Some Thoughts on the Air Carrier Access Act

June 12, 2018

Silhouette of person in wheelchair moving through airport terminal. Text says "Air Carrier Access Act. Disability Rights in Air Travel."


In November 2013, the Department of Transportation issued new rules under the Air Carrier Access Act of 1986, requiring airline websites and ticket kiosks to be accessible to people with disabilities.

Regarding websites, the new regulations require that all parts of the website available to the public must conform to the latest web accessibility guidelines (WCAG 2.0, Level AA). Airlines have a limited time to comply, and they must consult with people with disabilities in the process of modifying their websites to make them accessible. Notably, the rules do not apply to external companies (such as Expedia or Orbits) that sell airline tickets and packages with other travel services unrelated to the airline, such as hotels and rental cars. All providers, however, must give “website only” discounts to people that call to make a reservation because they are unable to use the website due to a disability. Finally, the regulations require airlines to make available an online request form to request flight accommodations related to a disability, such as seating with enough space to accommodate a service animal.

When it comes to kiosks, the 2013 rules require that 25 percent of kiosks in each cluster at an airport be accessible and that accessible kiosks provide the same services as other kiosks.

The Importance of Website Accessibility

For me, air travel is very important because I am very mobile and independent. I have booked flights for vacations, conferences and school. I even booked multiple trips to do research on my undergraduate senior thesis last year. I live alone, and therefore often do not have someone to help me. But even if I did, it is frustrating to be forced to ask for help with tasks that I am capable of doing myself. Phone reservations are also not a solution to inaccessible websites. First, wait times are a nightmare. Second, it is difficult to make trade-offs between different times, durations, airports and prices when someone is waiting for you to make up your mind on the other end of the line. Additionally, not being able to use airline websites can have implications beyond flying. My job as a research assistant sometimes requires making travel arrangements for my supervisors. Inaccessible websites would make it more difficult to do my job, even though I am otherwise competent to perform all of the position’s requirements.

One important aspect of the rule is that, as mentioned above, it requires airlines to consult with people with disabilities to ensure their websites are accessible. One danger with only requiring specific technical guidelines is that there could be cases when the website follows all the specific guidance, but still has usability issues for people with disabilities. This is likely to happen because screen readers and web-based technology change so quickly. If only the WCAG guidelines were required, with no consultation, some people may still be unable to use the website, which would make the rule useless to them. The consultation requirement, then, ensures that the websites are accessible in practice, not just in theory. It makes the regulations practical for people, instead of providing a technical checklist that determines compliance regardless of people’s actual experience using the site.


The rule ensuring that at least one kiosk at each airport location is accessible has different implications. For me, it is not as important as website accessibility because it does not have as many negative consequences as inaccessible websites (see above). It is possible to avoid using the kiosks completely. On the other hand, it is almost impossible (or at least extremely impracticable today) to choose a flight without a website because phone reservations do not allow you to view multiple options in one screen, which makes making trade-offs difficult in situations where there are a lot of options. Since I am extremely paranoid when I travel, I usually go to the airport with everything ready and avoid the kiosk. Even if I don’t, airport layouts are so different that I am going to have to request assistance getting around anyway, which means the ability to use the kiosks will not give me too much more independence in the process as a whole.

There are three major caveats to this, however. First, every traveler is different. Kiosk accessibility may not be as important to me personally due to my travel experiences, but it may be extremely important to other disabled travelers who have different disabilities or skills. Second, since I travel around cities on my own a lot, I have developed pretty good mobility skills. Therefore, in some airports (those that are smaller or more familiar, for example), I can just walk in and ask for directions, then go through the boarding process on my own. In these situations, it is incredibly helpful to have an accessible kiosk because it eliminates the need to ask someone else for help and allows me to go through the check-in process independently. Finally, I often travel with family or friends. If the group needs to use the kiosks for last minute arrangements, it is incredibly rewarding to be able to help my traveling companions with the kiosk task instead of letting them handle everything. This also makes it easier to share tasks (the way most families do) instead of me waiting around (and feeling pretty useless) as my traveling companions take care of everything. I personally dislike situations where there are too many tasks to take care of and not enough people, but I am unable to help due to accessibility issues. Being able to help is especially important in the check in process, where there are multiple things going on, and it helps to divide tasks when possible. Therefore, even when not traveling independently, accessible kiosks (and accessibility in general) allow me to be a contributing member of my family and community, which helps them but is also inherently satisfying, since I know I am capable of performing most tasks with the right accessibility features.


The 2013 regulations are helpful because they provide a minimum standard that makes it possible for people with disabilities to use services. It is very frustrating to encounter situations when I cannot perform a task, not because I am incapable of handling it, but because other people made choices that make it difficult for me to do something that would otherwise be very easy. However, it is important to acknowledge that there are some downsides that must be considered when promoting accessibility through regulation.

From personal experience, bigger companies are often the targets of regulations, while   small businesses are excluded because the cost of making large-scale changes can be prohibitive for them. However, it is precisely these bigger companies that are likely to already have accessible websites even before rules are imposed, because they have more resources to invest in improving their services or because they have a larger customer base to make demands. I have been independently making airline reservations since at least 2011 (two years before these regulations were published), and have never found an inaccessible airline website. Notably, I even successfully navigated websites of third party providers (like Expedia) that are not covered by this rule. Smaller airlines’ websites, however, were often more difficult to use. Therefore, the regulations are addressing companies that (for the most part) have the resources and incentives to make their websites accessible, while not affecting smaller providers. This makes sense – if a company is small, it may have fewer resources to engage in an extensive website redesign process, which makes applying these regulations difficult (the government doesn’t want small companies out of business).

There are reasons to take the cost concern seriously. Not all government websites adhere to the latest accessibility guidelines, which was pointed out in the public comment phase of these regulations. One would assume that government (who issues these regulations to protect people with disabilities) is not deliberately refusing to address problems with its own websites for no reason or because it does not care about people with disabilities. While it would be interesting to study the various obstacles both governments and businesses face when redesigning their websites to make them accessible, personal experience suggests that resources could play a role. Just a few weeks ago, I was trying to use a career-related government website. Part of the site was completely inaccessible, so I emailed the department, described my problem, and asked them to fix it. Unfortunately, they said that due to limited resources and other pressing priorities, they were unable to address my accessibility concerns. Government does not have the same incentives as businesses that may lead some people to think they would not make sites accessible without regulations (desire to make a larger profit and cost cutting, for example). The fact that government (who presumably cares about people with disabilities) has not adopted the latest accessibility guidelines should mean that business concerns about cost should be taken seriously and are not a means for them to avoid making websites accessible because they do not care.

Of course, in every field, there are people who are not concerned and do not want to put in the effort to make websites accessible even when they are able to do so. However, I like to think that this is not usually the case. I have written in a previous post on this blog about how contacting developers with specific problems often leads to issues getting resolved. While that post was about apps, the same idea applies to businesses and websites. I contact developers based on an assumption of good will, at least initially, that most people do not consciously choose to ignore accessibility. Rather, they often do not think of it, especially if they have never worked with people who have disabilities before, and are thinking of other aspects of their site (like aesthetic design or fancy graphics). This means that, when problems are pointed out to them, most developers are happy to address concerns. This may require more work from individual website users who must contact the developer and explain problems, but it may be the only way to address accessibility in situations where companies are not big enough to comply with broader guidelines.


The Air Carrier Access Act regulations are an important step forward in ensuring that all websites – not just those of companies that choose to adopt accessibility features – are accessible. Lack of website accessibility (travel or otherwise) has important, real-life implications for people, both in terms of being able to travel and make choices independently, but also in terms of performing job duties that require extensive internet navigation. People should not be denied access to websites simply because some businesses are more caring or responsive than others. However, there are important challenges and limitations to the rulemaking process, such as the fact that rules are difficult to apply to the websites that arguably need it most. This means that, even when the regulations come into effect, educating businesses and the public, reaching out when encountering problems and continuing to raise awareness about the importance of accessibility will never stop, even if the government requires every single website to be accessible.

About the Air Carrier Access Act

Air Carrier Access Act

Accessibility Consultant | Washington D.C.

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