Businesses can still apply for certifications in each state; however, they will no longer be able to reference gender or race as a disadvantage. Instead, these DBE certifications will be based on a “personal narrative”, which the DOT has attempted to clarify in the rule.

Under the DOT rule, the following requirements and deadlines apply to DBE recertification:

• The personal narrative “must identify at least one objective basis for the owner’s disadvantaged status. The basis may be any identifiable status or condition. The [narrative] must describe this objective distinguishing feature (ODF) in sufficient detail to justify the owner’s conclusion that it prompted economic hardship, social barriers, or denied opportunities that the owner experienced.”
• The certifying agency “may conclude that a reasonable person would not consider the owner economically disadvantaged in fact (EDIF) compared to non-disadvantaged individuals with comparable qualifications.”
• Agencies conducting these reevaluations must complete them no later than Dec. 24, 2026. The U.S. DOT may grant a one-time extension of up to 90 days to complete the process. A state may then apply to reinstitute its DBE program while working on revised goals.
• Existing DBE firms that have not yet applied for recertification have until March 24, 2027, or 90 days after their state’s extension, if applicable, to do so. Firms that miss the applicable deadline will be considered ineligible for the program.

These deadlines are intended to close out the initial reevaluation process for each state. Prospective DBE firms may still apply for certification (or recertification) on an ongoing basis.