How ESOs Can Support DBE Firms Through the 2025 Certification Changes

Katherine Zobre
2 days ago
4 min read

The U.S. Department of Transportation's October 2025 Interim Final Rule has significantly altered the process of Disadvantaged Business Enterprise (DBE) certification. For entrepreneurial support organizations (ESOs), chambers of commerce, and state DBE offices, this represents both a challenge and an opportunity to provide critical support to small business communities.

Understanding What's Changed

The new rule eliminates race- and sex-based presumptions of disadvantage, requiring all applicants—both new and existing—to demonstrate social and economic disadvantage through individualized evidence. This means:

All currently certified DBEs must be reevaluated under new standards
Firms cannot rely on demographic characteristics for certification eligibility
Personal narratives with specific evidence are now required from all applicants
During the transition period, DBE participation cannot be counted toward goals and contract goals cannot be set

The Critical Support Gap

This transition creates significant challenges for small businesses:

Documentation burden: Firms must now compile detailed evidence of specific instances of economic hardship, systemic barriers, and denied opportunities
Narrative development: Many business owners have never had to articulate their challenges in a formal legal framework
Uncertainty: Temporary loss of certification benefits during reevaluation
Technical complexity: Understanding what constitutes sufficient "preponderance of evidence"

How State DOT DBE & Airport Concessions DBE Offices Can Lead

State DBE offices and UCPs have the most direct impact on implementation:

1. Clear, Proactive Communication

Publish detailed timelines for the reevaluation process
Create state-specific guidance documents with examples
Establish dedicated hotlines or email addresses for questions
Send personalized outreach to all currently certified firms

2. Technical Assistance

Develop state-specific personal narrative templates or guidance
Provide "office hours" for firms to ask questions
Offer pre-submission reviews (where capacity allows)
Create FAQs based on common questions

3. Process Transparency

Publish information about what evaluators will look for
Share (anonymized) examples of successful narratives
Clarify evidence standards and documentation requirements
Provide estimated processing times

4. Stakeholder Coordination

Partner with PTACs, chambers, SBDCs, and other ESOs
Train partner organizations on new requirements
Create referral networks for specialized assistance
Host joint workshops and information sessions

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How APEX Accelerators Can Help

APEX Acclerators (formerly Procurement Technical Assistance Centers, (PTAC)) are uniquely positioned to support firms through this transition:

1. Educational Workshops

Host sessions explaining the new certification requirements
Provide timeline clarity on the reevaluation process
Explain what "individualized proof" means in practice
Cover documentation best practices

2. One-on-One Counseling

Help firms inventory their experiences and potential evidence
Review draft personal narratives for completeness
Identify gaps in documentation before submission
Connect firms with appropriate resources (legal, financial advisors)

3. Documentation Support

Create checklists of required materials
Help firms organize financial records and PNW statements
Assist in identifying "similarly situated non-disadvantaged" comparisons
Guide firms on quantifying economic impact

4. Bridge Strategy Development

Help firms identify non-DBE contracting opportunities during transition
Develop marketing strategies that don't rely on DBE status
Support capability statement updates
Identify alternative small business certifications (8(a), HUBZone, WOSB, etc.)

How Chambers of Commerce Can Contribute

Chambers can leverage their convening power and business networks:

1. Information Hub

Serve as a central clearinghouse for updates from state UCPs
Track and communicate reevaluation timelines
Share success stories and templates (where appropriate)
Host Q&A sessions with state DBE officials

2. Peer Learning Networks

Create confidential peer support groups for affected businesses
Facilitate knowledge sharing among firms going through reevaluation
Connect businesses with mentors who've successfully navigated certification

3. Advocacy and Communication

Communicate chamber members' challenges to state transportation departments
Advocate for reasonable timelines and clear guidance
Provide feedback to UCPs on process improvements
Amplify the voice of affected businesses

4. Resource Mobilization

Connect firms with pro bono legal services
Partner with accounting firms for PNW statement assistance
Organize writing coaches or communications professionals to help with narratives
Identify grant funding for application support services

Recommended Personal Narrative Framework

ESOs should guide firms toward a structured approach:

Section 1: Educational Barriers

Specific instances with dates, locations, outcomes
Economic impact (lost opportunities, delayed progress)
Comparison to non-disadvantaged peers

Section 2: Employment Barriers

Documented instances of economic hardship
Career progression compared to similarly situated individuals
Quantified financial impact

Section 3: Business Barriers

Financing challenges (interest rates, loan denials, terms)
Market access issues with specific examples
Contract opportunities denied or delayed
Supply chain or vendor relationship challenges

Section 4: Quantified Economic Impact

Dollar amounts wherever possible
Timeline of cumulative effects
Current position vs. projected position absent barriers

Section 5: Supporting Documentation

PNW statement
Loan applications and responses
Bid records
Financial statements
Any other relevant evidence

Action Steps for ESOs

Immediate (Next 30 Days)

□ Contact your state UCP for specific timeline and guidance

□ Inventory your current DBE clients and reach out proactively

□ Develop educational materials specific to the new requirements

□ Schedule initial information sessions

Short-term (30-90 Days)

□ Create partnerships with legal and financial service providers

□ Develop templated frameworks (not forms, but guidance)

□ Establish regular office hours for DBE questions

□ Track common challenges and questions

Ongoing

□ Advocate for reasonable implementation timelines

□ Share best practices across ESO networks

□ Monitor firm success rates and identify bottlenecks

□ Adjust support services based on emerging needs

Critical Considerations

What ESOs SHOULD Do:

Empower firms to tell their authentic stories
Help organize and present genuine experiences effectively
Provide factual information about requirements
Connect firms to appropriate professional services

What ESOs Should NOT Do:

Provide legal advice (unless appropriately credentialed)
Fill out applications on behalf of firms
Make promises about certification outcomes
Suggest fabricating or exaggerating experiences

The Path Forward

This transition period is challenging, but ESOs have a vital role to play. By providing education, resources, and support, entrepreneurial support organizations can help ensure that eligible small businesses successfully navigate the new certification requirements.

The firms most likely to succeed will be those who:

Start the process early
Document thoroughly
Partner and communicate
Present clear, specific, quantified evidence

As trusted advisors to the small business community, ESOs must step up during this critical period. The quality and accessibility of support services in the coming months will significantly impact which businesses maintain their DBE status and continue accessing federal contracting opportunities.

This blog post is for informational purposes only and does not constitute legal advice. Businesses should consult with qualified legal counsel regarding their specific certification situations.

About The Author: The Founders Playground LLC provides fractional program support to entrepreneurial support organizations. We help ESOs maximize their impact through strategic planning, program design, and operational excellence.