Wisconsin recorded just 122 Disadvantaged Business Enterprise recertification applications from Feb. 16 to April 2 after a U.S. Department of Transportation rule in October required DBE firms to certify without using race or sex as proof of disadvantage, a change that has sharply reduced the pool of firms currently approved to bid under federal contracting goals.
That drop matters to the small industry the program was designed to help: the DBE Program exists to give small businesses access to federally assisted transportation and airport concession projects, and Wisconsin had about 1,300 minority- or women-owned firms in construction or airports last fall whose ability to compete depends on being listed as approved DBE firms.
The scale of the decline is concrete. Of 796 firms eligible to recertify, Wisconsin received 122 applications during the reopening window; the state’s Unified Certification Program had preliminarily approved 87 of those applications at the time officials reported the numbers. In fiscal year 2025 Wisconsin set an overall state DBE goal for highway projects at 12.96 percent; WisDOT now says its overall triennial goal is likely to be lower than previous years if the current application totals hold.
When state departments of transportation set project goals, they use the number of available DBE firms, the type of work and the project’s location. "When [state DOTs] set their goals on projects moving forward, they base those goals on available or approved firms currently within that state," Ugo Nwagbaraocha said, explaining why a smaller approved list translates directly into smaller percentage goals on future contracts.
There is a gap, however, between the raw application totals and any final goal cut. WisDOT cautions that a lower statewide goal is not yet certain because the recertification process is still underway and the method the agency uses to set DBE goals has not been completed. Project-level objectives are set case-by-case, and the agency says it will finish reviewing applications and complete its goal‑setting method before finalizing numbers.
That unfinished work matters because the immediate practical effect of a smaller approved pool is a narrower set of firms available for contracting targets. Nwagbaraocha warned that the trend could reach beyond paperwork into hiring and local economies: "DBE firms, we’re critical to the economy, hiring and employment. If [low recertification] moves forward currently, this is going to affect not just [DBE firms] but the entire economy," he said, linking certification counts to real jobs and local business activity.
The stakes are clearest on the largest projects. Nwagbaraocha said declining certification totals could lower goals on major builds such as the John A. Blatnik Bridge replacement, a $1.8 billion project in Superior, because fewer approved DBE firms in relevant trades or the region will reduce the percentage targets WisDOT can reasonably set. Project goals are calculated from the pool of available firms; shrink that pool and the attainable goal falls.
Recertifications have been extremely low across the U.S. after the October interim final rule reset how disadvantaged status is certified, and many firms are reportedly hesitant to restart the process. That national context is why Wisconsin’s numbers matter beyond a single state: the count of approved firms is the raw material for every future DBE goal on highways and at airports.
What happens next is procedural but decisive. WisDOT will complete its review of submitted applications and finish the DBE goal‑setting method that determines triennial and project goals. The single unresolved question that will determine how deeply future contracting is reshaped is how many of the 122 applicants — and how many of the broader 796 eligible firms — ultimately emerge as fully approved DBEs. That final tally will set the ceilings for DBE percentages on megaprojects and, in turn, decide whether small industry gains secured by the program will hold or recede.
