DBE/ACDBE IFR Reevaluation
On Friday, October 3, 2025, 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. In compliance with this new ruling, the Alaska Department of Transportation (Alaska DOT&PF) Civil Rights Office (CRO) has created the following process to recertify DBE & ACDBE firms.
Authority:
- 49 CFR Parts 23 & 26 Docket No. DOT-OST-2025-0897, RIN 2105-AF33
- 49 CFR Part 26 Participation by DBE in DOT Financial Assistance Programs
- 49 CFR Part 23 Participation of DBE in Airport Concessions
Key Provisions & DBE Impact:
Key Provisions:
- Certification Review: All DBE firms previously certified using race- or sex-based presumptions of social and economic disadvantage must be reevaluated by CRO to determine eligibility under the new standards established in the IFR.
- Personal Narrative Requirement: Certified DBE firms 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), must now submit a personal narrative explaining their social and economic disadvantage, without regard to race or gender, and submit an updated personal net worth statement.
- The bidder’s list is still required, except for the race and gender reporting.
DBE Impact:
- The certifications for any DBE firm that previously qualified based on a presumed disadvantage will not be effective during the certification review period.
- DBE firms must submit a personal narrative and a personal net worth statement, which will be reviewed during the certification review period.
- This change does not impact prevailing wage, certified payroll, or prompt payment.
FAQs on IFR:
- Effective 10/03/2025 – View FAQ #1
- Effective 12/01/2025 – View FAQ #2
Timeline:
- 09/30/2025: USDOT notified all UCPs that changes were being issued to the programs.
- 10/03/2025: USDOT released the new changes to the DBE/ACDBE programs.
- 10/03/2025: USDOT issued FAQ Guide #1
- 10/06/2025: Alaska DOT&PF CRO submitted necessary changes for Standard Specifications (Special Provisions)
- 10/08/2025: CRO notified DBE/ACDBE Firms
- 11/10/2025: Interstate DBE/ACDBE firms were decertified.
- 11/12/2025: Sent out survey to DBE/ACDBE firms seeking input on IFR response.
- 12/01/2025: USDOT issued FAQ Guide #2
- 12/22/2025: CRO sent out information on reevaluation.
- 01/05/2026: CRO created a new page on the website.
Timeline: What's Next?
January:
- Create page on the CRO website for reevaluation.
- Host training sessions for DBE/ACDBE firms on reevaluation process.
February:
- Host training sessions for DBE/ACDBE firms on reevaluation process.
March:
- Discuss IFR changes and how the CRO has responded during the Annual Civil Rights Conference.
- During the conference, host training session for DBE/ACDBE firms on reevaluation process.
June:
- The CRO hopes to have a finalized DBE/ACDBE Directory with firms recertified.
Reevaluation Process:
- DBE/ACDBE firms are provided with instructions and forms for completing the Personal Narrative (PN) Statement and the Personal Net Worth (PNW) Statement, including guidance on how to submit the required information.
- Firms must submit all relevant documentation to DOT.CRO.DBECerts@alaska.gov.
- A review panel will evaluate the submitted materials.
- If the information does not meet IFR requirements, a Certification Specialist will contact the firm with feedback and instructions for correction. The goal is to successfully recertify all firms.
- If the information does meet IFR requirements, the firm will be notified of approval.
- Firms that do not respond to Certification Staff may be subject to decertification.
Recertification Process:
- Firm Is Notified: The firm receives a notice explaining that recertification is required and what documents must be submitted.
- Identify Who Must Submit Documents: Any owner who controls 51% or more of the business must submit the required materials.
- Complete the Personal Narrative (PN): Each required owner writes a PN describing experiences of social and economic disadvantage in education, employment, or business.
- The narrative must explain:
- What happened
- When and where it happened
- Who was involved
- How it caused economic harm or limited opportunities
- Why the owner is disadvantaged compared to others in similar situations.
- Complete the Personal Net Worth Statement (PNW): Each required owner completes the official PNW Statement and includes the required supporting documents.
- Submit All Documents: The firm submits the PN, PNW Statement, and supporting documents to the certification office by the stated deadline.
- Review by Certification Office: The certification office reviews the materials to determine whether the firm qualifies for continued DBE/ACDBE certification.
- Receive Decision:
- The firm is notified of the decision:
- If approved, the firm remains eligible.
- If documents are not submitted by the deadline, the firm becomes ineligible.
Recertification Instructions:
Forms:
Training Sessions:
The CRO will be offering optional training sessions for DBE/ACDBE firms starting in January. Sessions will be recorded and posted on this page.
Optional Training Sesson:
- When: Tuesday, 01/20/2026
- Time: 01:00 PM AKST Time
- Platform: Zoom
- Register: Zoom Link
Optional Training Sesson:
- When: Wednesday, 01/28/2026
- Time: 10:00 AM AKST Time
- Platform: Zoom
- Register: Zoom Link
Questions? Contact:
Certification Questions? Email: DOT.CRO.DBECerts@alaska.gov
Training Session Questions?
Email Zhenia C. Peterson at zhenia.peterson@alaska.gov or Amanda Dawson at amanda.dawson@alaska.gov.