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Refund duties reached travel agencies through a single paragraph, written twice in the same year. Paragraph (l) of 14 CFR 399.80 lists the refund failures the Department of Transportation treats as unfair or deceptive when a ticket agent commits them. The Department revised it on April 26, 2024, in Refunds and Other Consumer Protections.¹ It revised the same paragraph again on August 12, 2024, to conform the regulation to the FAA Reauthorization Act of 2024.² The text in force is the second version, and the citation line at the end of the section says so.

What the paragraph asks of an agent that is the merchant of record

The first sentence of paragraph (l) turns on a role. It reaches a failure to make a prompt refund of airfare, including any taxes and ancillary fees, on request, where a flight is canceled or significantly delayed or changed.³ The consumer must have chosen not to travel and not to accept compensation instead, and the sentence closes "when the ticket agent is the merchant of record."³ A second sentence carries a further refund duty, for consumers on the same reservation as an individual with a disability who does not want to continue travel.³ That second duty is not framed by the merchant-of-record role.³

Promptness is defined rather than left to the agent. A prompt refund is one made within 7 business days for credit card purchases, counted from the ticket agent receiving information from a carrier.³ For other forms of purchase the paragraph allows 20 calendar days from the refund becoming due.³ Refunds go back in the original form of payment, unless the consumer agrees to a cash equivalent.³

The same paragraph governs the agency's own fee

A ticket agent may retain a service fee charged when issuing the original ticket, to the extent that service is "for more than processing payment for a flight that the consumer found."³ Two requirements follow in the next sentence. The fee must be charged on a per-passenger basis. Its existence, its amount, and its non-refundable nature where that is the case are "clearly and prominently disclosed to consumers at the time they purchase the airfare."³

Compensation offered in place of a refund carries conditions of its own. Travel credits, vouchers, and other compensation may be offered where they remain valid and redeemable by the consumer for at least 5 years.³ The agent must first inform consumers that they are entitled to a refund if that is the case.³ Material restrictions, conditions, and limitations are then disclosed clearly, including the expiration date.³

A rule can sit in the book and go unenforced

Printed text and enforced obligation move separately. Under the regulations as they stand, a flight given a different flight number from the one active at the time of purchase counts as a canceled flight.⁴ That classification makes the consumer eligible for a prompt refund and the related notifications.⁴ On December 5, 2025, the Department announced that it would not enforce those requirements for renumbered flights, where the passenger is rebooked on the new flight without a significant change or delay.⁴ It extended that discretion on July 7, 2026, until July 7, 2027, while a rulemaking on flight cancellation is pending.⁴

The reverse also happens. The Department published Enhancing Transparency of Airline Ancillary Service Fees on April 30, 2024, and a Fifth Circuit panel stayed it on July 29 of that year.⁵ The full court vacated the rule on February 3, 2026.⁵ The Department removed the rule from the Code of Federal Regulations on July 2, 2026, and restored the standards established in 2011.⁵ In the Department's own account, consumers "have not experienced any changes in the airline ticket purchasing process" as a result of the vacated rule.⁵

Prescribed wording and illustrative wording are different things

Three provisions supply words to a ticket agent, and they supply them in three different ways. Section 258.5(c) says the seller "shall provide the following written notice" and then prints it, under the heading "Notice: Change of Aircraft Required."⁶ That notice runs to three sentences, and all three are text to be reproduced whole.⁶ They cover the change of aircraft, the flight numbers that may appear at the airport, and the details the seller gives on request.⁶

Section 257.5(c) works differently. It fixes a phrase inside a sentence the seller writes. The notice is to state "Operated by" followed by the corporate name of the transporting carrier and any other name in which that service is held out to the public.⁷ The specimen printed after that requirement is a safe harbor, given as a form of statement that will satisfy the paragraph.⁷ Paragraph 257.5(d) sets a minimum for broadcast advertising, calling for at least a generic disclosure statement, offering "Some flights are operated by other airlines." as its example.⁷

The limits of what an editor can settle

Which fares an agency sells, which carriers it books, and whether it is the merchant of record on a given sale are questions for the agency and its counsel. Whether a disclosure satisfies the Department is theirs as well. We do not answer either. Work sent to us is kept in confidence.

The wording is where we work. Where a prescribed notice departs from the section that prints it, the departure is usually a retyped heading or a dropped sentence. The citation line at the end of a regulation carries its amendment dates, which is what a page written to an earlier version has to be read against. A checkout page naming a service fee is read for three things: an amount, a basis, and whether the fee is refundable.