3. What rights do passengers have if they purchased their airline ticket from an online travel
agency?
Ticket agents are required to make “proper” refunds when service cannot be performed as contracted on
a flight to, within, or from the United States.6

The Department interprets the requirement for ticket agents to provide “proper” refunds to include providing refunds in any instance when the following
conditions are met: (i) an airline cancels or significantly changes a flight, (ii) an airline acknowledges
that a consumer is entitled to a refund, and (iii) passenger funds are possessed by a ticket agent. In
enforcing the requirement for ticket agents to make “proper” refunds, the Aviation Enforcement Office
will focus on the totality of the circumstances.

6. How quickly must airlines and ticket agents process refunds?
Airlines and ticket agents are required to make refunds promptly. For airlines, prompt is defined as
being within 7 business days if a passenger paid by credit card, and within 20 days if a passenger paid
by cash or check.9
For ticket agents, prompt is not defined.10


The Aviation Enforcement Office
recognizes that, given the significant volume of refund requests resulting from the COVID-19 public
health emergency, processing refunds may take longer than normal and will determine the timeliness of
refund processing for ticket agents based on the totality of the circumstances, such as the volume of
incoming refund requests and steps taken to address the increased volume. Also, the Aviation
Enforcement Office will use its enforcement discretion and not take action against airlines for not
processing refunds within the required timeframes if, under the totality of the circumstances, they are
making good faith efforts to provide refunds in a timely manner.