Interstate certification, defined
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What §26.85 requires
Section 26.85 exists so a certified DBE does not have to prove ownership, control, and disadvantage from scratch in every UCP where it wants to work. The rule puts the paperwork burden on the firm's existing record rather than on a new application:
- A cover letter addressed to the receiving UCP that lists every UCP where the firm currently holds DBE certification, and asks the receiving UCP to certify the firm on the basis of its home-state certification.
- An electronic image of the home-state directory entry showing the firm as currently certified, with its NAICS codes and work descriptions.
- A complete request. The 10-business-day clock only runs once the receiving UCP has everything it needs. Anything missing resets it.
Since October 2025, several UCPs have asked for proof that the home-state certification survived reevaluation. The DOT final rule of September 25, 2026 now says a simple notification is enough, described below.
What changed after October 3, 2025, and what the 2026 final rule says
The October 3, 2025 Interim Final Rule removed the race- and sex-based presumptions of disadvantage and required every UCP to reevaluate every certified firm under §26.111; the final rule of September 25, 2026 confirmed it. A directory entry from before October 2025 therefore no longer proves the firm meets the current standard. In response:
Several UCPs asked for a home-state reevaluation letter dated after October 3, 2025 with every interstate request. Idaho is a confirmed example.
Massachusetts paused interstate applications entirely.
Alaska removed its interstate (out-of-state) firms from its directory on November 11, 2025; it reimburses firms that regain certification in Alaska up to $2,000 for qualified professional services through December 31, 2026.
The final rule’s answer. Once your home UCP (the Jurisdiction of Original Certification) reevaluates you, other states “should automatically accept that decision upon simple notification, such as a letter or a screenshot showing the firm’s status in the JOC’s updated DBE directory.” The receiving UCP records it, and no further requirements may be imposed. If you do not reaffirm in the other state within one year of your home decision, you follow the regular §26.85 process as if for the first time.
Federal backstop: every UCP must finish reevaluations by December 24, 2026; nonresponsive firms have until March 24, 2027 (49 CFR 26.111(c)–(d)).
State policies may take time to catch up with the final rule; confirm the receiving UCP’s current practice before you file.
Step by step
- Get your home-state reevaluation letter, or a dated screenshot of your updated listing. If your home UCP has reevaluated you, ask for the written determination. If it has not finished, most receiving UCPs will wait for it. See where each state stands on the reopening tracker.
- Capture your directory entry. Save a dated screenshot or PDF of your listing in the home-state DBE directory, showing the firm as certified with its NAICS codes.
- Check the receiving UCP's current interstate policy. Look for a letter requirement, a pause, or extra forms. The UCP directory has each office's phone and email.
- Draft the cover letter. List every UCP where you are certified, state the NAICS codes you want recognized, and enclose the directory image and reevaluation letter. Members can generate this packet in about five minutes with the interstate packet generator.
- File with the receiving UCP. Use its portal or email as instructed. Never send certification requests to U.S. DOT.
- Calendar the 10 business days. Confirm the request was logged as complete, then follow up if the deadline passes without action.
- Add the new certification to your compliance calendar. Each certification carries its own annual Declaration of Eligibility (§26.83(j)) and 30-day material-change notice (§26.83(i)) obligations.
Why 2027 is the year to expand
Reevaluation cut most state directories sharply, and goals are starting to come back on a smaller pool of eligible firms. Verified examples:
- Arizona:
1,225 certified firms before reevaluation; 277 retained. Firms not retained were delisted June 30, 2026.
- Pennsylvania:
1,408 firms certified on October 3, 2025; 431 retained as of August 26, 2026, with 538 non-responsive, 155 withdrawn, and 50 denied. Reevaluation closed September 1, 2026.
- Wisconsin:
only 122 of 796 eligible firms applied for reevaluation; 87 were preliminarily approved.
- Minnesota:
priority reevaluation completed August 18, 2026 and contract goals resumed the same day, at a reduced FHWA goal of 6.2% (down from 15.3%).
Goals are lower than they were, but the number of firms able to meet them fell faster. A prime looking for certified subcontractors in Arizona in 2027 is choosing from roughly a quarter of the 2025 directory. A firm that is reevaluated and retained at home, and holds the letter or a screenshot of its updated listing, can carry that standing into neighboring states through §26.85 while most competitors are still rebuilding their home-state file.
States with a verified interstate policy
Only the states below have an interstate-specific policy we have verified. "Several UCPs" asked for the home-state letter; this list is what we can confirm, not the full set, and the 2026 final rule says notification should be enough. Last checked 2026-09-22.
| State | Home-state letter | Interstate policy | Source |
|---|---|---|---|
| Alaska | Not confirmed | Interstate firms were decertified 11/11/2025; out-of-state firms should expect to re-request certification with a post-IFR home-state record. | UCP page |
| Idaho | Required | Interstate applicants must include a home-state reevaluation letter dated after October 3, 2025. | UCP page |
| Massachusetts | Not confirmed | Interstate (26.85) applications paused. Confirm with the Massachusetts UCP before sending a packet. | UCP page |
If your target state is not listed, assume the receiving UCP may still ask for a home-state reevaluation letter and confirm before you file.
Generate your §26.85 packet
DBE Compliance Membership members draft the interstate cover letter, enclosure list, filing checklist, and the target UCP's contact block from their own firm record. $300/year, $35/month, or $500 for a single filing cycle.
Not yet reevaluated at home?
The interstate route only works once your home-state file is clean under the final rule. If you still owe your home UCP a personal narrative and PNW statement, start there; nonresponsive firms have until March 24, 2027 at the latest (49 CFR 26.111(d)). Narrative Pro drafts the full package for $79, or $149 with a year of the Compliance Membership included; a $49 Narrative Review scores a draft you already have.
Frequently asked questions
What is interstate DBE certification?
Do I have to file a full new DBE application in every state?
What is the home-state reevaluation letter?
How long does the receiving state have to decide?
Once I am certified in several states, do I have separate compliance obligations in each?
DBE Narrative Pro is a document-preparation service, not a law firm, and this page is not legal advice. Certification decisions are made by each state's UCP under 49 CFR Part 26.