Impact of Rule Requiring Re-evaluation of DBEs Is Uncertain
On October 3, 2025, the U.S. Department of Transportation issued an Interim Final Rule (“IFR”) for the Disadvantaged Business Enterprise Program and Disadvantaged Business Enterprise in Airport Concessions Program, which requires each Unified Certification Program to re-evaluate all certified Disadvantaged Business Enterprise (DBE) businesses. To that end, the Illinois Unified Certification Program (IL UCP) notified all DBE firms certified prior to October 3, 2025, that they are required to submit a personal narrative to demonstrate their qualification as a DBE by November 24, 2025. Additionally, the Illinois Department of Transportation (IDOT) – the agency that administers the IL UCP and issues certifications that are honored by multiple agencies – has removed the IL UCP Directory from its website.