Effective October 3, 2025, the US Dept of Transportation issued changes to the DBE program for DOT contracting. We’re here to answer your FAQs.
This is currently an evolving situation!
This article was last updated on 11/12/2025. The information below represents the most recent guidance released from state UCPs and legal experts. WBEC-East is a 501c3 and does not participate in lobbying or partisan activities. This article is for educational purposes only.
Overview:
On 10/3/2025 the US DOT released an “Interim Final Rule” announcing changes to the DBE certification program, which is the certification for contracting with federal and state DOTs and airports. The change eliminates gender and racial qualifiers, and opens the eligibility to a more broad “disadvantaged” criteria. Going forward, currently certified DBEs will need to recertify by submitting a narrative explaining how they are disadvantaged, though as of 11/12, no states have yet to open this recertification process. While the federal government has been shut down, each state’s DOT and united certification program (UCP) has been working to interpret this new definition and create new recertification processes. There is no uniform timeline or guidance from most of the states as of this article’s publication.
Does this affect my WBENC or WOSB certification?
NO.
The DBE certification is specific to federal and state DOTs and airports. If you do not currently keep your DBE certification active and pursue government transportation contracting, this will likely not affect you.
The WBENC certification abides by a specific set of Standards & Procedures which is defined by the WBENC National Certification Committee. WBENC continues to be the premier certification accepted by hundreds of procurement departments throughout the private sector and in many cities and states across the country.
There have been no certification changes announced by WBENC.
The WOSB certification is one of the SBA’s certification programs for contracting with federal agencies. At this time, no changes have been announced to the WOSB program.
Learn more about different certifications: How to Pick the Right Certificate for Your Business
What can I do to protect my business during this time of change?
Focus on the range of your revenue, client, and sector streams. The majority of the media-attention this past year has been on changes to federal contracting and certification programs, including the DBE.
There’s steady ground to be found in state and city contracting, as well as the multitude of private sector corporations in every industry. The evolution of federal agency contracting processes does not necessarily reflect where any other contracting or certification programs are headed. Plus, diversification of revenue is always a good business practice as a general rule of thumb.
While others lean back to wait and see, NOW is the time for you to be leaning in to the procurement programs with corporations, cities, and states that continue to strongly support small business certifications.
I have my DBE – what do I do next?
Eventually all certified DBEs will need to submit a recertification accompanied by a narrative detailing how you and your business qualify as economically and/or socially disadvantaged.
However, while the government has been shut down, no further guidance has been given to the states on when these recertifications are due, or what constitutes the new definition of “economically and/or socially disadvantaged.” State DBE certifiers have been working to get clarification and begin updating their processes.
For now, no action is needed on your part.
Each state’s United Certification Program (UCP) will issue directions on how and when to recertify.
Ensure you are following your state’s DOT and UCP for recertification updates:
Pennsylvania
PAUCP landing page: https://paucp.dbesystem.com/
ProRank DBE Supportive Center: https://penndbe.prorankllc.com/
New Jersey
NJUCP landing page: https://njucp.dbesystem.com/
NJ Supportive Services: https://dot.nj.gov/transportation/business/civilrights/ssp.shtm
Delaware
DEUCP landing page: https://deldot.gov/Business/dbe/
DE Supportive Services: https://deldot.gov/Business/dbe/index.shtml?dc=supportiveServices
How do I prove that I am “disadvantaged” when I submit my DBE recertification?
There currently is no officially issued definition of what constitutes “disadvantaged,” and no universal guidance on how to write your narrative. Continue to follow your state DOT and UCP for announcements.
Reminder: many states do not yet have recertification open yet.
Each state’s United Certification Program (UCP) will issue directions on how and when to recertify.
In the meantime, start gathering some of the following:
Evidence of struggles obtaining contracts or credit: Insurance denials; High bonding requirements; Loan denials or high interest and unfavorable terms; Low bid success rates; Licensing or permitting delays; Quotes for prohibitively expensive essential equipment etc.
Examples of environmental obstacles: Census or zoning data showing high poverty or unemployment rates; Rating of the school system where you were raised; Lack of infrastructure in your current and/or childhood town; Documentation of first generation education/homeownership/business ownership; Evidence of career disruption due to illness or caregiving; Letters of support or testimony from community leaders and business connections, etc.
Data supporting industry barriers: Demographic data showing underrepresentation in industry, region, or trade associations; Examples of discrimination (with specific dates and impact); Proof of non-traditional learning or self-taught skills; Emails showing bias or lack of responsiveness from professional connections, etc.
Personal finances: Statement of personal net wealth; Utilization of personal savings to fund business; Multiple years of personal taxes; Low credit score; Student loan debt; Limited retirement savings; etc.
Business finances: Business plans or profit/loss statements showing slow growth; Cash flow statements indicating tight margins or inconsistent revenue; Payroll records showing minimal staffing or lack of owner compensation; Multiple years of tax returns; Accounts receivable aging reports showing delayed payments, etc.
Where can I go to learn more?
Pennsylvania DBE Support Services offers consulting and technical assistance
@DBELawyerDanielle Vlog for regular DBE insight geared towards small businesses
November 6 PennDOT Announcement outlining key changes