Accessibility laws · United States (aviation)

Air Carrier Access Act (ACAA)

Fly people to, from, or inside the United States and your website has been under a named WCAG rule since 2015. Not the ADA. A separate statute, a separate regulator, and a regulation that says the version out loud. The Department of Transportation wrote it, it lives at 14 CFR 382.43, and it requires WCAG 2.0 Level AA. Core booking pages had to conform by December 12, 2015, and the rest of the primary site by December 12, 2016. It reaches you if you operate at least one aircraft with a designed seating capacity of more than 60 passengers, and a foreign carrier is caught on the same terms as a US one.

WCAG version the rule names: 2.0 AA
Designed seats that trigger it: 61+
Whole-site deadline: Dec 2016
Regulator, not the DOJ: DOT

What the law is

The Air Carrier Access Act of 1986 stops airlines discriminating against passengers on the basis of disability, and the regulation carrying it out is 14 CFR Part 382. That part covers a lot more than the web. Boarding assistance, wheelchair stowage, service animals, seating, lavatories, and the training airline staff get are all in there. One section handles the website. Section 382.43 is titled around information and reservation services, and paragraph (c) is where the WCAG requirement sits. Two things make it unusual on this site. It names a WCAG version rather than leaving courts to fill the gap, and its regulator is the DOT rather than the Department of Justice, which means the complaint you would file and the office that would investigate are both different from every other US page here.

The trigger is the aircraft, not the company. You are inside paragraph (c) if you are a US or foreign air carrier operating at least one aircraft with a designed seating capacity of more than 60 passengers, and you own or control a primary website marketing passenger air transportation to the general public in the United States. The regulation lists three signs of such a site. The content can be viewed in English, it advertises or sells flights operating to, from, or within the United States, and it displays fares in US dollars. Sell nothing but domestic flights inside another country and this rule is not yours.

Now the boundary, because it is the part people get wrong. The section binds carriers. An online travel agent is not a carrier, and neither is a metasearch site or a corporate booking tool. Part 382 says so structurally rather than by exception. An indirect carrier, defined as somebody who sells air transportation to the public without operating the aircraft and without being an authorized agent of a carrier, is subject only to sections 382.1 through 382.15, and the website rule at 382.43 sits outside that range. So a travel site can be selling the exact same seat on the exact same flight and be outside this regulation entirely. It may still owe the ADA. It does not owe 14 CFR 382.43.

Then there is the sentence that makes this page worth writing. Paragraph (c)(2) requires the carrier to test its primary website in consultation with people with disabilities, or with members of disability organizations, who use or want to use airline websites to research or book travel. It sets the coverage too. Between them, the people testing have to be able to give feedback on usability by individuals with visual, auditory, tactile, and cognitive disabilities. That is a US federal regulator writing user testing into the definition of a compliant website. No other regime on this site says the standard alone is not enough and then names the people who have to be asked.

This applies to you if…

You are a US air carrier, in which case Part 382 applies to all your operations and all your aircraft, wherever in the world they fly. There is no domestic carve-out and no foreign-route carve-out for a US carrier.
You are a foreign carrier operating flights that begin or end at a US airport. The part reaches those flights and the aircraft used for them, and nothing else. A Frankfurt to Prague leg on the same ticket is outside it.
You operate at least one aircraft with a designed seating capacity of more than 60 passengers and you run a primary website selling air travel to the American public. One aircraft over the threshold pulls the whole website in, so a mixed fleet does not get you a smaller duty.
You build or run an airline's booking engine, check-in flow, or mobile web experience under contract. The duty belongs to the carrier and it reaches you through the contract, because no airline meets WCAG 2.0 Level AA on a checkout you control without your help.
You sell air travel without operating aircraft, in which case this rule is probably not yours. Check what this page says about indirect carriers before you relax, then go and read the ADA page, because something else likely is.

What it technically requires

The public-facing pages of your primary website have to conform to all Success Criteria and all Conformance Requirements of WCAG 2.0 for Level AA, named in the regulation as the W3C Recommendation of 11 December 2008. That is the whole standard rather than a selection from it, and the conformance requirements are part of the citation, so a page that passes every criterion and fails on complete processes still fails the rule.
Seven services had the earlier deadline, and the list is closed. Booking or changing a reservation including all flight amenities, checking in for a flight, reaching a personal travel itinerary, checking flight status, reaching a personal frequent flyer account, reaching flight schedules, and reaching carrier contact information. All seven had to conform by December 12, 2015. Every remaining page of the primary website had to conform by December 12, 2016. Both dates are long gone, which means there is no runway left and no phase-in to plan around.
Your website has to be tested in consultation with people with disabilities before those dates, covering visual, auditory, tactile, and cognitive disabilities between them. The regulation gives the reason in its own words, which is to make sure the site is usable by individuals with disabilities. Conformance was never meant to be the whole test here, and the regulator said so in the rule itself.
A conforming alternate version is allowed, and only just. You may use one where making the public-facing page itself meet Level AA would be an undue burden or would fundamentally alter the information or functionality of that page. WCAG's own allowance carries no such test. The DOT added one, so a separate accessible version built for convenience rather than necessity does not satisfy this rule.
Two more website duties sit just outside the WCAG paragraph and both have their own dates. By December 12, 2015 the site needed a way for people with disabilities to request accommodation for future flights, naming wheelchair assistance, seating accommodation, escort assistance for a passenger who is blind or has low vision, and stowage of an assistive device. By December 12, 2016 it needed a disclaimer that fires when somebody follows a link out to an external site or third-party software, telling them the destination may not follow the same accessibility policies. No other regime on this site asks for that second one.
Your reservation agents, your contractors, and your website all have to tell a passenger with a disability how to reach a Complaints Resolution Official when they raise a disability concern. That is a separate duty in section 382.151, it applies to any carrier using aircraft with 19 or more passenger seats, and it is a website requirement hiding outside the website section.

All roads lead to WCAG. Start with Level AA, the legal standard or the full 55-rule library. Unfamiliar term along the way? The A to Z glossary decodes it.

How it is enforced

Complaints go to the Department of Transportation, and there is a clock on them. Anyone who believes a carrier has broken any provision of Part 382 can seek assistance or file an informal complaint with the DOT's Aviation Consumer Protection Division no later than six months after the date of the incident, or file a formal complaint under the Department's own procedural rules inside the same six months. Six months is short. A passenger who spends a fortnight arguing with customer service and then waits to see whether anything changes can lose the route without ever hearing that it existed.

Before that, there is a person inside the airline whose job is to fix it on the spot. A carrier operating aircraft with 19 or more seats has to designate one or more Complaints Resolution Officials, and a CRO has authority to overrule any other member of staff, with one exception for a pilot in command making a safety decision. Where a CRO agrees a violation happened, they owe the passenger a written statement of the facts and what the carrier will do. Where they disagree, they owe a written statement of why. Either way the statement has to tell the passenger about their right to pursue DOT enforcement, in person at the airport where possible and within 30 calendar days otherwise.

Written complaints run on their own timetable. A carrier has 30 days to make a dispositive written response, and the response has to specifically admit or deny that a violation occurred rather than express regret and move on. Carriers operating at least one aircraft with more than 60 designed seats also categorize every disability complaint they receive, keep the records for three years, and file an annual report with the DOT by the last Monday in January. Note that the reporting threshold and the website threshold are the same 60 seats. If the web rule reaches you, so does the reporting.

One honest limit on this page. We have not researched whether a passenger can sue a carrier directly under the ACAA, and that question has its own body of federal case law. What the regulation itself sets out is the DOT route, so that is what this page describes and nothing more. Ask a lawyer about the rest.

Key dates

May 13, 2009General compliance date for 14 CFR Part 382
Nov 12, 2013The rule adding the WCAG 2.0 AA website requirement is published
Dec 12, 2015Deadline: the seven core booking and travel pages, plus the accommodation request mechanism
Dec 12, 2016Deadline: every remaining page of the primary website, plus the external link disclaimer
Dec 12, 2022Deadline: at least 25 percent of automated airport kiosks in each airport location meet the design specifications

What to do about it

Every obligation on this page is measured against WCAG, so the first step is knowing where you actually stand. Run the free 10-page scan for the machine-checkable slice. For the rest, we review the key journeys with an expert and a real blind screen-reader user, then attach a screenshot and a fix to every finding. $499, 5 business days.

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Orientation only, current as of August 2026. Not legal advice, and no attorney-client relationship is created. For your specific situation, talk to your own lawyer.