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Disadvantaged Business Enterprise (DBE) Program

DBE program policy for FTA recipients under 49 CFR Part 26, updated for the October 2025 interim final rule and September 2026 final rule: policy statement, liaison officer, goals, small business element, prompt payment, monitoring and reporting.

Transit16 questions · about 10 min
Your Business

Disadvantaged Business Enterprise (DBE) Program

49 CFR Part 26 — Policy Statement and Program Elements
Effective: November 6, 2026

DBE Policy Statement

Your Business has established a Disadvantaged Business Enterprise (DBE) program in accordance with the regulations of the U.S. Department of Transportation (DOT), 49 CFR Part 26. Your Business receives federal financial assistance from the Federal Transit Administration (FTA) and, as a condition of receiving this assistance, has signed an assurance that it will comply with 49 CFR Part 26.

It is the policy of Your Business:

  • To ensure nondiscrimination in the award and administration of DOT-assisted contracts.
  • To create a level playing field on which DBEs can compete fairly for DOT-assisted contracts.
  • To ensure that the DBE program operates in a nondiscriminatory manner and without regard to race or sex, while maximizing efficiency of service.
  • To ensure that only firms that fully meet the eligibility standards of 49 CFR Part 26 are permitted to participate as DBEs.
  • To help remove barriers to the participation of DBEs in DOT-assisted contracts.
  • To promote the use of DBEs in all types of federally assisted contracts and procurement activities.
  • To assist the development of firms that can compete successfully in the marketplace outside the DBE program.

The Civil Rights Officer has been designated as the DBE Liaison Officer. In that capacity, the DBE Liaison Officer is responsible for implementing all aspects of the DBE program and has direct, independent access to the General Manager on DBE program matters. Implementation of the DBE program is given the same priority as compliance with all other legal obligations incurred by Your Business in its financial assistance agreements with DOT.

Your Business has circulated this policy statement throughout the organization and to the DBE and non-DBE business communities that perform work on its DOT-assisted contracts, by posting it on its website and in each facility, and including it in every DOT-assisted solicitation.

Applicability and Program Status

Your Business is an FTA Tier I recipient. It expects to award prime contracts, excluding transit vehicle purchases, with a cumulative total value of more than $670,000 in FTA funds in a federal fiscal year, and keeps a DBE program meeting all the requirements of 49 CFR Part 26. The program has been submitted to FTA for approval, and significant changes will be submitted to FTA before they take effect.

Changes to the DBE Program in 2025 and 2026

On October 3, 2025, DOT issued an interim final rule, made final on September 25, 2026, that changed the DBE program. Under the current rule:

  • There is no longer any presumption that a business owner is socially and economically disadvantaged because of race or sex. Every owner must show disadvantage based on their own experiences and circumstances, through a Personal Narrative and a personal net worth statement (49 CFR 26.67).
  • Every currently certified DBE is being reevaluated by its state's Unified Certification Program (UCP) under the new standard. UCPs must complete reevaluation by December 24, 2026, unless DOT grants a one-time extension of up to 90 days (49 CFR 26.111). Firms that do not submit the required documents are disqualified.
  • Until the UCP covering Your Business has completed its reevaluation, Your Business may not set DBE contract goals, may not count DBE participation toward DBE goals, and is not required to update its overall goal (49 CFR 26.45(h), 26.51(h), 26.55(i)).

As of the date of this policy, the Illinois Unified Certification Program has not completed its reevaluation. Until it does, Your Business will not set DBE contract goals on new solicitations, will not count DBE participation toward goals, and will not enforce DBE contract goals that were set before October 3, 2025. Your Business will continue all other parts of this program, including DBE-neutral outreach, the small business element, prompt payment, monitoring and reporting, and will update this policy when reevaluation is complete.

DBE Liaison Officer

DBE Liaison Officer contact details: [mailing address]; [phone]; [email]

Preview with sample answers. Yours uses your organization's details and your answers.

What's inside

  1. 1DBE Policy Statement
  2. 2Applicability and Program Status
  3. 3DBE Liaison Officer
  4. 4Nondiscrimination and Assurances
  5. 5DBE Certification and Directory
  6. 6Overall Goals, DBE-Neutral Means and Contract Goals
  7. 7Fostering Small Business Participation
  8. 8Prompt Payment and Retainage
  9. 9Monitoring, Counting and Transit Vehicle Purchases
  10. 10Reporting, Records and Review

Written against: 49 CFR Part 26 (Participation by Disadvantaged Business Enterprises in Department of Transportation Financial Assistance Programs), as amended by the interim final rule of October 3, 2025 (90 FR 47969) and the final rule of September 25, 2026 (91 FR 60885); FTA DBE program requirements and the FTA Master Agreement.

Wording taken from the regulations is kept word-for-word and can't be edited.

How it works

1

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2

Answer

16 questions, one at a time, with examples and suggestions. Follow-ups appear only when they apply.

3

Review and download

Review it (send it to your attorney from PolicyWise if you choose), publish it, and download the Word file.

Included

  • Your organization's details, logo and signature filled in
  • Guided questions with examples and suggestions
  • Optional: send to your attorney for review
  • Editable Word download, every version kept
  • Your own review and approval steps
  • Review reminders

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