Introduction
On September 30, 2025, the U.S. Department of Transportation (USDOT) issued an Interim Final Rule (IFR) that fundamentally changes the operation of the Disadvantaged Business Enterprise (DBE) and Airport Concessions Disadvantaged Business Enterprise (ACDBE) programs. This IFR was published in the Federal Register and became effective October 3, 2025.
For more than four decades, the DBE and subsequently, the ACDBE programs have been a gateway for minority- and women-owned firms to access airport opportunities. The programs include a rebuttable presumption of disadvantage based on race and gender. Per this IFR, the rebuttable presumption of social disadvantage based on race and gender has been eliminated.
In its place, USDOT has mandated that every firm, whether newly applying or currently certified, must demonstrate social and economic disadvantage on an individualized basis. In the interim, all existing certifications are in a suspended state. Firms remain certified in name, but their participation cannot be counted toward DBE or ACDBE goals until a reevaluation of all currently certified firms is conducted. Additionally, airports cannot set new goals during this interim period.
This transition has created uncertainty, but it also creates opportunity. The Airport Minority Advisory Council (AMAC) is committed to supporting its members through this transition. Below are answers to the many questions that have been presented. We will update this list as new and relevant questions are presented.
USDOT DBE & ACDBE Program Interim Final Rule
AMAC FAQs Question Submission: USDOT DBE & ACDBE Program Interim Final Rule
FAQs (As of October 3, 2025)
1. What has changed with the DBE and ACDBE programs?
USDOT has eliminated rebuttable presumptions of social disadvantage based on race and gender. Every 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, and became effective immediately. Per the IFR, the rule becomes effective immediately after publication. From that point forward, 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?
No. You are still listed as certified with your UCP. However, your certification must be reevaluated under the new rules. Until that happens, your participation does not count toward DBE/ACDBE goals.
4. Can joint venture partners and primes continue to operate under existing agreements?
Yes, all parties have a binding contract with all the enumerated rights and obligations.
5. 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.
6. 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. AMAC will closely monitor timelines and advocate for consistency across airports and UCPs.
7. What is AMAC doing to support its members?
AMAC is taking proactive steps to support members through this transition. We will host sessions to explain the new rule, answer questions, and share resources. In addition, AMAC is developing tailored resources to help all of its members—including DBEs, ACDBEs, corporate partners and airports—clearly understand the changes and navigate their impact.
8. What should I do now?
Review the IFR and IFR Guidance to learn the details of the changes. Attend webinars hosted by AMAC to learn best practices around creating a personal narrative. Start considering the information that you will need to draft your personal narrative immediately, update your Personal Net Worth Statement and collect any supporting documentation.
9. How can we stay competitive during this transition?
Focus on two areas:
- Certification Readiness: Complete your Personal Narrative, update your Personal Net Worth Statement and gather documentation now.
- Operational Excellence: Continue demonstrating strong performance on existing contracts. Airports and primes prioritize partners who have proven they add value beyond credit.
10. Where can I get help preparing my personal narrative?
AMAC members are strongly encouraged to participate in the AMAC webinar, “Maintaining & Expanding DBE/ACDBE Certification,” on October 7, 2025, at 11:30 am ET. Register by clicking here.
Additionally, AMAC is compiling a list of members who can provide one-on-one assistance to prepare your personal narrative and for individual legal advice.
11. AMAC is actively tracking these issues and will update members. The key points under review are:
- What happens if my firm is not recertified?
- Will every state apply these rules the same way?
- Can I appeal a negative decision?
- What if I am in the middle of bidding on a new opportunity?
- How will this impact disparity studies and future goals?