Your cutoff depends on one fact you probably do not have: whether your UCP asked DOT for more time. Here is how to get it in an afternoon.
Know what you are looking for
Read § 26.111(c)(1) once. A UCP may request a one-time extension of up to 90 days to finish reevaluation. The Office of Small and Disadvantaged Business Utilization (OSDBU) at DOT may grant it for good cause. The request must go in before December 24, 2026. The preamble adds that the UCP asks by emailing OSDBU at DBEreevaluations@dot.gov. That is everything the rule says. It does not require the UCP to announce the request. It does not require DOT to publish the grant.
Start with the UCP’s site
Open the certification page for your state. Find it through the UCP directory if you do not have it bookmarked. Search the page for “extension,” “December 24,” “complete” and “reevaluation.” Check the news or announcements section, not just the program page. Note the date on the newest post. Take a screenshot with the date visible. If the page says the reevaluation is complete, you already have your answer: no extension matters, and the March 24, 2027 cutoff applies to any nonresponsive firm.
Ask a recipient for the completion email
Under § 26.111(c)(2), a UCP that finishes must email OSDBU, then copy that email within three business days to every recipient of DOT funding in its jurisdiction, certifying or not. Your transit agency, your airport authority and your state DOT district office are all on that list. Call the DBE office at one of them and ask whether the completion email has arrived. If it has, no extension is in play. If it has not by late December, the UCP is either finishing at the wire or working under an extension, and you need to know which.
Ask your prime’s DBE liaison
Primes watch this closely because contract goal setting and counting resume once the UCP completes. Their DBE liaison or compliance officer often hears from the recipient before a small firm does. Ask what they have been told and by whom. Treat it as a lead, not a record. Confirm anything you hear with the UCP itself.
Send the UCP this email
Write to the certification office, not a general inbox. Put your firm name and DBE number in the subject line. Keep the body to four lines so it gets answered.
- Has the UCP finished the § 26.111 reevaluation for all of its member agencies, and on what date did it email OSDBU?
- Has the UCP requested or been granted the one-time extension under § 26.111(c)(1), and if so, what is the extended deadline?
- Does the UCP show a Personal Narrative and PNW statement on file for my firm’s owner(s), and if not, what is my submission deadline under § 26.111(d)?
- Please reply in writing; I will rely on your answer to set my filing date.
Save the reply as a PDF. Put it in the same folder as your narrative. If nobody answers within five business days, call, then send the email again with the call noted.
What the extension changes for March 24
Without an extension, your UCP’s finish line is December 24, 2026; an owner who has not filed by then gets a written notice of nonresponse with a cutoff of March 24, 2027. With an extension, the UCP’s deadline moves later, by up to 90 days, and your cutoff becomes 90 days after that extended deadline. Note the word. The clock runs from the UCP’s deadline, not from the day it happens to finish. Nothing else moves: the narrative still needs an objective basis and a statement of harm in type and magnitude, and missing the cutoff still means automatic disqualification with no hearing. Nor does an extension touch the earlier submission date your own UCP set.
Do not read an extension as permission to wait. A UCP that asked for more time is a UCP with a backlog. A packet filed in January lands in a queue. A packet filed in April lands behind it.
Do not mix up three different dates
First, your UCP’s own submission date, set in 2025 or 2026 and in some states pushed back once already. Second, December 24, 2026, the federal completion deadline for every UCP. Third, the OSDBU extension, which moves only the second date. A state that pushed back its spring submission date did not thereby get a federal extension. As of our tracker’s last update on September 22, 2026, we have not verified any UCP as having requested one under § 26.111(c)(1). That describes what we have confirmed, not a claim that none has.
Do this today
- Check your state on the reevaluation tracker. Screenshot the UCP page.
- Send the four-line email. Calendar a follow-up call for five business days out.
- Start the narrative whatever the answer. Read the three-owner explainer if you want to see how each answer plays out.
An extension buys your UCP time. Buy yourself some by filing first. Draft it now
Source: § 26.111(c)–(d) and preamble, FR Doc. 2026-19688 (September 25, 2026) · Related: The notice of nonresponse, annotated · Reminders after you are retained