DBE/ACDBE Reevaluation: What Certified Firms Need to Know

The Texas Unified Certification Program is reevaluating every Texas-based Disadvantaged Business Enterprise (DBE) and Airport Concession Disadvantaged Business Enterprise (ACDBE) firm under new federal eligibility criteria. Submissions are open through Thursday, April 30, 2026.

Austin Small and Minority Business Resources is not the certifying authority, that role belongs to the Texas Department of Transportation (TxDOT) but our office has been fielding questions from the firms we serve. The answers below address the most common ones. For questions specific to your submission, contact TxDOT's Civil Rights Division or call 512-416-4700.

The Basics

Do I have to submit a 2025 Reevaluation Application?

Yes, if you want to remain in the program. All previously certified Texas DBE and ACDBE firms who wish to continue participating must complete the reevaluation process by Thursday, April 30, 2026.

Why is reevaluation happening?

The federal Disadvantaged Business Enterprise Interim Final Ruling (IFR) updated the eligibility criteria for the DBE and ACDBE programs. Every Texas-based firm must be reevaluated under the new criteria. The Texas Unified Certification Program (TUCP) is administering the process statewide.

Has the DBE program been eliminated?

No. The DBE program still exists. The Interim Final Ruling did not eliminate the program — it updated the criteria for who qualifies.

Submission

Where do I submit my reevaluation application?

Submit your application to the agency that originally certified your business. If your DBE or ACDBE certification was issued through Austin Small and Minority Business Resources, submit through the [Austin SMBR Certification and Compliance System](https://austintexas.mwdbe.com/). If you were certified by another agency, submit to that agency directly. Other TUCP partners include:

- Texas Department of Transportation
- North Central Texas Regional Certification Agency
- South Central Texas Regional Certification Agency
- City of Houston
- Corpus Christi Regional Transportation Authority

What documents do I need to submit?

TxDOT requires four documents from qualifying owners:

- [Form CIV-PN](https://www.txdot.gov/content/dam/docs/division/civ/civ-pn-form-and-instructions.pdf) (Personal Narrative), with supporting documentation
- An updated Personal Net Worth Statement
- A complete copy of your most recently filed personal tax return, including all schedules and W-2s
- A current personal bank statement

Is there a specific date requirement for the personal bank statement?

Yes. The personal bank statement must be dated within 30 days of your Personal Net Worth Statement. It serves as supporting documentation for the amount entered on Line 1, Cash and Cash Equivalents (checking and savings accounts, certificates of deposit and similar holdings).

What information should I include in my personal narrative?

TxDOT's instructions ask that your narrative:

- Be based on your individualized experiences in American society
- Describe specific incidents of economic hardship, systemic barriers and denied opportunities, including dates, context, supporting documentation and outcomes
- Demonstrate how those incidents impeded your progress or success in education, employment or business
- Compare your experiences to those of others who did not face the same disadvantages
- Not rely on or refer to race or sex, in whole or in part

For full instructions, refer to [Form CIV-PN](https://www.txdot.gov/content/dam/docs/division/civ/civ-pn-form-and-instructions.pdf).

What if I miss the April 30 deadline?

Contact TxDOT's Civil Rights Division as soon as possible. Firms that do not submit by the deadline will be removed from the TUCP directory.

What if I don't want to seek reevaluation?

Firms may withdraw from the program by submitting a technical support ticket through the TUCP portal with "Withdraw DBE/ACDBE Certification" in the subject line.

Home State and Interstate Firms

I have been reevaluated by my home state. Do I also need to submit a reevaluation application with Texas?

No. You only need to complete the reevaluation process with your home state or original state of certification.

I have been reevaluated by my home state. Can I submit a DBE or ACDBE interstate application to SMBR?

Not at this time. Austin SMBR is not accepting DBE or ACDBE interstate applications during reevaluation. As part of the Texas Unified Certification Program, the City of Austin follows TxDOT's lead, and TxDOT has paused all DBE and ACDBE certification-related activities until the statewide reevaluation process is complete.

After You Submit

What happens during the review period?

All DBE and ACDBE firms will be temporarily delisted from the TUCP directory while reevaluation is underway. Only firms that demonstrate eligibility under the new criteria will be reinstated. TxDOT subject matter experts will handle review, evaluation and approval recommendations.

Are new certifications being processed during this time?

No. New DBE and ACDBE certification applications, interstate applications and Declarations of Eligibility are temporarily on hold. They will resume after the statewide reevaluation process is complete. Pending Declaration of Eligibility certification dates will not change.

Active Contracts

What happens to my existing City of Austin contracts during reevaluation?

Your existing subcontract agreements remain in place. A signed subcontract with the prime contractor establishes your contractual right to perform the work on that specific contract.

Can a prime contractor drop me because of reevaluation?

Federal regulation 49 CFR §26.53(f) continues to apply during this period. Approved committed DBEs cannot be terminated from a contract without TxDOT's prior written approval. If a prime contractor self-performs the work of a committed DBE, the prime is not entitled to payment for that work.

Are prompt payment requirements still in effect?

Yes. Prompt payment applies to all subcontractors, not just DBEs. For contracts executed before October 3, 2025, prime contractors must enter payments in TxDOT's Data Management System, and subcontractors must confirm prompt payment — even when the reported payment is zero.

Will TxDOT continue conducting Commercially Useful Function reviews?

TxDOT will not conduct Commercially Useful Function (CUF) reviews during the reevaluation process. Prime contractors are responsible for conducting their own internal CUF reviews during this time.

What happens to DBE participation counted on my contracts?

Once reevaluation concludes and goal setting and participation counting are reinstated, the Department will review DBE participation on all active City of Austin contracts based on expenditures. If a firm has been decertified, participation will not be counted from the date of decertification forward. The work itself can continue under the existing subcontract.

My prime wants to modify my subcontract. What process do they need to follow?

On federally funded City of Austin projects, prime contractors must submit a Request for Change to delete, reduce, add or otherwise modify a subcontract agreement, per their contract with the City. If you see changes happen without one, contact SMBR Compliance.

Resources and Support

Several resources are available to help certified firms through this transition:

- TxDOT's Civil Rights Division  or 512-416-4700 for questions specific to your reevaluation submission
- TxDOT's Interim Final Ruling webpage for the most current statewide guidance
- The previously recorded TxDOT reevaluation webinar available on TxDOT's website
- Austin SMBR's Certification Division for guidance on supportive services beyond reevaluation

If you need webinar materials translated or interpreted, contact TxDOT's Civil Rights Division. Advance notice is recommended.

Submit your reevaluation application through the Austin SMBR Certification and Compliance System by Thursday, April 30, 2026.