The Employer Pull Notice program is a California DMV service that automatically sends your organization an updated driving record whenever something changes on an enrolled driver’s license: a conviction, a failure to appear, a reported accident, a suspension, or any other action against the driving privilege.1California DMV. Employer Pull Notice Program Enrollment is mandatory for employers whose drivers hold commercial or specially endorsed licenses, and starting April 1, 2026, every EPN transaction has to be handled electronically.
What the DMV Sends You
Once a driver is enrolled under your requester code, the program runs in the background. Any triggering event on that driver’s record generates a report to you, usually within days of the event hitting the DMV database. That is the practical value of EPN compared to pulling records once a year: a driver who loses their license on Monday doesn’t stay behind the wheel until the next scheduled check.
You also get an annual report on the anniversary of each driver’s enrollment, whether or not anything happened during the year.2California Highway Patrol. General Order 10.13 – Employer Pull Notice Program The annual report is your baseline confirmation that the record is still clean, or your catch for anything a triggered report somehow missed.
Who Has to Enroll
California Vehicle Code Section 1808.1 ties the mandatory requirement to the type of license, endorsement, or certificate your drivers need, not to the vehicles your company happens to own. Enrollment is required if your drivers hold or need any of the following:3California Legislative Information. California Code VEH 1808.1 – Records of Department
- A Class A or Class B license, covering most commercial trucks, buses, and heavy equipment transport.
- A Class C license with a hazmat endorsement, passenger endorsement, or other special endorsement under Vehicle Code Section 15278.
- A special certificate for school bus, youth bus, farm labor vehicle, or similar operations under Vehicle Code Sections 12517 through 12527.
- Authorization to drive for-hire passenger vehicles, including charter-party carriers, PUC-permitted passenger stage corporations, and permitted taxicabs.
If someone drives one of these vehicles for you, they have to be enrolled under your requester code.3California Legislative Information. California Code VEH 1808.1 – Records of Department
Voluntary Enrollment
Employers outside the mandatory categories can enroll drivers voluntarily, and fleet insurers often push for it. Companies running passenger cars, delivery vans, or other non-commercial vehicles use the program the same way; the only difference is that the law doesn’t force the question. For voluntary enrollments, you need a signed waiver from each driver authorizing the monitoring, kept on file at the worksite.
How to Enroll
The core application is the DMV’s INF 1104, the Employer Pull Notice Program Application. It asks for your company’s legal name, physical and mailing addresses, a designated account contact, billing information, your Federal Employer Identification Number, and a statement of purpose. Mandatory enrollees check the box citing Section 1808.1; voluntary enrollees confirm that signed waivers are on file for each driver. For the driver list itself you need each driver’s full legal name and California driver’s license number, and license number typos are the most common reason an enrollment stalls.
As of April 1, 2026, new regulations under California Code of Regulations Title 13, Section 350.47 require employers to submit documents, request and receive driver records, and pay invoices electronically.1California DMV. Employer Pull Notice Program The DMV routes new enrollees through its EPN Online Requester portal. Employers already enrolled under the old paper process have to move to electronic access as well.
Once the DMV approves your enrollment, you receive a unique requester code. That code identifies you in every transaction and gets attached to each enrolled driver’s record in the DMV system.1California DMV. Employer Pull Notice Program If you’d rather have a DMV-approved EPN agent manage the account and driver list, that arrangement is set up with an Agent Authorization form (INF 2110).
Keeping the Driver List Current
The program only works if the list reflects who actually drives for you. Add new drivers and remove terminated ones promptly through the online portal or your approved agent.1California DMV. Employer Pull Notice Program If anything on your original application changes, such as the company address or the designated contact, file a Notice of Change (INF 4) within 10 days.
Removing terminated drivers protects you two ways. You stop paying for reports on people who no longer work for you, and you close out the data access link between your requester code and that person’s license record. Build the removal step into your offboarding checklist.
What to Do When a Report Shows a Problem
The reports arrive easily enough. Acting on them is where the real liability lives. When an EPN report shows that a driver’s license has been suspended, revoked, or restricted, the question is simple: can this person still legally drive for you? If the answer is no, they have to come off driving duties immediately.
California takes this seriously. 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. The penalty is up to six months in county jail, a fine of up to $1,000, or both.3California Legislative Information. California Code VEH 1808.1 – Records of Department That’s a criminal charge against the employer, not a regulatory slap.
The civil side is just as serious. If you know a driver’s license is suspended or that their record shows a pattern of serious violations and you let them drive a company vehicle anyway, you’re exposed to a negligent entrustment claim if there’s an accident. Negligent entrustment liability isn’t capped at ordinary auto policy limits, so a plaintiff can reach for company assets. The whole point of EPN is to put the information in your hands. Ignoring what the reports say eliminates any argument that you didn’t know.
When a disqualifying report comes in, pull the driver from all driving assignments right away. Document the date you received the report, the action you took, and the date the driver stopped driving. If the issue is resolved and the license is reinstated, run a follow-up record check to confirm the reinstatement before the driver returns to the wheel.
Driver Consent and Privacy Rules
Pulling someone’s driving record triggers federal privacy law, and the consent paperwork needs to be in place before you enroll anyone.
Fair Credit Reporting Act
When a driving record is obtained through a third-party service or consumer reporting agency, it is a consumer report under the FCRA. Before requesting it, you have to give the driver a clear written disclosure in a standalone document stating that a driving record may be obtained for employment purposes, and the driver has to authorize the request in writing.4Office of the Law Revision Counsel. 15 USC 1681b – Permissible Purposes of Consumer Reports
If you plan to take adverse action based on the report, such as reassigning, suspending, or firing the driver, a two-step notice process applies. First, give the driver a copy of the report and a summary of their rights before you finalize the decision, and allow a reasonable waiting period, generally at least five business days, for the driver to dispute the report’s accuracy. Only then do you send the final adverse action notice identifying the reporting agency and explaining the decision.
For positions regulated by the Department of Transportation, the FCRA permits a streamlined process where disclosure and consent can be handled orally or electronically if the application itself was made by phone, mail, or online.4Office of the Law Revision Counsel. 15 USC 1681b – Permissible Purposes of Consumer Reports
Driver’s Privacy Protection Act
The federal DPPA limits how state DMVs can release personal information from motor vehicle records, with a specific exemption for employers checking commercial driver’s license records and related employment uses.5Office of the Law Revision Counsel. 18 USC 2721 – Prohibition on Release and Use of Certain Personal Information From State Motor Vehicle Records EPN fits inside that exemption because you’ve enrolled the driver under your requester code and the DMV is the direct source. Don’t share, sell, or repurpose the records for anything beyond driver safety monitoring and employment decisions.
How EPN Fits With Federal FMCSA Rules
EPN does not replace the federal recordkeeping obligations that apply to motor carriers. Under 49 CFR 391.25, every motor carrier has to 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, and document the reviewer, the date, and the results in the driver qualification file.6eCFR. 49 CFR 391.25 – Annual Inquiry and Review of Driving Record An EPN annual report can satisfy the California piece of that inquiry, but it doesn’t reach records from other states. If your driver held a commercial license in Nevada or Arizona, you have to request those records separately.
Federal law also sets the retention clock. Under 49 CFR 391.51, the driver qualification file, including every driving record inquiry, has to be kept for the entire duration of employment plus three years after the driver leaves.7eCFR. 49 CFR 391.51 – General Requirements for Driver Qualification Files The three-year clock starts on the termination date, not the date of the last record. Destroying files early is a common audit finding and carries its own penalties.
Recordkeeping and Confidentiality
California’s general employment record guidance points toward keeping most employment documents for at least four years, which lines up with the statute of limitations on many employment-related claims. For EPN reports, the safe practice is to retain them for whichever period is longest: the federal three-years-after-termination rule for commercial drivers, or a state retention period matched to the longest applicable statute of limitations for negligence or employment claims.
EPN reports hold sensitive information: license numbers, violations, suspensions. The designated contact on your account is responsible for maintaining confidentiality. Keep access limited to managers and HR staff who need to review driving fitness. When records are no longer required, destroy them securely. For paper, that means cross-cut shredding; for electronic files, a recognized data sanitization method rather than a simple delete.