On Friday, October 3, 2025, the U.S. Department of Transportation (USDOT) issued an Interim Final Rule (IFR). This ruling makes immediate and significant changes to the Disadvantaged Business Enterprise (DBE) and Airport Concession DBE (ACDBE) programs nationwide. All DBE firms previously certified using race- or sex-based presumptions of social and economic disadvantage must be reevaluated to determine eligibility under the new standards established in the IFR. Certified DBE firms owned by an individual who was presumed to be disadvantaged (e.g., women, Black American, Hispanic American, Native American, Asian Pacific American, Subcontinent Asian American), must now submit a personal narrative explaining their social and economic disadvantage, without regard to race or gender, and submit an updated personal net worth statement.
Reevaluation Process
- DBE/ACDBE firms are provided with instructions on how to complete the personal narrative.
- Training workshop was provided and presented by ITD’s DBESS firm, Project Solutions Inc.
- Firms must submit all relevant documentation to www.itd.dbesystem.com as “25 Re-Evaluation Application”
- Documents must include Personal Narrative (PN) Statement and Personal Net Worth (PNW) Statement
- The PN must describe experiences of social and economic disadvantages in education, employment, or business, and must explain the following:
- What happened?
- Who was involved?
- When and where did it occur?
- Why do you believe it was biased or discriminatory?
- Why is the owner disadvantaged compared to others in similar situations?
- How did it impact your education, professional, or business progress?
- The PN must describe experiences of social and economic disadvantages in education, employment, or business, and must explain the following:
- Include any documentation that supports your narrative.
- Documents must include Personal Narrative (PN) Statement and Personal Net Worth (PNW) Statement
- The ITD certification committee will evaluate the PN and PNW.
- If more information is needed or clarification is needed ITD will work with the firm in accordance with § 26.83 curative measures.
- If the certification committee finds that the PN and PNW meets the requirements found in § 26.67 social and economic disadvantage, the firm will be notified of the recertification.
- Firms that do not meet the requirements for the program and wish to appeal the decision will have to appeal the decision directly to USDOT.
- Firms that do not submit the necessary information, however, will remain ineligible for the DBE program until they submit the required documentation demonstrating DBE eligibility under the new standards.
- Firms that do not submit necessary information when it is time for the firm to submit their annual DOE will be decertified.