DOT Revises All DBE and ACDBE Rules

Kaplan Kirsch
02 October 2025

On September 30, the U.S. Department of Transportation (USDOT) issued an Interim Final Rule revising the Disadvantaged Business Enterprise (DBE) and Airport Concessions DBE (ACDBE) programs.

The rule eliminates the longstanding presumption of disadvantage based on race and sex, requiring all applicants to demonstrate individual social and economic disadvantage.

Effective October 3, 2025, Unified Certification Programs must reevaluate all existing DBEs under the new standards.

Grant recipients are directed to suspend current goals, set 0% DBE goals on contracts, and halt enforcement of existing contract goals until recertification occurs.

While the program’s framework remains in place, implementation details and timelines are unclear.

Stakeholders are advised to review program documents, coordinate with UCPs and regional offices, and prepare for potentially significant delays in certification and goal-setting

DOT Revises All DBE and ACDBE Rules | Kaplan Kirsch LLP | 02 Oct 2025