Changes to DBE/ACDBE Certifications Rules

The U.S. Department of Transportation (DOT) has made immediate changes to how Disadvantaged Business Enterprise (DBE) and Airport Concessions DBE (ACDBE) certifications work. These changes took effect on October 3, 2025. 

What's new? 

• All DBE and ACDBE certifications will have to undergo a reevaluation process
  •  Race and gender are no longer automatic proof of disadvantage. You now have to show how you've been financially impacted by real barriers you’ve faced (e.g., lack of access to financing, business opportunities, or systemic hurdles) and how they caused financial harm. 
• To stay in the program, certified business owners must submit: 
  • A Personal Narrative explaining challenges you've faced (like trouble getting loans or contracts). 
  •  A Personal Net Worth statement showing your current financial situation. 

Contact Us: creoDBE@kcmo.org

What This Means for You 

• If your business is already certified, you’ll need to send in the new documents to be reviewed again under the updated rules.

• If Missouri is not your Jurisdiction of Original Certification: please be on the lookout for further information from your home state. The process will generally be the same as these changes have rolled out nationwide.

• While CREO, as a member of the Unified Certification Program, reviews these submissions, some parts of the program—like setting DBE participation goals—are temporarily paused. 

• If you would like to voluntarily withdraw your participation in the DBE program, please complete this form and send a copy to CREODBE@kcmo.org. You may also send an email to the same address with a statement that you are not interested in recertifying for the DBE program. 

• NOTE: This does not affect the City's Minority, Woman or Small Local Enterprise programs as these programs are not subject to Federal Rules and Regulations.  

Official Notice

DBE Laws, Policy, and Guidance
This page contains the DBE program regulations, official DOT guidance, and OA documents. Also posted are archived rules, regulations, guidance, and policies of the DBE program as well as various amendments and reports. Updates on the DBE Program are posted routinely.

The Department's current DBE and ACDBE Program Regulation is found in 49 C.F.R. Part 23 and 49 C.F.R. Part 26.

Interim Final Rule, October 3, 2025  pdf file
IFR Guidance

This interim final rule (IFR) ensures that the U.S. Department of Transportation operates its Disadvantaged Business Enterprise and Airport Concession Disadvantaged Business Enterprise Programs in a nondiscriminatory fashion—in line with law and the U.S. Constitution. The IFR removes race- and sex-based presumptions of social and economic disadvantage that violate the U.S. Constitution.

PUBLIC COMMENT PERIOD

This IFR is effective October 3, 2025. Comments must be received on or before November 3, 2025. To the extent practicable, DOT will consider late-filed comments. 
ADDRESSES: You may submit comments identified by the docket number DOT– OST–2025–0897 by any of the following 
methods: 
Federal Rulemaking Portal: http://www.regulations.gov. Follow the online instructions for submitting comments. 
Mail: U.S. Department of Transportation, Docket Operations, M– 
30, West Building Ground Floor, Room W12–140, 1200 New Jersey Avenue SE, Washington, DC 20590. 
Hand Delivery: U.S. Department of Transportation, Docket Operations, West Building Ground Floor, Room W12–140, 1200 New Jersey Avenue SE, Washington, DC 20590, between 9 a.m. 
and 5 p.m., Monday through Friday, except Federal holidays. 

Instructions: All submissions must include the agency name (Office of the Secretary of Transportation (OST), U.S. Department of Transportation (DOT)), docket name (49 CFR Parts 23 and 26), and docket number (DOT–OST–2025– 0897) or Regulatory Identifier Number 2105-AF33.

CREO is committed to helping your business understand the impact of these changes while ensuring the City of Kansas City small business programs remain fully compliant and effective. 

Soon we will be sending all certified DBEs a questionnaire which will assist in crafting your narrative. A blank, fillable Personal Net Worth form is attached here. Please complete and save to your device and submit it with your narrative when requested. 

We will also keep you informed of any guidance or other information we receive from the U.S. DOT.