Air Carrier Access Act – Web Accessibility Requirements

by Timothy Stephen Springer on January 29th, 2013

U.S. and foreign air carriers operating flights to or selling tickets to the U.S. public are required to ensure that the public-facing content of websites that they own or control conforms to the Web Content Accessibility Guidelines (WCAG) 2.0 Level A and Level AA. If enacted, the proposed requirements will not just apply to U.S. air carriers’ public-facing pages; they will also apply to foreign carriers’ public-facing pages that are used to advertise or sell to the U.S. public for air transportation that begins or ends in the U.S.

In addition, carriers will be held responsible for the activities of their agents, including travel sites such as Orbitz, Expedia and sites that package air travel with vacation packages – such as rewards sites for financial services companies. The NPRM requires carriers to ensure that these agents comply with the same website accessibility requirements that the agencies themselves comply with.

Monitoring and Certification

Specific monitoring and certification requirements are not spelled out in the current SNPRM. Instead the DOT defines a variety of method that carriers could do to certify sites for compliance and monitor agents for compliance. As part of the final rulemaking SSB expects a specific method for defining compliance will be defined.

For carrier sites the Department has considered requiring carriers to post WCAG conformance statements that define the level of compliance of a site against the WCAG conformance requirements. Unlike the Section 508 requirements the WCAG has extensive rule related to making conformance claims that would well serve the Department in this respect. This approach has also been recommended by the European Union as part of the Mandate M 376 requirements. SSB expects that this approach – or a watered down version of it – will make its way into the final requirements.

For agent sites carriers could periodically – once or twice a year – review ticket agent Web sites for accessibility. There is an extensive amount of software that would support this effort – AMP being the best example. Another option would be for carriers to monitor disability complaints received through ticket agents to see if any of the complaints allege that a ticket agent’s Web site is inaccessible.


The timing of the final standards will be developed in the notice of rulemakng. The DOT intends for the Web site accessibility requirements to cover any new or completely redesigned Web site “brought on line” 180 or later after the effective date of the rule. In addition, within a year after the effective date of the rule specific pages on existing sites would need to be made compliant or provide a valid alternative. This would include pages associated with:

  • Booking or changing a reservation,
  • Flight check-in,
  • Accessing a personal travel itinerary,
  • Frequent flyer account,
  • Flight status or schedules, and
  • Carrier contact information.

Finally all pages on a carrier’s primary site would have to conform within two years from the final rule’s effective date.

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