The U.S. Department of Transportation (DOT) recently announced the issuance of a final rule[1], effective May 26, 2026, requiring covered air carriers[2] to prepare and submit a one-page passenger rights summary (a “Passenger Rights Summary”) addressing key disruption-related topics. The final rule implements Section 429 of the FAA Reauthorization Act of 2018.

Under the rule, covered air carriers must create and post a one-page document summarizing passenger rights in the following areas:

  • Compensation with respect to rebooking options, refunds, meals, and lodging in instances of (i) flight delays of various lengths, (ii) flight diversions, and (iii) flight cancellations.
  • Compensation for mishandled baggage (including delayed, damaged, pilfered, or lost baggage).
  • Voluntary relinquishment of a ticketed seat due to overbooking or priority of other passengers.
  • Involuntary denial of boarding and forced removal for whatever reason, including for safety and security reasons.

The DOT additionally recommends covered air carriers prepare the Passenger Rights Summary as a “concise, user-friendly” document and consider making the one-pager available in a location that is highly visible to the general public.

Although the final rule becomes effective May 26, 2026, covered air carriers will not be required to submit the Passenger Rights Summary until the DOT publishes a subsequent notice in the Federal Register announcing Office of Management and Budget (OMB) approval of the information collection established by the rule. After submission, covered air carriers must prominently display the Passenger Rights Summary on their websites within 90 days.


[1] USCODE-2024-title49-subtitleVII-partA-subpartii-chap417-subchapI-sec41727.pdf

[2] Section 401 of the 2018 FAA Act defines the term “covered air carrier” for its purposes as an air carrier or foreign air carrier as those terms are defined by 49 U.S.C. 40102.

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Photo of Amy Karnikian Amy Karnikian

Amy Karnikian is a seasoned aviation attorney and serves as senior counsel in the Aviation Group. Amy’s practice focuses on business and commercial aircraft, general aviation transactions, aviation regulatory compliance, and advising clients on emerging technologies such as unmanned aircraft systems (Drone/UAS) and…

Amy Karnikian is a seasoned aviation attorney and serves as senior counsel in the Aviation Group. Amy’s practice focuses on business and commercial aircraft, general aviation transactions, aviation regulatory compliance, and advising clients on emerging technologies such as unmanned aircraft systems (Drone/UAS) and electric vertical takeoff and landing (eVTOL) aircraft.

She advises high-net-worth individuals, Fortune 500 corporate flight departments, and airlines on operating structure matters such as leasing, timeshare and fractional ownership agreements, and the sale and purchase of aircraft. Amy also advises investors on the regulatory impact of investment in aviation-related businesses or those that own and/or operate aircraft.

Amy previously served as senior associate at a major law firm, where her practice focused on commercial aircraft sales, leasing, finance, restructuring, and a variety of other cross-border transactions. Her clientele included aircraft lessors, financial institutions, and airlines. During her tenure at that firm, she led the negotiations of high value sale-leaseback and financing transactions spanning various jurisdictions, aircraft maintenance contracts with OEMs and MROs, lease novations in connection with sale and purchase transactions, and various other corporate and transactional matters in the aviation space.

In addition to her work at that firm, Amy spent a year as a secondee at Amazon, where she supported the Global Amazon Air cargo business on a wide range of matters.

Prior to her legal career, she worked for a leading aircraft lessor, where her passion for aviation took root.

Photo of Mary-Caitlin Ray Mary-Caitlin Ray

A former attorney for the Federal Aviation Administration, Mary-Caitlin represents aircraft owners, operators, and manufacturers as well as investors into aviation related businesses, advising on regulatory and transactional matters. Her clients come to her for practical and strategic advice on navigating complex aviation…

A former attorney for the Federal Aviation Administration, Mary-Caitlin represents aircraft owners, operators, and manufacturers as well as investors into aviation related businesses, advising on regulatory and transactional matters. Her clients come to her for practical and strategic advice on navigating complex aviation challenges. She has significant experience advising clients on the impacts of and solutions for emerging technologies in the aviation sector, including uncrewed aircraft systems (UAS or drones) and electric vertical takeoff and landing (eVTOL) aircraft.

Mary-Caitlin’s practice spans the crewed and uncrewed side of the aviation world.

She has advised Fortune 500 flight departments, high net worth individuals, and manufacturers and suppliers on regulatory concerns related to the operation and production of aircraft, including complex issues related to permitted compensation, pilot licensing, operating structures such as dry leasing, timesharing and fractional ownership agreements, and emergency and Letter of Investigation response related to quality escapes and incidents. She also represents clients in the acquisition and sale of business aircraft, including cross-border transactions requiring the export or import of aircraft.

Mary-Caitlin counsels drone and eVTOL manufacturers, operators, and owners on all aspects of FAA regulatory compliance, including the business impacts of the evolving global regulatory framework for emerging aviation technologies. She also advises drone manufacturers and operators developing internal aviation-related corporate policies and best practices.

Mary-Caitlin has significant experience advising investors on the regulatory implications of investment into a wide array of aviation-related businesses, including MROs, manufacturers (including eVTOL manufacturers), and businesses that own and/or operate aircraft.