Disadvantaged Business Enterprise

USDOT interim final rule requiring immediate changes to the DBE program regulations

On October 03, 2025, the U.S. Department of Transportation (USDOT) issued an interim final rule (IFR) requiring immediate changes to the Disadvantaged Business Enterprise (DBE) program regulations. 

Recent Updates

On November 3, 2025, the AZUCP distributed the attached document(PDF, 287KB) providing guidance for firms to submit the required personal narrative during the upcoming reevaluation period. A forthcoming document will be distributed, and posted here, providing further guidance for submitting the personal narrative through the firms respective agency compliance system and including the due date to submit the personal narrative.   NOTE: The City will NOT process your personal narrative if sent via email.  The personal narrative and other documents MUST be submitted in the compliance system through the soon to be created reevaluation application process.      

Key Provisions 

  • Certification Review: All DBE firms previously certified using race- or sex-based presumptions of social and economic disadvantage must be reevaluated by each AZUCP partner to determine eligibility under the new standards established in the IFR. 
     
  • Personal Narrative Requirement: Certified DBE firms owned by an individual who was presumed to be disadvantaged (e.g., women, Black American, Hispanic American, Native American, Asian Pacific American, Subcontinent Asian American), must now submit a personal narrative explaining their social and economic disadvantage, without regard to race or gender, and submit an updated personal net worth statement. 
     

  • Suspension of DBE Goals for Future Projects: For contracts effective on or after October 03, 2025, the City of Tucson and other DOT fund recipients cannot set DBE goals until the certification review process described in the bullet above is complete. 

  • Contracts before October 3, 2025: For credit participation by certified DBEs can no longer be counted towards the assessed goal.

  • The bidder’s list is still required to be submitted at time of bid, except for race and gender reporting. 

DBE Impact

  • The certifications for any DBE firm that previously qualified based on a presumed disadvantage will not be effective during the certification review period.   
     
  • Affected firms will be notified directly. The notice will include instructions regarding the certification review process and submission requirements for firms seeking to regain DBE certification.  
     
  • DBE firms must submit a personal narrative and a personal net worth statement, which will be reviewed during the certification review period. If a firm fails to comply or does not meet the standard of certification, it will be decertified without the opportunity to go to a hearing. 
     
  • This change does not impact prevailing wage, certified payroll, or prompt payment. 

SBE Program Continuity

While DBE goals are paused, City of Tucson continues to advance SBE contract goals. The SBE program remains race- and gender-neutral, focusing solely on economic disadvantage, and is not impacted by the interim rule.

City of Tucson Support & Resources

City of Tucson is committed to assisting certified firms and applicants through this transition.  Plans are being discussed with the AZUCP program partners on exactly what support & resources will be offered.

Questions

Review the full Disadvantaged Business Enterprise Program Implementation Modifications online.

 

Related Documents and Forms

Related Information

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