The Air Carrier Access Act (ACAA) and Digital Accessibility

The Air Carrier Access Act (ACAA) is landmark legislation that prohibits airlines from discriminating against passengers with disabilities. It applies to both domestic and foreign air carriers, and also requires airlines to provide various types of assistance and accommodations to people with disabilities. 

The ACAA has strict requirements for digital accessibility. By meeting those requirements, airlines (and their contractors) can also improve compliance with the Americans with Disabilities Act (ADA). 

Below, we’ll answer some common questions about the ACAA and how it relates to websites, apps, and other digital products.

How does the ACAA protect the rights of air travelers with disabilities?

The ACAA establishes a “Bill of Rights'' for travelers with disabilities and establishes specific rules for air carriers. Airlines and their contractors are legally responsible for fulfilling the act’s requirements, with extremely limited exceptions. For example, airlines would not be required to accommodate a passenger if providing the accommodation could potentially compromise the safety of the flight.

The United States Department of Transportation (DOT)’s Bill of Rights currently consists of the following rights: 

1. The right to be treated with dignity and respect.
2. The right to receive information about services and aircraft capabilities and limitations.
3. The right to receive information in an accessible format.
4. The right to accessible airport facilities.
5. The right to assistance at airports.
6. The right to assistance on the aircraft.
7. The right to travel with an assistive device or service animal.
8. The right to receive seating accommodations.
9. The right to accessible aircraft features.
10. The right to resolution of a disability-related issue. 

It’s important to note that the ACAA’s protections begin before the passenger takes their seat on the aircraft: Airlines must provide passengers with accessible ticketing services and other resources.

Related: What to Know About the DOJ’s New Title II Web Accessibility Rules

Does the ACAA require digital accessibility?

Yes. The ACAA provides the Department of Transportation (DOT) with broad authority to create regulations. The DOT explicitly requires that airlines follow the Web Content Accessibility Guidelines (WCAG) 2.0 Level AA; that requirement became official on December 12, 2015.
Published by the World Wide Web Consortium (W3C), WCAG is an international standard for digital accessibility. Web pages associated with these core air travel services must follow (or conform with) WCAG: 

• Booking or changing a reservation, including all flight amenities. 
• Checking for a flight.
• Accessing a personal travel itinerary.
• Accessing the status of a flight.
• Accessing a personal frequent flyer account.
• Accessing flight schedules.
• Accessing carrier contact information.

Air carriers may provide an “accessible alternative" to their primary web content if the alternative meets WCAG — but the alternative must provide the same functionality and information as the original page. 

Does the ACAA apply to digital kiosks?

Yes. All airlines that exceed 10,000 passengers per year must ensure that 25% of their digital kiosks meet the ACAA’s accessibility standards. 25% of each “cluster" of kiosks within each airport must be accessible.

Additionally, if your organization operates digital kiosks, you must:

• Ensure that any passenger with a disability who requests an accessible automated kiosk is given access to one. 
• Ensure that accessible kiosks are “visually and tactilely identifiable" as accessible (they must have appropriate signage). 
• Ensure that accessible kiosks are maintained in working condition. 

Digital kiosks are also subject to Title III of the ADA. That includes kiosks operated by ticket agents, provided that those agents do not qualify as small businesses.

The bottom line: If your organization operates kiosks, they must be accessible — and if they’re not reasonably accessible, you’re taking a significant risk (and missing an opportunity to connect with customers). 

Related: Accessible Kiosks: The What, Why, and How

How can I build a strategy for ACAA accessibility compliance?

For airlines, airports, and travel booking websites, digital accessibility is an urgent priority. You should work closely with your accessibility partner to develop a long-term, self-sustainable strategy for ACAA and ADA Title III compliance. 

That strategy should include:

• Regularly testing content for accessibility issues. Content should be tested frequently — ideally, whenever it is updated — using the latest version of WCAG. 
• Publishing an accessibility statement. An accessibility statement outlines your commitment to passengers with disabilities and explains your current level of conformance. 
• Training employees. Workers must understand the four principles of WCAG and the importance of digital accessibility.

If you’re ready to embrace digital accessibility — and enjoy the enormous business benefits of an accessible website — we’re here to help. Send us a message to connect with an accessibility expert or get started with a free WCAG Level A/AA website analysis.