INDUSTRY AWAITS FURTHER DOT GUIDANCE ON PASSENGER RIGHTS SUMMARY RULE
June 1, 2026
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The U.S. Department of Transportation has not yet published any subsequent notice announcing Office of Management and Budget approval, which is required before U.S. and foreign air carriers can submit their one-page document summarizing passenger rights. By way of background, DOT published a final rule last month requiring covered air carriers to submit and post online a one-page summary of passenger rights (the “Passenger Rights Summary”). This requirement applies to all U.S. and foreign air carriers operating to, from, or within the United States, conducting scheduled passenger service or public charter service with at least one aircraft having a designed seating capacity of thirty (30) or more seats. While the rule’s effective date is May 26, 2026, U.S. and foreign air carriers cannot comply until a valid OMB control number is issued and DOT provides guidance on the submission process. Without specific submission instructions, there is uncertainty as to whether carriers will be required to submit their Passenger Rights Summary on May 26th, or whether the compliance deadline will be delayed. Considering the above, carriers should have a “close to final” draft prepared so they can submit without delay once DOT begins accepting submissions, especially if submissions are required in short order. The Passenger Rights Summary must then be posted on carrier websites within 90 days of submission to DOT.
This Aviation Blog Post is intended to keep readers current on developments in the law. It is not intended to be legal advice. If you have any questions, please contact Evelyn Sahr at 202.659.6622 or esahr@eckertseamans.com; Drew Derco at 202.659.6665 or dderco@eckertseamans.com; Tyler Myers at 202.659.6642 or trmyers@eckertseamans.com, or any other attorney at Eckert Seamans with whom you have been working.
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