DOT PAUSES ENFORCEMENT OF CERTAIN REFUND OBLIGATIONS
January 5, 2026
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On December 5, 2025, the U.S. Department of Transportation issued a notice of enforcement discretion regarding the Airline Refunds and Other Consumer Protections rule. In short, the Department will not enforce the refund requirements in 14 C.F.R. 260.6, 14 C.F.R. 260.9 and 14 C.F.R. 399.80(l) for cancelled flights when flights are renumbered, so long as passengers are rebooked on flights under a new flight number. While DOT’s current refund regulations automatically classify flight number changes as flight cancellations making passengers eligible for a refund, DOT paused enforcement of such refund requirements until June 30, 2026. To be clear, the Department’s notice of enforcement discretion does not affect the enforcement of ticket refund or notification obligations for any other situations. This move comes after several U.S. air carriers and trade associations urged the Department to reconsider the current definition of a cancelled flight. In correspondence to DOT, Alaska, American, and Airlines for America reasoned that the current regulatory definition is overly broad and that flight number changes are made for many reasons (e.g., commercial concerns, operational flexibility, and FAA safety-related compliance) without adversely impacting passengers.
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