Alexandria, VA; May 5, 2025 - The American Society of Travel Advisors (ASTA), representing more than 190,000 travel professionals nationwide, formally submitted comments to the U.S. Department of Transportation (DOT) in response to its Request for Information (RFI) on regulatory reform.
ASTA’s recommendations aim to alleviate burdensome regulations affecting small business ticket agents while maintaining transparency and consumer protection in the airline industry.
"The DOT has saddled the nation's travel agencies with providing refunds when airlines experience travel disruptions,” said Zane Kerby ASTA President and CEO. “This misappropriation of responsibility needs to be fixed. Our members shouldn't be forced to cover refunds for flights they didn't cancel."
In its submission, ASTA strongly urged the Department to reevaluate three specific regulatory areas that unduly strain travel advisors, including ticket refund obligations and the disclosures advisors must make both in-person and over the phone.
Eliminate the Ticket Agent Obligation to Issue Consumer Refunds for Canceled or Substantially Changed Flights
ASTA is calling for the repeal of the DOT’s current rule, finalized in April 2024, mandating ticket agents who are the merchant of record issue refunds to consumers for flights canceled or significantly changed by the airline within seven days. This rule requires agents to refund consumers even when they are not in possession of the funds—creating severe cash flow and liability issues, particularly for small businesses.
ASTA emphasized that agents do not control airline funds, lack real-time access to cancellation data, and could be forced to refund customers out-of-pocket. While DOT attempted to mitigate this issue by requiring airlines to "promptly transfer" funds to agents, the regulatory language remains ambiguous and ineffective.
ASTA is advocating for a complete repeal of the requirement as the only equitable solution.
Streamline Offline Ticket Disclosure Requirements as Directed by Congress in the 2024 FAA Reauthorization Act
In alignment with the FAA Reauthorization Act of 2024, ASTA is urging the DOT to modernize and simplify the disclosure requirements for offline airline ticket sales, such as those made over the phone or in person. Currently, advisors must make up to seven separate disclosures during each transaction, a process that is both time-intensive and legally risky.
ASTA supports the Act’s directive that allows disclosures related to airline policies and fees to be made via referral to airline and DOT websites and urges the Department to move forward in short order. This approach strikes a balance between regulatory compliance and practical limitations of offline interactions, offering consumers necessary information without burdening advisors with impractical delivery methods.
Eliminate Outdated and Unnecessary Disclosure Requirements Regarding Aircraft Insecticide and Code Share Flights
ASTA is also advocating for the removal of disclosure mandates related to aircraft disinfection and code share flights. The organization argues that these requirements offer limited consumer benefit while creating excessive compliance obligations.
For insecticide use, disclosures must be made for all flights to 36 listed countries—regardless of whether the flight is actually treated. For code share arrangements, regulations require exhaustive, often duplicative disclosures in every form of communication, including casual inquiries. Any noncompliance, even unintentional, subjects advisors to steep penalties.
“These regulations impose significant costs and risks on small travel businesses with little added value to consumers,” said Peter Lobasso, ASTA’s General Counsel and Senior Vice President of Industry Affairs. “Our members need a fair regulatory environment that acknowledges their important but limited role in the transaction chain and supports their continued ability to serve travelers effectively.”
