California Unified Certification Program

Below are the directions provided by the Los Angeles County Metropolitan Transportation Authority regarding their Unified Certification Program.

CALIFORNIA UNIFIED CERTIFICATION PROGRAM

March 2, 2026

Subject: Disadvantaged Business Enterprise (DBE)/Airport Concession Disadvantaged Business Enterprise (ACDBE) Eligibility Reevaluation Required

Dear Business Owner(s),

The U.S. Department of Transportation (U.S. DOT) issued an Interim Final Rule (IFR) which took effect on October 3, 2025. The IFR removes race- and sex-based presumptions from the definition of “socially and economically disadvantaged individual” as it pertains to DBE/ACDBE eligibility. Instead, majority owner(s) must now demonstrate on a case-by-case basis that the individual meets the criteria described in 49 CFR Section 26.67 to qualify as a DBE/ACDBE.

Section 26.67 states as follows:

(a) Non-presumptive Disadvantage. All applicants must demonstrate social and economic disadvantage (SED) affirmatively based on their own experiences and circumstances within American society, and without regard to race or sex.

(1) To satisfy the SED requirement and ensure all determinations of disadvantage are not based in whole or in part on race or sex, an owner must provide the certifier a Personal Narrative (PN) that establishes 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.

(2) The PN must state how and to what extent the impediments caused the owner economic harm, including a full description of type and magnitude, and must establish the owner is economically disadvantaged in fact relative to similarly situated non-disadvantaged individuals.

(3) The owner must attach to the PN a current Personal Net Worth (PNW) statement and any other financial information he considers relevant.

Your firm was DBE/ACDBE certified by the Los Angeles County Metropolitan Transportation Authority (Metro) prior to the effective date of the IFR. As such, you are hereby provided with the opportunity to submit documentation demonstrating your DBE/ACDBE program eligibility under the updated standards set forth in 49 CFR part 26. If you wish to maintain your DBE/ACDBE eligibility, you are required to submit a personal narrative, along with an updated PNW statement. It is requested that you provide this documentation to Metro by Thursday, April 16, 2026, to be reevaluated for certification under the updated eligibility standards. A firm that meets the new requirements will be recertified as a DBE and/or an ACDBE. If you do not submit the necessary information your firm will remain ineligible for the DBE/ACDBE Program until you submit the required documentation demonstrating DBE/ACDBE eligibility under the new standards.

To begin the re-evaluation process, please visit metro.gob2g.com and follow the below directions:

• Login to metro.gob2g.com
• Click “Renew/Apply for Certification”
• Click “Your firm is currently certified with Metro”
• Click “You are an existing DBE, and you would like to submit for re-evaluation”

Firms that submit documentation for reevaluation of DBE/ACDBE certification and are denied based on the new requirements will have the right to appeal the decision under 49 CFR Section 26.89. Instructions for submitting an appeal will be included in the denial letter. If you do not wish to proceed with submitting the required documentation, or if you believe your firm no longer qualifies for the DBE/ACDBE Program, please notify us at certificationunit@metro.net so that we may remove your firm accordingly.

Attached you will find guidance for demonstrating social and economic disadvantage. Please note, this is intended solely as a guide for firms seeking to demonstrate DBE/ACDBE eligibility under the IFR requirements and does not constitute legal advice. Firms are advised to monitor any future guidance or changes to the regulations issued by the DOT. If you have any questions regarding the DBE/ACDBE program updates, please contact us at (213) 922-2600 (option 1) or at certificationunit@metro.net. 

This guidance document is not intended to replace sound professional judgement. It is not legal advice. This document provides general information as part of the DBE reevaluation process.

Important Reminder:

Metro’s Small Business Enterprise (SBE), Disabled Veteran Business Enterprise (DVBE), Local Small Business Enterprise (LSBE), and Medium Size Business Enterprise (MSZ) Programs, which never used race- or sex-based presumptions of disadvantage, remain in effect and unchanged.

1. The IFR made changes to the ACDBE regulations in 49 CFR Part 23 in a substantially similar manner to those changes made in 49 CFR Part 26.