DBE Support Services Program Manager
The recent federal changes to the Disadvantaged Business Enterprise (DBE) Program have created significant uncertainty for firms seeking certification or renewal. With the U.S. Department of Transportation’s Interim Final Rule (IFR) becoming effective on October 3, 2025, the national DBE certification process has entered a temporary holding pattern.
Importantly, this pause applies to all DBE firms — both those already certified and those seeking new certification. These changes are the result of federal regulatory updates, not state-level decisions.
Why Everything Is On Hold
Under the IFR, every Unified Certification Program (UCP) must reevaluate all currently certified DBEs that were originally certified within their jurisdiction. Certification standards have changed significantly, requiring both new and existing DBE owners to meet updated eligibility requirements.
Until these reevaluations are completed:
- DBE contract goals cannot be set
- DBE participation cannot be counted
- DBE program plans relying on former rules are no longer valid
- New applications cannot proceed under outdated forms
- Existing certifications must be reevaluated before being recognized again
These changes impact every state and every UCP nationwide.
New Requirements: The Personal Narrative
Under the updated rule, DBE owners must submit a personal narrative that demonstrates social or economic disadvantage using specific, federally defined criteria
This narrative may include examples of:
- Educational barriers
- Employment challenges
- Business obstacles
- Denial of credit or capital
- Unequal treatment compared to similarly situated individuals
- Systemic or economic barriers
The federal guidance emphasizes that narratives cannot rely on race or sex as evidence of disadvantage — a major departure from previous certification standards.
Owners must also provide an updated personal net worth statement and any other documentation needed to show eligibility
Partnering with Illinois DOT for Narrative Outline Drafts
Although the federal government has defined what a narrative must demonstrate, the IFR does not provide applicants with an outline or structural template for writing the narrative.
To help support firms through this transition, we are partnering with the Illinois Department of Transportation (IDOT) to develop draft narrative outlines and guidance materials. These resources will help firms understand:
- How to organize their narrative
- What types of examples meet federal criteria
- How to present information clearly and effectively
- What level of detail is expected
As these outline drafts are completed, we will share them in upcoming webinars, along with additional guidance and best practices for both new applicants and currently certified DBEs.
What Firms Can Do Now
Even with the pause, DBEs can prepare:
For certified DBEs:
- Begin drafting the personal narrative
- Organize financial records
- Update tax, corporate, and ownership documentation
For new applicants:
- Review the new federal criteria
- Begin identifying relevant experiences for your narrative
- Attend upcoming webinars for outline drafts and guidance
- Thank you for your patience during this transition. We will continue sharing updates as they become available.
Contact Mary Zimmerman to learn more about the DBE Support Services Program.