Reevaluation & Recertification of Disadvantaged Business Enterprise (DBE) and Airport Concessions DBE (ACDBE)

In Sept. 2025, the U.S. Department of Transportation (“USDOT”) issued an Interim Final Rule (“IFR”), concerning Disadvantaged Business Enterprise (“DBE”) and Airport Concessions DBE (“ACDBE”) programs. The IFR removed race and gender-based presumptions from the definition of “socially and economically disadvantaged individual." Therefore, the owner of a DBE or ACDBE applicant must demonstrate, on a case-by-case basis, that the individual meets the criteria described in 49 CFR § 26.67. To remain in the program(s), every DBE and ACDBE owner MUST submit a personal narrative (“PN”) and current personal net worth statement (“PNW”) as part of the reevaluation and recertification process. The IFR delineates rules governing transition to the new requirements and provides that until a unified certification program (“UCP”) completes the reevaluation process, “each recipient covered by that Unified Certification Program (“UCP”) may not: (1) include DBE contracts goals or concession-specific ACDBE goals; or (2) count any participation towards overall DBE or ACDBE goals.” See USDOT Guidance dated Sept. 30, 2025. 

Effective Aug. 31, 2026, the Miami-Dade County Strategic Procurement Department is accepting reevaluation documentation from existing DBE and ACDBE certified firms in accordance with the IFR, effective Oct. 3, 2025, for which it is the Jurisdiction of Original Certification (“JOC”), to determine and recertify DBE/ACDBE firms according to and consistent with the terms of the IFR.

All out-of-state (i.e., Interstate) DBE/ACDBE firms must first be reevaluated and recertified by their JOC UCP before they may reapply for Interstate certification, and those firms must provide an acceptance of recertification letter from their JOC. 

The following items must be submitted to Miami-Dade County, Strategic Procurement Certification Unit, through the Business Management Workforce System (“BMWS”)

• Personal Narrative for each owner claiming social and economic disadvantage.  In the narrative, the owner must:
  • Based on her or his own experiences and circumstances, demonstrate social and economic disadvantage that occurred within American society, and without regard to race or sex;
  • Establish the existence of disadvantage by a preponderance of the evidence based on individualized proof regarding specific instances of economic hardship, systemic barriers, and denied opportunities that impeded the owner’s progress or success in education, employment, or business, including obtaining financing on terms available to similarly situated, non-disadvantaged persons; and
  • State how and to what extent the impediments caused the owner economic harm, including a full description of the type and magnitude, and establish that the owner is economically disadvantaged in fact relative to similarly situated, non-disadvantaged persons.
    
    
• Current Personal Net Worth (PNW) Statement and any other financial information the owner considers relevant
  • A signed copy of the firm’s (including any affiliates) signed 2024 and 2025 Corporate Federal Tax Returns, with all schedules and pages.

Please follow the instructions below on how to submit the requested information via BMWS:

Log in to the mdcsbd.gob2g.com

1. Click the Apply for / Renew Certification button.
2. Click the Login link under Renew Your Certification.
3. In the decision tree, select You are an existing DBE and would like to submit for re-evaluation.
4. Click Submit a 2025 Re-evaluation Application.
5. Select the radio button to confirm the firm's name that is applying and then click Continue.
6. Check the box after reading the message and review the Document List.
7. Click Continue.
8. The application will open, and you can complete questions in General Information.
9. Attach the documents in the Document List.
10. Sign and Submit.

Failure to submit this required information will result in your firm remaining ineligible for counting towards DBE/ACDBE participation.  The firm will remain ineligible until successful completion of the reevaluation process and recertification.

Read the full text of USDOT’s Interim Final Rule and FAQs:

• 2025 Interim Final Rule
• Interim Final Rule FAQs

If you do not wish to participate in the reevaluation process and wish to withdraw your DBE/ACDBE certification, the SEDO can send a request to [email protected].

Please submit your re-evaluation documents no later than Oct. 31, 2026.  Upon receipt and review of your required submission, Miami-Dade County will notify you regarding your application and continued eligibility status.  Recertification documents submitted after this date will be processed only after all timely submissions have been evaluated and processed.

Should you have any questions regarding this matter, please contact our office at (305) 375-3111.