Originally Posted by Often1

Not funny. The Rules themselves expressly require pax compliance with a carrier's ticketing policies and "usual" practices. Quoted below is the exact text from the Code of Federal Regulations rather than a conversational summary of what some DOT media person thought the rules say.

This thing has been debated over and over and over and over again. DOT has the absolute authority to amend its own rules. All it needs to do is publish a proposed amendment for public comment, consider the comments -- presumably the carriers object -- and then amend the rule. But, DOT hasn't done this.

That is simply because in air carrier world, dating back to the Wright Brothers (well maybe not quite), you either have a ticket or you don't. It's the only constant."

But under the regulation you don't need a ticket for compensation you need
Confirmed reserved space

"Confirmed reserved space means space on a specific date and on a specific flight and class of service of a carrier which has been requested by a passenger, including a passenger with a “zero fare ticket,” and which the carrier or its agent has verified, by appropriate notation on the ticket or in any other manner provided therefore by the carrier, as being reserved for the accommodation of the passenger.


The regulation says that once you have that notation you are covered.

§ 250.5
Amount of denied boarding compensation for passengers denied boarding involuntarily.
(a) Subject to the exceptions provided in § 250.6, a carrier to whom this part applies as described in § 250.2 shall pay compensation in interstate air transportation to passengers who are denied boarding involuntarily from an oversold flight as follows

the language you describe which is in the exceptions clearly cannot over ride the specific entitlement. No airline ticketing requirement can override the specific regulation

From the United contract of carriage
"UA requires ticketing at the time of reservation"

and . "Ticket means the record of agreement"

So the reservation is the ticket is the agreement