Disadvantaged Business Enterprise (DBE) Program
About the Program
The federal DBE Program seeks to create a level playing field on which Disadvantaged Business Enterprises can compete fairly for USDOT-assisted contracts. CDOT administers this program on behalf of FHWA and FTA as a condition of receiving federal funds, and must adhere to regulatory requirements in order to remain eligible for continued federal funding.
CDOT FHWA DBE Goal is 12.48% (Federal Fiscal Years 2025-2027)
CDOT FTA DBE Goal is 2.67% (Federal Fiscal Years 2026-2028)
USDOT issues Interim Final Rule and guidance requiring immediate changes to DBE program regulations
On Oct. 3, 2025, the United States Department of Transportation (USDOT) published an Interim Final Rule (IFR) in the Federal Register modifying the eligibility requirements for participation in the Disadvantaged Business Enterprise (DBE) program. Furthermore, the IFR mandates that all currently certified DBEs be reevaluated, and ultimately recertified, for continued program eligibility under these new requirements. 49 C.F.R. § 26.111.
The Disadvantaged Business Enterprise (DBE) and Airport Concessions Disadvantage Business Enterprise (ACDBE) modifications can be found in the Federal Register Update.
Key Provisions to Know
- Certification review: All DBE firms must be reevaluated and recertified to determine eligibility under the new standards established in the IFR.
- Personal narrative requirement: All certified DBE firms, including but not limited to those 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), will now be required to submit a personal narrative explaining their social and economic disadvantage, without regard to race or gender.
- CDOT is seeking detailed guidance on narrative details and criteria from the USDOT but please see the link above to the IFR for a discussion about the personal narrative requirement.
- Personal net worth statement: All certified DBE firms, including but not limited to those 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), will now be required to submit an updated personal net worth statement.
- Please visit the Federal Register update on personal net worth statement details and criteria.
- Suspension of DBE goals for future projects: Contracts effective on or after Oct. 03, 2025, CDOT cannot set DBE goals until the certification review process described in the bullet above is complete.
CDOT ESB Program Continuity
While DBE goals are paused for contracts executed on or after Oct. 3, 2025, CDOT continues to advance the Emerging Small Business (ESB) program. The ESB program remains race- and gender-neutral, focusing solely on business size, and is not impacted by the interim rule.
CDOT Support & Resources
- CDOT is committed to assisting all affected firms and applicants through this transition as we clarify a path forward.
- CDOT will continue to provide supportive services to the small business community.
- Stay connected through our Connect2DOT newsletter for information, online resources, events and more.
