• September 30, 2025, The U.S. Department of Transportation has issued an Interim Final Rule that has an immediate impact on every Disadvantaged Business Enterprise ("DBE") and Airport Concession Disadvantaged Business Enterprise ("ACDBE") certified individual and business in the United States.  Individuals and firms applying for certification are also impacted. 
• New standards are NOW in place that eliminate presumption of disadvantage based on race or gender.  Individuals and firms will be evaluated on a case by case basis, based on information and documents that must be provided. 
• A Personal Net Worth Statements were required in the past.  AN ADDITIONAL, NEW REQUIREMENT is the requirement for a WRITTEN PERSONAL NARRATIVE.   The Personal Narrative must demonstrate social ecomonic disadvantage. 
• Under the Interim Final Ruling, every DBE/ACDBE currently certified must be reevaluated under the new standards. All new applicants must apply under the new standard in 49 CFR 26.67.  Reevaluation and new applications must include the submission of a Personal Narrative with individualized proof of social disadvantage. 

WHAT TO DO? 

• DBE/ACDBE firms that are currently certified should prepare a Personal Net Worth Statement and Personal Narrative, according to the new standards and criteria.  Consulting with qualified legal professional to navigate through these new requirements, standards and criteria and for compliance purposes

What are the next steps?  Contact Michelle DelMar, Esq., for next steps concerning new requirements for DBE / ACDBE Certification, guidance, advice and representation concerning Personal Narrative and other requirements for DBE / ACDBE Certification. 

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