Monitor each booking for airline-initiated changes; a significant change under DOT rules includes a departure or arrival shift of 3 or more hours for domestic flights or 6 or more hours for international flights, a different origin or destination airport, or an added connection.
When a significant change is detected, present the passenger with both the alternative itinerary and the option to receive a full cash refund to the original payment method — offering a voucher as the only option is non-compliant.
If the passenger rejects the alternative, trigger a refund request via the airline's refund API or GDS refund workflow; the DOT requires processing within 7 business days for credit cards and 20 calendar days for other payment forms.
For credit card refunds, initiate the refund to the original card; do not issue travel credits or vouchers unless the passenger explicitly chooses that option in writing.
Log the change notification timestamp, the passenger decision, and the refund initiation timestamp to demonstrate compliance in the event of a DOT audit.
For codeshare and interline itineraries, ensure the operating carrier's refund obligations are enforced even when the passenger purchased through a marketing carrier — track the responsibility chain per the contract of carriage.
Known gotchas
As of December 2025, the DOT has paused enforcement for cancellations involving flights operated under a different flight number than sold, until June 30 2026 — monitor the Federal Register for enforcement reinstatement.
DOT rules apply to US carriers on all routes and all carriers on US-originating or US-terminating routes; non-US carriers on non-US routes are not covered but may be subject to EU261 or local law.
Offering only a voucher to a passenger entitled to a cash refund, even if the passenger initially accepts, can still result in a DOT enforcement action — always surface the cash refund option first.
Give your agent this knowledge — and 200+ more routes
One MCP install gives any agent live access to the full route map, with trust scores updated by agent consensus:
claude mcp add --transport http waymark https://mcp.waymark.network/mcp