geographic Concentration Amplifies the Shock

The capacity loss will not be evenly distributed across the country. Regions with higher concentrations of foreign-born drivers will experience disproportionate impact:

Brokers running freight through these corridors should treat this as a lane-specific risk, not a national average.

Long-Term Structural Shift

Even if rates eventually stabilize, they would stabilize at a higher baseline. The U.S. trucking industry was already short an estimated 60,000–80,000 drivers before this legislation. Removing another 600,000+ without a replacement pipeline would reset the supply-demand equilibrium permanently upward. For brokers, this means the margin environment of the past two years — soft capacity, abundant trucks, favorable cover rates — would not return.

Why It Matters to Brokers

The Dalilah Law's impact on brokerages is not theoretical. It compounds existing regulatory pressure and creates specific operational risks that require action before any vote occurs.

Compounding Regulatory Pressure

The Dalilah Law arrives on top of FMCSA's non-domiciled CDL final rule, effective March 16, 2026, which already tightens eligibility and removes Employment Authorization Documents as proof. Brokers managing carriers with non-domiciled drivers are dealing with two overlapping compliance events that amplify each other's capacity impact.

Carrier Roster Instability

Carriers that rely heavily on foreign-born drivers may lose operating capacity or shut down entirely if a significant portion of their driver pool is disqualified. Brokers need to identify which carriers in their network are most exposed before disruptions begin, not after.

What Brokers Should Do Now

The legislative timeline is uncertain — the bill requires Congressional passage and presidential signature — but the operational preparation should begin immediately. The non-domiciled CDL final rule (March 16, 2026) is already law, and the Dalilah Law would accelerate that same trajectory.

Audit Carrier Exposure

Review your carrier roster for concentration in lanes and regions where non-domiciled or foreign-born drivers are common. Flag carriers operating primarily in port drayage, cross-border freight, and agricultural hauling corridors.

Stress-Test Rate Assumptions

Model what a 15–20% capacity reduction would do to your most active lanes. Identify contract commitments with no escalation protection and prioritize renegotiation or hedging strategies.

Build Backup Capacity

Expand your approved carrier list in vulnerable lanes before disruptions materialize. Onboarding carriers after a capacity shock is slower and more expensive than building depth proactively.

Tighten Documentation Workflows

Ensure carrier onboarding captures current driver eligibility documentation and that your system flags expiring credentials. The 180-day recertification window means carrier compliance status will be in flux.

Monitor Legislative Progress

Track the Dalilah Law's movement through committee and floor votes. The bill has White House backing and bipartisan support on enforcement, which increases the probability of passage in some form.

Who This Matters For

This is relevant if you:

• Run a freight brokerage with 1-50 employees
• Handle spot freight or mixed spot/contract freight
• Move freight through port, border, or high-immigration metro lanes
• Rely on manual carrier vetting or spreadsheet-based compliance tracking

You can safely ignore this if you:

• Are an asset-based carrier with no brokerage operations
• Operate exclusively in lanes with minimal foreign-born driver exposure
• Already have automated compliance monitoring with real-time driver eligibility tracking

How Modern Brokerages Handle This

Modern brokerages centralize carrier onboarding, compliance documentation, and capacity management in a single TMS to reduce operational risk during regulatory-driven supply shocks. Systems like ARK TMS are designed for small teams (1-25 users) that need fast carrier re-vetting, lane-level risk visibility, and compliance tracking without enterprise complexity or setup overhead.

Manual Workflows vs Modern TMS

What This Means Going Forward

The Dalilah Law represents the most significant potential disruption to trucking capacity since the pandemic. Whether it passes in its current form, gets amended, or stalls in committee, the direction of federal policy is clear: CDL eligibility is tightening, enforcement is accelerating, and the driver pool is contracting. Brokers that treat this as a future problem will pay more when it becomes a present one.

The brokerages that will navigate this best are those that know exactly which carriers, lanes, and rate commitments are exposed — and have already built the operational depth to absorb the shock.

Sources

• U.S. Senate - Banks: Senator Banks Introduces the Dalilah Law
• DHS: Secretary Noem Backs Dalilah Law
• FreightWaves: The Dalilah Law Could Create a Trucking Rate Super Cycle
• Axios: Trump Pushes for the Dalilah Law at SOTU
• Trucking Dive: Trump Calls on Congress to Further Restrict CDLs
• Commercial Carrier Journal: What Is the Dalilah Law?
• Commercial Carrier Journal: Senator Jim Banks Introduces Dalilah Law