A4A SEEKS GUIDANCE ON DISABILITY REPORTING REQUIREMENTS
April 8, 2026
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On March 2, 2026, Airlines for America submitted comments to DOT concerning the usefulness of annual disability-related complaint reports that U.S. and foreign air carriers operating to, from, and within the U.S. are required to submit. Given that U.S. and foreign air carriers are already required to submit annual reports to DOT’s Office of Aviation Consumer Protection, Airlines for America advised against expanding the scope and form of reported data. Airlines for America nevertheless requested regulatory guidance from OACP on the proper categorization of passenger complaints within the existing framework. For instance, since the launch of DOT’s Aviation Complaint, Enforcement, and Reporting System (“ACERS”) in August 2025, those in the aviation industry continue to experience an increasing number of erroneously categorized complaints which impacts the quality of the information reported to DOT. To remedy this issue, Airlines for America and other aviation stakeholders seek clarification from OACP on how regulators plan to categorize complaints submitted by artificial intelligence and/or other autonomous application programs (i.e., computer bots). Specific regulatory guidance from OACP on such matters will be helpful to carriers and regulators alike so that annual DOT disability reports accurately reflect compliance with consumer protection regulations.
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