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DBE Interim Final Rule (IFR) information

DBE Interim Final Rule (IFR) information

 

DBE Interim Final Rule (IFR)

The U.S. Department of Transportation (USDOT) issued an Interim Final Rule (49 CFR Parts 23 & 26, Docket No. DOT-OST-2025-0897, RIN 2105-AF33). This ruling makes immediate and significant changes to the Disadvantaged Business Enterprise (DBE) and Airport Concession DBE (ACDBE) programs nationwide. The Arizona Department of Transportation has taken action to comply with the new requirements of the Interim Final Rule by establishing a dedicated resource page for DBE and ACDBE firms. Visit DBE Interim Final Rule (IFR) Information.

Notices from ADOT regarding USDOT DBE Interim Final Rule (IFR):

  1. IFR Implementation SBWD Communication - Oct. 16, 2025
  2. Follow up Guidance SBWD Communication - Nov. 21, 2025
  3. AZUCP Reevaluation Application Guidelines for DBE/ACDBE's in Arizona - updated December 12, 2025
  4. Notice to All DBE/ACDBE Firms - Jan. 6, 2026
  5. AZUCP Reevaluation Application Guidelines for DBE/ACDBE's in Arizona (Updated Feb. 2026)  - Feb. 17, 2026
  6. ADOT Webinar: From Policy to Practice | Webinar Slides (PDF) and Webinar Recording - March 12, 2026
  7. Action Required_ Reevaluation Application Submission Notification _ May 2026 Update - May 15, 2026
  8. AZUCP Webinar: After Reevaluation | Webinar Slides (PDF) - June 23, 2026
  9. AZUCP Navigating DBE Certification After July 1, 2026 (Updated June 30, 2026) - June 30, 2026
  10. Building the Future of Arizona’s DBE Program Together - July 8, 2026

Please reach out to our DBE Certification team if you have any questions at [email protected].

Reevaluation Process

Effective October 3, 2025, the U.S. Department of Transportation (DOT) has issued an Interim Final Rule (IFR) that immediately changes how the Disadvantaged Business Enterprise (DBE) and Airport Concession DBE (ACDBE) Programs operate nationwide.

The Arizona Unified Certification Program (AZUCP) has concluded its DBE reevaluation period and has resumed all certification activities effective July 1, 2026.

What This Means

  • Firms that did not submit a reevaluation application by June 30, 2026 have been delisted from AZUTRACS and are not eligible for participation in the DBE program, however these firms will remain listed as a Small Business Concern if they are self-registered.
  • After July 1, 2026 only firms that have been reevaluated and found eligible for continued DBE certification will be listed in the AZUTRACS as active DBEs.

If a firm submits a reevaluation application after July 1, 2026 and is found eligible, the DBE status will be updated and the firm will again be listed as an active DBE.

New DBE, ACDBE and interstate applications will now be accepted. New applications must be submitted online at utracs.azdot.gov, and the application will guide firms through the process of identifying the correct certifying agency based on the firm’s primary location. Note: All reevaluated firms will have their eligibility restored as of October 3, 2025 when the Interim Final Rule was issued with no gap in their certification status.

Firms that have already submitted their reevaluation applications to their certifying agency have either received or will soon receive a decision letter. Please log in to your certification record to view your most recent status update. No further action is required at this time.

Firms that have not yet submitted a reevaluation application can submit a new application and can contact the appropriate certifying agency to request assistance.

Next Steps for Arizona’s DBE Program

The successful completion of Arizona’s statewide DBE reevaluation process marks an important milestone for Arizona and our transportation partners. We sincerely appreciate the collaboration, patience and commitment demonstrated by certified firms, contractors, public agencies and industry stakeholders throughout this transition.

As implementation of the updated federal regulation continues, ADOT's focus now shifts toward strengthening the DBE Program plan through collaboration, strategic planning and continuous improvement.

Over the coming months, ADOT will be collaborating with the industry to establish the next steps in updating ADOT’s DBE program plan to align with the USDOT’s DBE Interim Final Rule (IFR), which went into effect on October 3, 2025. Together, we will continue building a transparent and effective DBE Program that expands opportunities, strengthens partnerships and supports Arizona’s transportation industry for years to come.

Authority

Federal Aid contracts and management of ADOTs DBE Program

  • The DBE program still exists. The IFR did not eliminate the DBE program.
  • The submission of Bidders List is still a requirement per 49 Code of Federal Regulation (CFR) § 26.11(c).
  • The termination provisions identified under 49 CFR § 26.53(f) continue to apply to existing contracts. Approved committed DBEs cannot be terminated without ADOT’s prior written approval.
  • Compliance with the prompt payment requirement is still applicable and applies to all subcontractors, not just DBEs.
  • Prime contractors must continue to report prompt payments to all subcontractors in ADOTs contract management systems for ADOT contracts, and the LPA DBE System for ADOT subrecipient contracts.
  • ADOT paused the goal setting process for ADOT and subrecipient federally-assisted contracts.
  • ADOT paused the performance of Commercially Useful Function (CUF) reviews of DBE work on existing contracts during the reevaluation process.
  • ADOT will continue to provide Supportive Services to the Small Business community.

USDOT official Frequently Asked Questions (FAQ) on DBE Interim Final Rule (IFR)

  • Published Dec. 01, 2025 (updated the original FAQ, released Oct. 24, 2025)