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Big Changes to DBE, Interim Final Rule
October 3rd, 2025
KEY TAKEAWAY:
Race, ethnicity, and gender are no longer automatic indicators of social disadvantage.
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On October 3, 2025, the U.S. Department of Transportation (USDOT) issued an Interim Final Rule (IFR) revising the Disadvantaged Business Enterprise (DBE) and Airport Concession DBE (ACDBE) programs under 49 CFR Part 26 and Part 23.
This change significantly restructures how social and economic disadvantage (SED) is determined, removes long-standing group presumptions, and temporarily pauses new DBE goal-setting until states reevaluate all currently certified firms.
Below is an overview of what this means for you as a currently certified DBE, including those with interstate certifications or active DBE contracts.
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Key Federal Resources
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Federal Register: Disadvantaged Business Enterprise Program and Disadvantaged Business Enterprise in Airport Concessions (IFR, Oct. 3 2025)
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DOT IFR (PDF): DBE IFR Published 10-03-2025
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DOT Implementation Guidance (PDF): DBE IFR Guidance 10-03-2025
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What the Rule Changes
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Group Presumptions Removed:
Race, ethnicity, and gender are no longer automatic indicators of social and economic disadvantage.
Every applicant (new or existing) must now demonstrate disadvantage individually. -
New Application Requirements:
All owners must provide a detailed Personal Narrative describing specific barriers and economic hardship, supported by a current Personal Net Worth (PNW) statement and relevant documentation. -
Reevaluation of Current DBEs:
Every currently certified DBE will undergo a reevaluation by its certifying agency (UCP or state DOT).-
The timeline is “as quickly as practicable” – no specific deadline has been issued.
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You will retain your certification during this reevaluation.
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After review, you will either be recertified or decertified under the new standards.
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What the Rule Says and Doesn’t Say
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If you are currently DBE Certified:
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​You have not lost your DBE Certification.
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Continue to perform and invoice existing DBE work as usual, these projects are unaffected.
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Continue to obtain work, cash flow is your lifeline!
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Prepare to create a personal narrative, considering what you personally have gone through in your journey up to and including owning your business.
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Anything with documentation is especially important​
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Respond promptly to the State DOT WHEN they reach out to you.
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THERE IS NOTHING TO DO RIGHT NOW, October 7th, 2025.
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If you are about to apply:
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Apply through the exisiting mechanism (Database or Paper based)
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Additional documentation/questions may be asked at a later date (but don't hold off submitting)
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The typical "up to 90 days to review" may take much, much longer, be patient.
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Feel Free to contact us for a no obligation discussion about this ruling and recommended strategies. New information should be coming in the near future.
Why HIT Executive Consulting?
98% Approval Rate
40% to 50% of applicants are denied for MBE, DBE, or WBE Certification for failing to prove documented ownership, management and control, or other reasons.
Expert Review
Our QA Process includes review by a Business Strategist, Certification Subject Matter Expert (SME), and if necessary, Attorney and/or Accountant.
Quick Submission
Most WBE, DBE, and MBE Certification Applications only take 4-6 weeks from Project Kick Off to Application Submission using our services!
For over 14 years, and 600+ Companies Certified Nationwide, HIT Executive Consulting has specialized in Business Certifications (including WBE, DBE, and MBE Certification), Business Assessments, Executive Mentorship, Business Services, Company Valuations and assisting companies with the Business Certification Process.
UAMMI Supplier Diversity Certification
(SDC) Mentorship Program​
HIT Executive Consulting is proud to create the SDC Mentorship Program for the Utah Advanced Materials and Manufacturing Initiative, UAMMI. UAMMI is a federal and state funded initiative helping companies connect and grow within Utah’s advanced materials and manufacturing industry. This 10-week program walks qualifying companies through the certification process while featuring speakers from the Women’s Business Center of Utah, SBA-Utah District Office, WBEC-West, iMpact Utah, and various currently certified Utah companies. The program goals are to provide mentorship, resources, assistance, and guidance to identify the benefits of certification and to review step-by-step the qualifications and required documentation to complete the certification process successfully.
The program is funded by the Utah-MEP, in a partnership with HIT Executive Consulting, Inc.
Current Certification Clients
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If you are a Qualifying Individual(s), this questionnaire will help determine which Certification to choose.
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* HIT Executive Consulting is not affiliated with the WBENC, NWBOC, NMSDC, USWCC, NGLCC, DOT or any other third party certifier. For Certifications, we only work with businesses with qualified individuals who are 51% owners, manage, and control their company, or are in the process of meeting the minimum criteria. Qualification for one Certification does not necessarily mean an individual will qualify for other Certifications. Qualifying as a qualified individual does not guarantee approval as there is much more to the process. Please contact us for more details.
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