1. What has changed with the DBE and ACDBE programs?
DOT has eliminated rebuttable presumptions of social disadvantage based on race and gender. Each DBE/ACDBE owner must now demonstrate social disadvantage, individually, through a written personal narrative and current Personal Net Worth statement. Until all currently certified firms are reevaluated, participation cannot be counted toward DBE or ACDBE goals.
2. When is this change effective?
The IFR was posted for public inspection on October 2, 2025, and was published in the Federal Register on October 3, 2025. Per the IFR, the rule becomes effective immediately after publication. As of October 3, 2025, all new DBE/ACDBE applications must follow the individualized certification process. For firms already certified, each Unified Certification Program (UCP) will begin reevaluating firms under the new standard before participation can again be counted toward DBE/ACDBE goals.
3. Does this mean my certification is gone?
You are still listed as certified with your UCP. However, your certification must be reevaluated under the new rules, which could lead to decertification if the new certification standards are not met. Until the reevaluation process is complete, your participation does not count toward DBE/ACDBE goals.
4. What is a “personal narrative” and why does it matter?
The personal narrative is a required written statement in which you, as the business owner, explain the barriers you have faced in business and how those barriers have caused economic harm. It must be detailed and compelling.
5. How long will reevaluation take?
The timeline will vary by state and certifying agency. Thousands of firms need to be reevaluated, which will take time.
6. What should I do now?
Review the
IFR and
IFR Guidance to learn the details of the changes. Start considering the information that you will need to draft your personal narrative, update your Personal Net Worth Statement, and collect any supporting documentation. Be on the lookout for any correspondence from your UCP related to the reevaluation process and respond immediately to any UCP requests for information.
7. Does the IFR allow prime vendors, which were awarded Broward County contracts prior to October 3rd, to arbitrarily cease using their DBE or ACDBE vendors?
No. The IFR does not alter existing contracts or allow prime contractors to unilaterally stop using DBE or ACDBE firms that were committed to perform work under Broward County contracts awarded prior to October 3rd. All contractual obligations between prime contractors and their subcontractors remain in effect, and both parties are required to comply with the terms of their agreements.
The IFR primarily affects how DBE and ACDBE participation is evaluated and counted by recipients like Broward County. During the reevaluation process, Broward County must confirm each firm’s eligibility under the updated federal requirements before counting participation toward project or overall goals. However, this does not relieve contractors of their contractual obligations.
8. Will there be an amendment to active awarded contracts that were assigned a DBE or ACDBE goal prior to October 3rd?
No. The IFR does not require or authorize amendments to existing contracts that were awarded prior to October 3, 2025. Broward County must comply with the IFR’s new requirements for reevaluation of existing DBE and ACDBE firms; however, this process applies administratively to how DBE and ACDBE participation is reviewed and counted going forward, not to the underlying contract terms.
