Travel rebooking during disruptions, agent to agent
How a traveler's agent could rebook or claim a refund with an airline's agent after a cancellation, under the US DOT refund rule and Canada's APPR.
When a flight is cancelled, thousands of travelers need the same scarce thing at once: a seat on the next flight out. Airline apps, airport lines and phone queues all fill up. A traveler’s agent could negotiate the rebooking directly with the airline’s agent, but the choice it makes has legal weight. Accepting one option can give up a refund, so the agent needs precise instructions.
How it works today
The airline pushes a notification with an automatic rebooking or a link to choose another flight. Travelers who want something else wait in line, call, or use the app’s options. Agents acting for travelers today work through the same app, site or phone line.
United States. DOT’s refund rule (14 CFR Part 260), with a compliance date of 28 October 2024, sets when a refund is owed:
- A flight is significantly changed if departure moves three hours or more earlier, or arrival three hours or more later, on a domestic itinerary (six hours for international), or if the passenger is moved to a different airport, given more connections, or downgraded. Changes that affect accessibility for passengers with disabilities also count.
- For a cancelled or significantly changed flight, the refund is owed if the passenger chooses not to fly the changed flight, not to accept rebooking, and not to accept a voucher, credit or other compensation.
- Refunds must be prompt: 7 business days for credit card purchases, 20 calendar days for other payment forms.
- A carrier may not treat a passenger as having accepted a credit or voucher in place of a refund unless the passenger affirmatively agrees (section 260.7).
On 7 July 2026 DOT extended, to 7 July 2027, its enforcement discretion for flights that are only renumbered without a significant change, while a new rulemaking reconsiders the definition of a cancelled flight. Other refund obligations are unaffected. DOT withdrew its advance notice on passenger compensation for controllable disruptions on 17 November 2025. What airlines promise beyond the rule, such as free rebooking and meal vouchers for controllable delays, appears on DOT’s Airline Customer Service Dashboard as voluntary commitments.
Canada. The Air Passenger Protection Regulations (SOR/2019-150) sort disruptions into three categories: outside the carrier’s control, within its control but required for safety, and within its control. The category sets the carrier’s duties. Rebooking is owed in all three, with the strongest duties for disruptions within the carrier’s control, including rebooking on other airlines when its own network cannot get the passenger out within set windows. If the rebooking does not meet the passenger’s needs, a refund is owed. For delays within the carrier’s control and not required for safety, compensation depends on arrival delay: $400, $700 or $1,000 from large carriers, and $125, $250 or $500 from small carriers, for delays of three to six hours, six to nine hours, and nine hours or more. Passengers have one year to claim, and the carrier has 30 days to respond. Draft amendments that would presume compensation is owed unless the carrier shows an exceptional circumstance were published in Canada Gazette Part I on 21 December 2024. As of 2026-09-26 we found no final version.
Industry standards. IATA’s New Distribution Capability (NDC) is an XML standard for airline offers and orders, and ONE Order replaces separate booking and ticket records with a single customer order. These define the airline’s side of the data. Neither defines how a traveler’s agent talks to the airline.
The agent-to-agent version
Illustrative. The traveler’s flight from Toronto to Vancouver is cancelled. Their instructions: arrive by 22:00 local time, partner airlines are fine, no overnight connections, never accept a travel credit, and if nothing works, take the refund.
- The agent receives the cancellation by push notification and opens a task with the airline’s agent.
- It sends the order ID, the cancelled segment and the traveler’s constraints.
- The airline’s agent returns the options it can confirm, each with a hold expiry.
- The agent accepts one that fits, or declines all and requests the refund.
- The airline’s agent confirms the new itinerary or the refund, with the disruption category it assigned.
Step 2:
{
"jsonrpc": "2.0",
"id": "req-irop-1",
"method": "SendMessage",
"params": {
"message": {
"messageId": "msg-irop-01",
"role": "ROLE_USER",
"parts": [
{ "text": "Flight cancelled. Rebook within these constraints or refund. Do not offer travel credit." },
{
"data": {
"orderId": "ORD-8KQ2ZP",
"cancelledSegment": { "flight": "XY123", "date": "2026-10-03", "from": "YYZ", "to": "YVR" },
"constraints": {
"arriveBy": "2026-10-03T22:00:00-07:00",
"allowPartnerCarriers": true,
"allowOvernightConnection": false,
"cabinNoLowerThan": "economy"
},
"ifNoOption": "refund",
"acceptTravelCredit": false
},
"mediaType": "application/json"
}
]
}
}
}
What has to be true
Identity. A booking reference and last name is what airline sites accept today. For an agent that can change or cancel an itinerary, the airline needs stronger proof of who the traveler is and which agent acts for them, such as a loyalty-account authorization.
Authority. This is where the rules bite. Under the DOT rule, accepting rebooking or compensation can end the refund right, and a credit needs the passenger’s affirmative agreement. The traveler’s authorization must say which alternatives the agent may accept, and it should never allow accepting a credit in place of a refund unless the traveler said so for this trip.
Record. Offer times, hold expiries, what was accepted and when, and the disruption category the carrier assigned. Those facts decide whether an APPR compensation claim or a DOT complaint succeeds.
Queue fairness. During irregular operations, seats go to whoever confirms first. Airlines will set their own rules for agent requests, and travelers need to know whether their agent competes on equal terms.
Where Emissar fits
- Mandate (spec in progress): the traveler’s rebooking limits and the “no credit” rule as a scoped credential the airline can check.
- Ledger (spec in progress): a signed record of offers, acceptances and the stated disruption reason.
- Verify (in development): lets the airline check the calling agent before touching a booking.
- Front Door (open to design partners): an agent endpoint in front of the airline’s existing rebooking systems.
- Handoff (in development): special assistance and accessibility needs go to a person with the full context.
- Settle (planned): refunds, checked against the order.
Open questions
- During a mass cancellation, should agent requests queue with app users, or be rate limited separately?
- How should an airline expose NDC or ONE Order data through an agent task without every traveler’s agent needing airline-specific code?
- If Canada finalizes the 2024 draft APPR amendments, how will the carrier’s disruption category and the exceptional-circumstance explanation be delivered in structured form?
- When an agent books a partner flight under its traveler’s constraints and the partner also disrupts it, which carrier’s agent owns the task?
Questions
- If an agent accepts a rebooking, does the traveler lose the refund?
- Under the US DOT rule, a refund for a cancelled or significantly changed flight is owed when the passenger does not fly the changed flight, does not accept rebooking, and does not accept a voucher or other compensation. So yes, accepting an alternative can end the refund right. That is why the traveler's instructions to the agent need to say which alternatives it may accept.
- Does the US require airlines to pay cash compensation for delays?
- No. DOT withdrew its advance notice on compensation for controllable disruptions on 17 November 2025. The airlines' commitments on the DOT dashboard, such as rebooking and meals, are voluntary, and none of the listed carriers commits to cash compensation.
Sources
- 14 CFR Part 260: Refunds for Airline Fare and Ancillary Service Fees (eCFR) (accessed )
- US DOT: Refunds and Other Consumer Protections, final rule (89 FR 32760, 26 April 2024) (accessed )
- US DOT: Airline Refunds and Other Consumer Protections, extension of enforcement discretion (7 July 2026) (accessed )
- US DOT: Airline Passenger Rights; Withdrawal (17 November 2025) (accessed )
- US DOT: Airline Customer Service Dashboard (accessed )
- Air Passenger Protection Regulations, SOR/2019-150 (Justice Laws) (accessed )
- Canada Gazette, Part I: Regulations Amending the Air Passenger Protection Regulations (21 December 2024) (accessed )
- IATA: New Distribution Capability (NDC) (accessed )
- IATA: ONE Order (accessed )
- A2A Protocol Specification (accessed )