DBE Contract Management

ADOT has established a Disadvantaged Business Enterprise program in accordance with the regulations of the U.S. Department of Transportation (USDOT), 49 CFR Part 26. As a condition of receipt of funding, ADOT has signed an assurance that it will comply with 49 CFR Part 26. It is ADOT's policy to ensure that DBEs, as defined in Part 26, have an equal opportunity to receive and participate in USDOT-assisted contracts. It is also the policy of the department to:

• Ensure nondiscrimination in the award and administration of USDOT-assisted contracts.
• Create a level playing field on which DBEs can compete fairly for USDOT-assisted contracts.
• Ensure that the DBE program is narrowly tailored in accordance with applicable law.
• Ensure that only firms that fully meet 49 CFR Part 26 eligibility standards are counted as DBEs.
• Help remove barriers to the participation of DBEs in USDOT-assisted contracts.
• Assist in the development of firms that can compete successfully in the marketplace outside the DBE program.

This site provides policies, guidelines, contract specifications, forms and resources relevant to DBE contract management. Forms are provided for use by ADOT internal departments, consultants/contractors and DBEs and small businesses. Different forms are required based on whether contracts are for construction or professional services (Engineering Design and Goods and Services contracts) and are further separated depending on whether the contract has been assigned a DBE goal or not.

Explore the various tabs for specific information.  If you can’t find what you’re looking for, email [email protected] or call 602.712.7761. You can also contact any one of our Contract Management Services staff.

All DBE Program Partners

Until further notice, to ensure compliance with the IFR below are DBE program changes effective October 3, 2025:

Key Changes

Temporary Suspension of Goals and Counting: The Arizona UCP has completed the Reevaluation of previously certified DBE firms in accordance with the IFR. Until ADOT has updated its DBE Program Plan and submitted its DBE Goal methodology to USDOT for review and approval, ADOT and all subrecipients must not:

• Set DBE contract goals.
• Count DBE participation toward overall program goals.

Existing Contracts executed prior to Oct. 3, 2025: Contracts already awarded and executed remain valid; however, DBE commitments and participation under those contracts cannot be counted toward goal attainment during the reevaluation period.

• Prime contractors must still submit Termination, Substitution, Reduction (TSR) Requests for committed DBEs even if the DBE subcontractors are no longer DBEs recertified in accordance with the IFR. TSR Request must be for good cause per 49 CFR Part 26.53(f).
• Good cause for termination exists if a DBE loses its DBE certification after the reevaluation process described in § 26.111 is completed because it is ineligible to receive DBE credit for the type of work required.

Goal Setting: All DBE goal requirements are suspended effective October 3, 2025. ADOT and subrecipients cannot set DBE goals on contracts. All projects shall be advertised and awarded with the applicable DBE Contract language without goal, updated in accordance with the IFR.

• Goal requests are still required to be submitted so the project number can be available in ADOT’s DBE Directory, AZ UTRACS, so Bidders can submit their Bidders List.

Compliance Monitoring: DBE compliance activities such as completing commercially useful function (CUF) site visits on existing and future contracts are suspended.

• The submission of a bidders list by all bidders seeking to bid on ADOT and all subrecipient USDOT-assisted contracts is still required per 49 CFR Part 26.11(c).

Next Steps

Goal Requesters: Continue to submit goal requests on all USDOT-assisted contracts so the project number can be available in ADOT’s DBE Directory, AZ UTRACS, so Bidders can submit their Bidders List.

Prime Contractors/Bidders: Do not submit utilization plans, commitments or reporting tied to DBE credit during this transition.

• Continue reporting prompt payment to all lower tier subcontractors on ADOT and All subrecipient contracts in the applicable contract management system, DOORS, or the ADOT LPA DBE System.
• Continue submitting Bidders list per 49 CFR Part 26.11(c).

From SBWD

• Clear Guidance: SBWD will publish updates through our IFR website, contract management systems DOORS or LPA DBE System, and email communications for firms who are signed up to receive SBWD communications.
• Support: As federal guidance is released and best practices emerge across states, SBWD will keep you informed and provide the tools you need to navigate the changes confidently. 

ADOT will continue to provide specific detailed information related to project impacts, we will also host Update sessions and provide outreach to ensure all partners understand and comply with the new requirements. 

We recognize the hardships these immediate changes create for firms, contractors and local agencies.

ADOT is committed to supporting you through this difficult transition.