In October 2025, the U.S. Department of Transportation (USDOT) issued an Interim Final Rule (IFR) that changes how Disadvantaged Business Enterprise (DBE) and Airport Concession DBE (ACDBE) programs are managed. Agencies must now adhere to these new requirements.
The new directive is profoundly challenging, and navigating its complexity may feel overwhelming. However, with clear steps, you can keep your program on track. B2Gnow is committed to helping our customers protect their program initiatives and maintain funding and participation goals during this transition.
With more than 25 years of experience helping organizations adapt to changing regulations, B2Gnow provides the guidance, tools, and ongoing support you need to stay compliant and keep your program running smoothly.
The Immediate Impact: What the IFR Requires
The new IFR removes the Socially and Economically Disadvantaged Owner (SEDO) presumption based on race and/or sex, requires each business owner to demonstrate individual Social and Economic Disadvantage (SED) status without regard to race and sex, and adds strict rules for program management. All DOT-funded recipients need to address these new requirements quickly:
- Race and Sex Presumptions Removed: The IFR removes the assumption of disadvantage based on race or sex. Now, everyone seeking certification must provide their own proof of SED.
- Mandatory Re-evaluation: Every Unified Certification Program (UCP) must re-evaluate all currently certified DBEs and ACDBEs.
- Counting and Goal Credit: The IFR requires individualized re-evaluations of currently certified firms, and recipients should not count firms for DBE/ACDBE goal credit where certification relied on the now-disallowed race/sex presumptions until the UCP completes re-evaluation. USDOT guidance also notes that contracts executed before October 3, 2025, do not automatically require amendment, but whether a firm’s participation can be counted for DBE credit depends on the outcome of the re-evaluation process.
- Increased Documentation and Audit Oversight: The new SED requirements mean agencies must keep detailed records and have a clear, auditable compliance process for federal and state reviewers, including continued tracking of prompt payments and documentation for subcontractor terminations/removals.
B2Gnow’s Approach to IFR Implementation
We are ready to help your agency stay in compliance with the new Interim Final Rule requirements, using our decades of experience and proactive system development.
- Our Track Record: Throughout our 25+ year history, B2Gnow has supported organizations through numerous rule updates and related system impacts. We are here to support you during this IFR and are committed to updating your systems as needed to keep your organization compliant.
- Our Approach: We quickly identify all system impacts and communicate our plan through clear documentation and live review sessions. Our current solution, with its recent updates, already supports the majority of the requirements in the new rules.
- Proven Leadership in an Evolving Landscape: Managing federal compliance is complex, and the regulatory landscape is constantly shifting. As the trusted experts organizations depend on to navigate these changes, B2Gnow has already successfully supported programs with race- and sex-neutral standards in states such as Texas, Arizona, and Florida. This extensive, proven experience shapes our approach to nationwide implementation, ensuring your program stays protected as requirements evolve.
Strategic System Solutions: How B2Gnow Safeguards Your Program Integrity
To help you manage the IFR, B2Gnow offers system solutions that keep your program compliant and running smoothly.
- Mastering Certification & Re-evaluation
- Integrated Re-evaluation Intake: We have developed and deployed a streamlined re-evaluation application that prompts firms to submit only the new IFR-required documents: the Personal Narrative (PN) and Personal Net Worth (PNW) Statement.
- Digital Audit Assurance: We also use a dedicated re-evaluation-tracking feature and standard audit questions to keep the SED review process consistent and thorough. For customers using the PNW module, the system digitizes the entire process, eliminates handwriting errors, and automatically calculates financial totals.
2. Controlling Counting & Goal Suspension
- Program Suspension/Resumption: B2Gnow has developed a database script that allows our clients, on request, to make specific and targeted updates to contracts with federal funding – essentially allowing the firms that are indicated as for-credit to be placed on pause, and that agencies must document the pause and why it was made. Once the directory re-evaluation is complete, the firms can again be counted for credit on active contracts.
- Flexible Payment Control: If clients choose a more manual approach, our standard contract compliance audit tools allow users to adjust a firm’s for-credit payment status on a contract-by-contract, payment-by-payment basis, making it simple to pause counting for as long as needed and then easily resume, while still maintaining the primary components of reported data: payments, confirmations, and payment timing.
3. Reporting & Audit Readiness
- Audit-Proof Data Management: B2Gnow keeps all documentation in one place, which is important for DOT, FAA, and FTA program reviews. Our system’s configurable options make it easy to track IFR-related decertifications and clearly distinguish them from other directory removals.
• With the Outreach module, it’s easy to build outreach campaigns for specific groups such as active DBE/ACDBEs, Interstate-certified vendors, or those engaged on current contracts or concessions. The module tools allow for specific tracking of who viewed the campaign, how often, and which mechanism was used.
• Within the certification record itself, communications with firms can be logged, including Q&A requests for additional documentation or certification letters.
- Compliance Reporting and Forms: We provide the fields you need to show which firms are re-evaluated, pending, or non-responsive. We will add support for the updated Uniform Certification Application, the Personal Net Worth (PNW) statement fields, and any revised reporting fields or semi-annual report formats as USDOT publishes them.
4. Orchestrating Communication & Change Management
- Proactive Partner Guidance and Outreach: We keep customers informed with timely updates on regulatory changes through the system dashboard and email, host educational webinars, and share our plans in documentation and live review sessions. We also use advanced outreach tools to connect with specific certified groups and share documentation requirements.
- Mandatory Public Transparency: For customers who submit an IFR System Intake form, B2Gnow can request configuration updates, such as adding standard disclaimers to all vendor-facing portals and public directories to let users know that certification is suspended and re-evaluation is underway. We can also add an indicator to certified directories to show which firms have been re-evaluated under the IFR.
Protecting Your Program: Compliance and Efficiency with B2Gnow
The IFR brings a period of intense administrative work. Agencies must follow the new certification standards and maintain fully auditable compliance records throughout the complex suspension and re-evaluation period.
B2Gnow is your essential partner because we provide both compliance and continuity:
- Proven Reliability: B2Gnow is the most trusted platform for managing federal program requirements, trusted by over 30 State DOTs and more than 90 airports and transit authorities.
- Audit Defense: When federal rules shift, B2Gnow delivers the essential, reliable system to ensure your immediate and long-term compliance. Our platform centralizes all SED documentation and automatically manages complex goal-counting controls, helping your agency defend its program during federal reviews.
- Immediate System Agility: Our quick response to the IFR, including mass updates, digital forms, and new tracking workflows, shows our commitment to keeping your system aligned with the latest requirements.
You do not have to navigate the IFR alone. B2Gnow compliance experts work with you every step to keep your program compliant, efficient, and protected during this transition.
Next Steps
The IFR presents a key moment for agencies to adapt and strengthen their DBE/ACDBE programs. B2Gnow is committed to being your essential partner throughout this transition.
- For Current B2Gnow Customers:
- Visit the B2Gnow Help Center or your system dashboard for detailed guidance on the next steps. You’ll find everything you need, including the IFR System Intake Form (required for agency-specific configuration updates), a summary of our findings, and webinars covering the USDOT IFR in depth.
- For Organizations Not Yet B2Gnow Customers:
- Schedule a Consultation: Connect with a B2Gnow compliance expert to discuss your agency’s needs and challenges and learn how our system solutions can help. You can schedule a demo at www.b2gnow.com/request-a-demo/.
By taking these steps, you can protect your program’s integrity, maintain funding and participation goals, and ensure audit readiness. Partner with B2Gnow to confidently navigate the changing regulatory landscape and secure the future of your DBE/ACDBE program.
