DBE Reevaluation Processing Time & Directory Status Tracker

USDOT's answers to questions about the final rule, approved by its General Counsel as consistent with Parts 23 and 26 but guidance, not law. They say recipients may begin counting DBE participation from the date their UCP notifies USDOT that its reevaluation is complete (a UCP that notified before the final rule, as the CUCP did on July 20, must send a second notice with the § 26.111(c)(2) figures, and counting is then subject to the Operating Administration's approval); that contract goals set before October 3, 2025 are legally unenforceable; that a recipient needs a new overall goal before using DBE-conscious contract goals; and that a firm disqualified in the reevaluation can appeal to USDOT under § 26.89. Read through a copy hosted by Maine DOT, because transportation.gov blocks automated downloads.

“Recipients may begin counting DBE participation starting from the date the UCP notifies the Department that the reevaluation process required by 49 CFR 26.111 has been completed.”

USDOT published the final rule finalizing, with few modifications, the October 2025 interim final rule, effective September 25, 2026. New 49 CFR 26.111(c) and (d) require every certifying program to complete its reevaluation by December 24, 2026 (with one extension of up to 90 days) and give a DBE that has not submitted its Personal Narrative and PNW statement until March 24, 2027, or 90 days after its program's extended deadline, before it is automatically disqualified. The rule rewrites the Personal Narrative test in 26.67 — an objective distinguishing feature, social barriers, comparison with individuals of comparable qualifications, and a separate economic-disadvantage-in-fact test — and does not amend the provisions that pause contract goals (26.45(h), 26.47(e), 26.51(h), 26.55(i)).

“Each UCP must complete the reevaluation process required under this section no later than December 24, 2026.”

Caltrans's own FAQ says its reevaluation is complete (the CUCP's July 20 notice to USDOT), that contract goals wait until FHWA and FTA acknowledge its Goal and Methodology reports and amended DBE Program Plan, anticipated in the fall of 2026, and that new goals apply only to projects still in development. It also says Caltrans is developing a Federal Small Business Enterprise Program targeted for 2027 and refers to the directory as reopened. It predates the final rule and still says the interim rule is not yet final.

“Contract goals cannot be set until FHWA and FTA formally acknowledge the final Goal and Methodology and the amended DBE Program Plan for each program.”

Caltrans's program-status page, as our monitor captured it on October 22, still describes the interim rule only: no DBE participation may be counted until the CUCP completes the reevaluation, the requirement to meet the overall goal is suspended, and districts continue to enforce prompt payment and the termination rule on federally funded contracts let before October 3, 2025. It links the interim-rule FAQ of December 1, 2025, not the September 28 FAQ on the final rule, and it conflicts with Caltrans's own September 16 FAQ, which says the reevaluation is complete.

“Until the reevaluation is complete, DBE goals cannot be set on contracts, and no DBE participation may be counted toward any DBE goal.”

As of August 13 this was the most recent official statement on the reevaluation, and it was newer than what several other official pages then said. The CUCP portal states that on July 20, 2026 the CUCP notified USDOT that statewide reevaluations of all firms that filed complete materials by the April 16, 2026 deadline are finished — and that new applications reopened the following day. Note the scope carefully: this announcement covers accepting new certification applications. It does not say DBE contract goal-setting has resumed, which is a separate question governed by Caltrans Office Bulletin #25-07R3 and by whether each recipient agency has adopted a new USDOT-approved overall goal.

“Effective July 21, 2026, all CUCP certifying agencies resumed accepting new DBE, ACDBE, and Interstate certification applications.”

USDOT publishes a live, state-by-state table tracking whether each state or territory's Unified Certification Program has finished reevaluating its currently certified DBEs/ACDBEs under the October 2025 Interim Final Rule. As of the July 13, 2026 update, California is marked complete.

“California | YES ... Last Updated: Monday, July 13, 2026”

Caltrans' DBE Program Updates page, which had shown a “Content Not Available” page since around August 24, was back online by October 4 with different dates: public comment on the proposed FFY 2027–28 goals ran September 16 to September 30, 2026, with Webex sessions on September 18, 21, 22, 24 and 29. The August 17–31 window and the August 24, 26 and 27 sessions it listed in August no longer appear. The proposal is unchanged — the FHWA overall goal from 21.35 percent to 11.80 percent, the FTA goal from 6.7 percent to .08 percent — and Caltrans' Next Steps still place FHWA and FTA acknowledgement of the Goal & Methodology reports before resuming contract goals; it still expects the new goals to restart in the 2026–27 federal fiscal year. Our monitor caught a rewrite of the DBE Certification & Reevaluation page in the same update: the sentences saying recipients may not set contract goals during the reevaluation period, that more than 6000 DBEs were being reevaluated, and that certified firms not meeting the new criteria may be decertified were removed, and the page again says “The Caltrans Office of Civil Rights continually welcomes new DBE applications.” Previously certified firms that have not yet submitted are still asked to upload a Personal Narrative, Personal Net Worth Statement and supporting documents, and firms that are not certified are not eligible to participate until Caltrans receives and approves them. As of October 7, 2026 contract goals have not resumed.

“The public comment on the revised statewide goals is from September 16 to September 30, 2026 ... Caltrans expects the new DBE goals to restart in the 2026–27 Federal Fiscal Year ... Receive FHWA and FTA acknowledgement of Goal & Methodology reports before resuming contract goals”

Caltrans rewrote its DBE pages between August 13 and August 16, 2026, and this supersedes the contradiction we had been reporting. The sentences saying recipients may not set contract goals, that new applications would be processed only after the reevaluation finished, and that out-of-state firms remained ineligible have all been removed. In their place Caltrans says the program is restarting and has proposed sharply lower goals for FFY 2027–2028: the FHWA overall goal falls from 21.35 percent to 11.80 percent, and the FTA goal from 6.7 percent to .08 percent. Caltrans attributes the reduction to the new, in its own words significantly smaller, pool of re-certified firms. At that time the page listed public comment as August 17–31, 2026, with Webex sessions on August 24, 26 and 27 (11am–1pm and 4–6pm each day); the October version, above, lists different dates. Read the sequence carefully before concluding goals are back: Caltrans lists receiving FHWA and FTA acknowledgement of the reports as a step that comes BEFORE resuming contract goals, and expects the new goals to restart in the 2026–27 federal fiscal year. As of August 16 contract goals had not resumed — but the reason had changed from “reevaluation is underway” to “new goals are awaiting federal acknowledgement.”

“The Disadvantaged Business Enterprise (DBE) program is restarting ... Caltrans expects the new DBE goals to restart in the 2026–27 Federal Fiscal Year ... The public comment on the revised statewide goals from August 17 to August 31, 2026.”

Office Bulletin 25-07 states DBE contract goal-setting and participation monitoring are suspended statewide, with narrow exceptions, until the CUCP finishes reevaluating all DBE firms under the new criteria.

“The California Unified Certification Program (CUCP) must reevaluate all DBE firms under the new criteria before their eligibility can be confirmed.”

SANDAG confirms it may not set any DBE contract goals until all California-certified DBEs are reevaluated under the IFR, citing Caltrans Office Bulletin #25-07 R3.

“SANDAG may not set any DBE contract goals until all certified DBEs have been reevaluated under the new IFR eligibility standards. More information on these changes is available in Caltrans Office Bulletin #25-07 R3.”

Confirmed the same statewide suspension of DBE contract-goal, good-faith-effort, counting and monitoring requirements on FAA/FHWA-funded contracts, and publicized a Caltrans-run reevaluation Q&A webinar series held in April 2026.

“DBE requirements for Federal Aviation Administration (FAA) and Federal Highway Administration (FHWA) funded contracts are suspended, effective immediately.”

As of its December 1, 2025 update, USDOT's official FAQ said there was no federally set deadline for a UCP to complete reevaluations — the interim rule only required progress "as quickly as practicable" — though a UCP could set its own non-binding internal submission date for firms. Superseded: the final rule effective September 25, 2026 added 49 CFR 26.111(c), which requires every UCP to complete its reevaluation by December 24, 2026.

“the regulation at 49 CFR § 26.111 provides that UCPs should complete the reevaluation process 'as quickly as practicable.'”

Reevaluation being complete does not by itself restart DBE contract goal-setting. USDOT's FAQ sets a two-part test: the UCP must finish its reevaluation AND the recipient agency must adopt a new overall DBE goal that USDOT approves. As of this check, no California recipient has completed the second part. The September 28, 2026 final-rule FAQ above restates the sequence.

“A recipient may not set any DBE contract goals until the UCP in the recipient's jurisdiction has completed the reevaluation process described in 49 CFR § 26.111.”

This is the current, still-active bulletin suspending DBE contract goal-setting statewide. As of August 6, 2026, it remains the newest bulletin on the topic — Caltrans's own bulletin index has been updated as recently as this month for unrelated topics, but no R4 or "reinstatement" bulletin for DBE exists. Contract goal-setting has not resumed in California even though USDOT marked the reevaluation process complete on July 13, 2026.

“#25-07R3: Suspension of DBE Program — April 2026.”