It will depend upon state laws and the reason behind the required SR-22 if a person can be mandated to carry this even without a driver's license. Financial Responsibility certifications (SR-22 or SR-26) are required in Virginia for the following situations according to the VA Department of Motor Vehicles:
- Unsatisfied judgements
- Driver license suspension as a result of a major conviction
- Uninsured motor vehicle suspension
If you were caught doing any of these violations then even without a license you could be required to obtain a SR-22.
Just because a person does not have a driver's license does not mean that the state has not started a driving history for the person. If you are caught driving without a license and are also cited for a moving violation, these can be recorded under a driver's history even if you have not obtained a license.
If you need to obtain a SR-22 for Virginia, click here for a quote.