Compliance Research Hub

Everything you need to know
about MWBE & DBE compliance

Agency requirements, participation goals, required forms, legal basis, and GFE documentation standards โ€” all in one place.

NYSDOTMTANYC DDC Port AuthorityDASNYOGS
State
NYSDOT
MTA
OGS / ESD
City / Authority
NYC DDC
DASNY
Port Authority
NJ DOT โ€” coming soon
NJ Transit โ€” coming soon
MDOT MBE โ€” coming soon
Baltimore City โ€” coming soon
City of Chicago โ€” coming soon
IL DOT โ€” coming soon
MassDOT โ€” coming soon
MBTA โ€” coming soon
New York State Department of Transportation
DBE & MWBE compliance for state highway, bridge, and transportation contracts
State agencyFederally fundedTransportation
Program
DBE / MWBE
Threshold
$750K+
Goal range
15โ€“30%
GFE required
Yes โ€” at bid
Overview
Goals & thresholds
GFE requirements
Required forms
Legal basis
Reporting
Program overview

NYSDOT administers two parallel diversity programs: the federal Disadvantaged Business Enterprise (DBE) program under 49 CFR Part 26 for federally funded contracts, and the state MWBE program under Article 15-A for state-funded contracts.

Prime contractors must either meet the participation goal or demonstrate a good faith effort. Goals are project-specific based on work type and available certified firms in the project area.

ConDocs covers NYSDOT fully โ€” CONR 391 Utilization Plan and CONR 392 Monthly DBE Payment Certification are auto-generated from your campaign data.
Participation goals by contract type
Contract typeCert typeTypical goalThreshold
Highway construction (federal)DBE15โ€“25%$750,000+
Highway construction (state)MBEWBEMBE 10% / WBE 10%$750,000+
Bridge constructionDBEMBEWBE15โ€“30%$750,000+
Professional servicesMBEWBEMBE 14% / WBE 6%$250,000+
Consultant/designDBE10โ€“15%$750,000+
Good Faith Effort requirements
1
Advertise the contract
Place advertisements in general circulation, minority-focused media, and trade publications at least 10 days before bid opening.
2
Send written solicitations
Email or fax bid invitations to all certified DBE/MWBE firms in relevant trade categories within the project area. Document delivery confirmation.
3
Follow up by phone
Make follow-up telephone calls to firms that received written solicitations. Log date, time, and who was spoken to.
4
Break down work into smaller scopes
Consider breaking work into smaller packages to increase opportunities for DBE/MWBE participation where commercially reasonable.
5
Document all efforts
Submit CONR 391 with your bid. If goal is not met, submit full GFE documentation package for NYSDOT review.
Required forms
DBE/MWBE Utilization Plan
CONR 391
At bid submission
DBE Payment Certification
CONR 392
Monthly during contract
GFE Documentation Package
GFE Package
At bid (if goal not met)
DBE Trucking Verification
CONR 395
As applicable
Subcontractor Payment Report
CONR 232
With each payment request
ConDocs auto-generates CONR 391 and CONR 392 from your campaign and payment data.
Reporting requirements
ReportFormFrequencyDue dateConDocs
DBE Payment CertificationCONR 392Monthly10th of following monthAuto-generated
MWBE Utilization ReportCONR 391At bidWith bid submissionAuto-generated
Annual DBE ReportFHWA 1391AnnualAugust 1Coming soon

All reports cover complete, closed periods only. ConDocs enforces this โ€” reports are available after the period closes.

Metropolitan Transportation Authority
DBE & MWBE compliance for transit capital construction and procurement contracts
State authorityFederally fundedTransit
Program
DBE / MWBE
Threshold
$750K+
Goal range
20โ€“35%
GFE required
Yes โ€” at bid
Overview
Goals & thresholds
GFE requirements
Required forms
Legal basis
Reporting
Program overview

The MTA administers DBE programs across all its agencies (NYCT, LIRR, Metro-North, MTA Construction & Development) under FTA requirements (49 CFR Part 26). The MTA's overall DBE goal is set triennially and applies to all FTA-assisted contracts.

The MTA's capital program โ€” one of the largest transit capital programs in the world โ€” regularly awards contracts exceeding $1 billion, making DBE compliance critical for any prime doing business with the MTA.

ConDocs generates MTA Schedule B (Utilization Plan) and DBE-3 (Monthly Payment Report) from your campaign data.
Participation goals by contract type
Contract typeCert typeTypical goalThreshold
Construction contracts (FTA-funded)DBE20โ€“30%$750,000+
Construction contracts (state-funded)MBEWBEMBE 15% / WBE 15%$750,000+
Professional services (FTA-funded)DBE15โ€“25%$250,000+
Procurement / supply contractsDBEMBE10โ€“20%$500,000+
ACDBE (airport concessions)ACDBEVaries by airportAll contracts
Good Faith Effort requirements
1
Pre-bid advertisement
Publish bid notice in MTA's DBE outreach publication and other general/minority media at least 10 days before bid date.
2
Written solicitations to DBE firms
Send written bid invitations to all certified DBE firms in relevant NAICS categories. Maintain proof of delivery (email confirmations or fax logs).
3
Follow-up calls
Make documented follow-up calls to all firms that received written solicitations. Log contact name, date, time, and outcome.
4
Project documents available
Make plans, specifications, and other project documents available to interested DBE firms in a timely manner.
5
Submit Schedule B with bid
Complete and submit MTA Schedule B (DBE Utilization Plan) with your bid. If goal not met, submit full GFE documentation for MTA DBE Office review.
Required forms
DBE Utilization Plan
Schedule B
At bid submission
DBE Monthly Payment Report
DBE-3
Monthly during contract
GFE Documentation Package
GFE Package
At bid (if goal not met)
DBE Subcontractor Payment Certification
DBE-6
With each progress payment
ConDocs auto-generates Schedule B and DBE-3 from your campaign and payment data.
Reporting requirements
ReportFormFrequencyDue dateConDocs
DBE Monthly Payment ReportDBE-3Monthly10th of following monthAuto-generated
DBE Utilization PlanSchedule BAt bidWith bid submissionAuto-generated
Semi-annual DBE ReportFTA ReportSemi-annualJune 1 / Dec 1Coming soon
Office of General Services / Empire State Development
MWBE compliance for state procurement and economic development contracts
State agency
Program
MWBE
Threshold
$25K+
Goal range
MBE 14% / WBE 6%
GFE required
Yes
Overview
Goals & thresholds
GFE requirements
Required forms
Legal basis
Reporting
Program overview

OGS and ESD administer MWBE requirements under Article 15-A of the New York Executive Law. OGS handles state procurement contracts while ESD handles economic development grants, loans, and incentive programs including 421-a tax abatements and capital grants.

The statewide goals are MBE 14% and WBE 6% for construction and MBE 14% and WBE 6% for professional services. These goals apply to all state contracts and subcontracts above $25,000.

ConDocs supports OGS quarterly MWBE compliance reporting. Reports are generated after each quarter closes.
Statewide participation goals
Contract typeMBE goalWBE goalThreshold
Construction14%6%$25,000+
Professional services14%6%$25,000+
Commodities & supplies14%6%$25,000+
ESD capital grants14%6%All grants
421-a / PILOT agreementsProject-specificProject-specificPer agreement

Goals are applied to the subcontractable portion of the contract, not the total contract value.

Good Faith Effort requirements
1
Solicit certified MWBE firms
Contact certified MBE and WBE firms registered in the NYS Contract System directory for each relevant trade category.
2
Written solicitations
Send written bid invitations at least 10 days before bid date. Maintain delivery proof.
3
Follow-up contact
Follow up by phone or email to confirm receipt and encourage participation. Document all contacts.
4
Submit Utilization Plan
Submit Form MWBE 100 (Utilization Plan) with bid. If goals not met, submit GFE documentation including all outreach records.
Required forms
MWBE Utilization Plan
MWBE 100
At bid / contract award
MWBE Quarterly Compliance Report
MWBE 102
Quarterly during contract
MWBE Payment Report
MWBE 101
With each payment request
GFE Documentation
GFE Package
At bid (if goal not met)
ConDocs generates the GFE package and supports quarterly MWBE compliance reporting for OGS/ESD contracts.
Reporting requirements
ReportFormFrequencyDue dateConDocs
MWBE Quarterly Compliance ReportMWBE 102Quarterly15th after quarter endAuto-generated
MWBE Payment ReportMWBE 101Per paymentWith payment requestComing soon
Annual MWBE ReportAnnualAnnualJanuary 31Coming soon
NYC Department of Design & Construction
M/WBE compliance for New York City capital construction projects
City agency
Program
M/WBE
Threshold
$1M+
Goal range
25โ€“35%
GFE required
Yes โ€” at bid
Overview
Goals & thresholds
GFE requirements
Required forms
Legal basis
Reporting
Program overview

NYC DDC administers M/WBE requirements under Local Law 1 of 2013 (NYC Administrative Code ยง 6-129) and NYC Executive Order 50. DDC sets project-specific M/WBE goals on construction contracts over $1 million, typically 25โ€“35% depending on available certified subcontractors.

NYC certifies firms through NYC Small Business Services (SBS) โ€” the same directory ConDocs syncs weekly for the NYC market. All MBE, WBE, LBE, and EBE firms certified by NYC SBS are eligible for DDC projects.

ConDocs syncs the NYC SBS certified firm directory weekly. All 5,000+ NYC-certified firms are searchable in the ConDocs directory.
Participation goals by contract type
Contract typeCert typesTypical goalThreshold
Construction (general)MBEWBE25โ€“35%$1,000,000+
Construction (infrastructure)MBEWBELBE20โ€“30%$1,000,000+
Professional servicesMBEWBE15โ€“25%$100,000+
Standard contractsMBEWBEEBEProject-specific$1,000,000+
Good Faith Effort requirements
1
Search NYC SBS BuyCertified directory
Use NYC SBS BuyCertified or ConDocs to identify certified M/WBE firms in each relevant trade category on the project.
2
Send written bid invitations
Email or fax bid invitations to identified firms. Include project description, scope, bid date, and contact information. Maintain delivery logs.
3
Make documents available
Provide plans, specifications, and other bid documents to interested M/WBE firms. Log which firms accessed documents and when.
4
Follow-up contact
Follow up with firms by phone. Document contact name, date, time, and whether firm is interested in participating.
5
Submit Appendix A with bid
Complete and submit DDC Appendix A (M/WBE Utilization Plan). If goal not met, submit GFE documentation including all outreach records and reasons firms were not selected.
Required forms
M/WBE Utilization Plan
Appendix A
At bid submission
Subcontractor Tracking Form
STF
Monthly during contract
GFE Documentation Package
GFE Package
At bid (if goal not met)
Subcontractor Payment Certification
SPC
With each progress payment
ConDocs generates the GFE package and Subcontractor Tracking Form (STF) from your campaign and payment data.
Reporting requirements
ReportFormFrequencyDue dateConDocs
Subcontractor Tracking FormSTFMonthly15th of following monthAuto-generated
M/WBE Utilization PlanAppendix AAt bidWith bid submissionAuto-generated
Annual M/WBE ReportAnnualAnnualFebruary 1Coming soon
Dormitory Authority of the State of New York
MWBE compliance for higher education, healthcare, and public facility construction
State authority
Program
MWBE
Threshold
$100K+
Goal range
MBE 14% / WBE 6%
GFE required
Yes
Overview
Goals & thresholds
GFE requirements
Required forms
Legal basis
Reporting
Program overview

DASNY finances, builds, and operates facilities for New York's colleges, universities, hospitals, and courts. All construction contracts are subject to Article 15-A MWBE requirements. DASNY maintains its own Business Registry of certified MWBE firms and requires quarterly MWBE compliance reporting.

DASNY is one of the largest construction program managers in New York, with an active portfolio exceeding $3 billion annually across CUNY, SUNY, healthcare, and state court facilities.

ConDocs supports DASNY quarterly MWBE reporting. Reports are generated after each quarter closes on March 31, June 30, September 30, and December 31.
Participation goals
Contract typeMBE goalWBE goalThreshold
Construction โ€” CUNY/SUNY14%6%$100,000+
Construction โ€” Healthcare14%6%$100,000+
Construction โ€” Courts14%6%$100,000+
Professional services14%6%$25,000+
Good Faith Effort requirements
1
Search DASNY Business Registry
Search the DASNY Business Registry and NYS Contract System for certified MWBE firms in relevant trade categories.
2
Written solicitations
Send written bid invitations to identified firms at least 10 days before bid date. Maintain delivery confirmation records.
3
Follow-up contact
Contact firms by phone to confirm receipt and encourage participation. Document all contacts with date, time, and name.
4
Submit Utilization Plan
Submit DASNY MWBE Utilization Plan with bid. If goal not met, submit GFE documentation package for DASNY MWBE Office review.
Required forms
MWBE Utilization Plan
DASNY MWBE-UP
At bid submission
Quarterly MWBE Compliance Report
DASNY MWBE-QR
Quarterly during contract
MWBE Payment Certification
DASNY MWBE-PC
With each payment request
GFE Documentation
GFE Package
At bid (if goal not met)
ConDocs generates the GFE package and supports quarterly MWBE compliance reporting for DASNY contracts.
Reporting requirements
ReportFormFrequencyDue dateConDocs
Quarterly MWBE Compliance ReportMWBE-QRQuarterly15th after quarter endAuto-generated
MWBE Payment CertificationMWBE-PCPer paymentWith payment requestComing soon
Port Authority of New York & New Jersey
MWBE & DBE compliance for bi-state transportation infrastructure contracts
Bi-state authorityFederally funded
Program
MWBE / DBE / SDVOB
Threshold
$500K+
Goal range
20โ€“30%
GFE required
Yes โ€” at bid
Overview
Goals & thresholds
GFE requirements
Required forms
Legal basis
Reporting
Program overview

The Port Authority operates JFK, LaGuardia, and Newark airports, the George Washington Bridge, Lincoln and Holland Tunnels, the Bayonne Bridge, the PATH train, and the Port of New York/New Jersey. Contracts are subject to both NY and NJ MWBE requirements as well as federal DBE requirements where federal funds are involved.

The Port Authority maintains its own certified firm directory, published as a bulk Excel download. ConDocs imports this data monthly. The PA's MWBE program covers MBE, WBE, DBE, SDVOB, and SBE firms from both New York and New Jersey.

ConDocs imports Port Authority certified firm data monthly from their bulk Excel directory. PA-certified firms are tagged in the ConDocs directory.
Participation goals by contract type
Contract typeCert typesTypical goalThreshold
Construction โ€” Airport capitalMBEWBEDBE20โ€“30%$500,000+
Construction โ€” Bridge/tunnelMBEWBE20โ€“25%$500,000+
Construction โ€” PATH/railDBEACDBE15โ€“25%$500,000+
Professional servicesMBEWBE15โ€“20%$100,000+
Concessions โ€” AirportsACDBE25โ€“30%All concessions
Good Faith Effort requirements
1
Search PA certified firm directory
Search the Port Authority's certified firm Excel directory for MBE, WBE, DBE, and SDVOB firms in relevant trade categories from both NY and NJ.
2
Written bid invitations
Send written solicitations to identified firms at least 10 business days before bid date. Maintain email delivery logs or fax confirmations.
3
Follow-up by phone
Call all firms that received written solicitations. Document name of person contacted, date, time, and outcome of each call.
4
Submit PA Participation Plan
Complete the PA's MWBE/DBE Participation Plan form and submit with bid. If goal not met, attach full GFE documentation package.
Required forms
MWBE/DBE Participation Plan
PA-PP
At bid submission
Monthly MWBE Payment Report
PA-MPR
Monthly during contract
GFE Documentation Package
GFE Package
At bid (if goal not met)
Subcontractor Payment Certification
PA-SPC
With each payment request
ConDocs generates the GFE package for Port Authority projects. Monthly payment reporting support is coming soon.
Reporting requirements
ReportFormFrequencyDue dateConDocs
Monthly MWBE Payment ReportPA-MPRMonthly10th of following monthComing soon
MWBE Participation PlanPA-PPAt bidWith bid submissionGFE package
Annual DBE Report (FAA)FAA AnnualAnnualDecember 1Coming soon