I read various reports that NZ is trying to evade local rules and trying to implement some rules in their own CoC regarding refunds - specifically their own rule that states that if it is circumstances beyond their control (which COVID-19 is obviously) that they can use their own discretion to either choose a cash refund or a credit.
However, those rules are in direct contradiction to US DOT and EU regulations.
My question is this - if a flight takes off at a US point of departure is the ticket subject to US DOT rules or are the rules based on the domicile of the airline (i.e. in this case New Zealand)? I am assuming the rule applies based on the point of departure. In my case it's LAX so US DOT rules will apply. If this is the case Air New Zealand will face US DOT enforcement actions with regard to denying refunds and their ability to service US markets can be adversely affected if they don't comply.
This has just been released by the US DOT to be clear - Airlines are mandated to give refunds in cash not vouchers:
https://www.cnbc.com/2020/04/03/coro...-are-axed.html