[Federal Register Volume 91, Number 3 (Tuesday, January 6, 2026)]
[Notices]
[Pages 385-388]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2025-24282]


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DEPARTMENT OF TRANSPORTATION

Office of the Secretary

[Docket No. DOT-OST-2025-2514]
RIN 2105-ZA20


Notice Regarding Investigatory and Enforcement Policies and 
Procedures of the Office of Aviation Consumer Protection

AGENCY: Office of the Secretary (OST), Department of Transportation 
(Department or DOT).

ACTION: Notice of proposed guidance.

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SUMMARY: The U.S. Department of Transportation is proposing to revise

[[Page 386]]

and update the investigatory and enforcement policies and practices of 
its Office of Aviation Consumer Protection (OACP), including the 
sanctions brought by OACP for non-compliance with aviation consumer 
protection requirements.

DATES: Comments should be filed by February 5, 2026. Late-filed 
comments will be considered to the extent practicable.

ADDRESSES: You may file comments identified by the docket number DOT-
OST-2025-2514 by any of the following methods:
     Federal eRulemaking Portal: go to http://www.regulations.gov and follow the online instructions for submitting 
comments.
     Mail: U.S. Department of Transportation, Docket 
Operations, West Building Ground Floor, Room W12-140, 1200 New Jersey 
Avenue SE, Washington, DC 20590-0001.
     Hand Delivery or Courier: U.S. Department of 
Transportation, Docket Operations, M-30, Ground Floor, Room W12-140, 
1200 New Jersey Avenue SE, Washington, DC 20590-0001 between 9:00 a.m. 
and 5:00 p.m., Monday through Friday, except Federal holidays. 
Commenters using this method of delivery should contact Docket Services 
at 202-366-9826 or 202-366-9317 before delivery to ensure staff is 
available to receive the delivery.
    Instructions: You must include the agency name and docket number 
DOT-OST-2025-2514 or the Regulatory Identification Number (RIN 2105-
ZA20) for the rulemaking at the beginning of your comment. All comments 
received will be posted without change to http://www.regulations.gov, 
including any personal information provided.
    Privacy Act: Anyone can search the electronic form of all comments 
received in any of our dockets by the name of the individual submitting 
the comment (or signing the comment, if submitted on behalf of an 
association, business, labor union, etc.) For information on DOT's 
compliance with the Privacy Act, please visit https://www.transportation.gov/privacy.
    Docket: For access to the docket to read background documents and 
comments received, go to http://www.regulations.gov or to the street 
address listed above. Follow the online instructions for accessing the 
docket.

FOR FURTHER INFORMATION CONTACT: Ryan Patanaphan or Blane A. Workie, 
Office of Aviation Consumer Protection, U.S. Department of 
Transportation, 1200 New Jersey Avenue SE, Washington, DC 20590, 202-
366-9342, 202-366-7152 (fax), [email protected] or 
[email protected] (email).

SUPPLEMENTARY INFORMATION: OACP, a unit within the Office of the 
General Counsel, is responsible for enforcing aviation consumer 
protection statutes and regulations. On January 3, 2023, OACP published 
on its website guidance describing its investigatory and enforcement 
practices, including an attachment listing the criteria the office uses 
to determine an appropriate sanction for violations.\1\ In February 
2025, President Trump issued Executive Order 14219, titled ``Ensuring 
Lawful Governance and Implementing the President's Department of 
Government Efficiency Deregulatory Initiative,'' which directs Federal 
agencies to prioritize enforcement of regulations that are explicitly 
authorized by the Constitution and Federal statutes.\2\ In March 2025, 
the Department's Acting General Counsel issued a memorandum clarifying 
the procedural requirements governing enforcement actions initiated by 
the Department in order to ensure that DOT enforcement actions satisfy 
principles of due process and remain lawful, reasonable, and consistent 
with Administration policy.\3\ In May 2025, the Department issued a 
notice of proposed rulemaking that proposes, among other things, to 
codify the provisions of that memorandum.\4\ OACP is proposing to 
revise its existing investigatory and enforcement policies and 
procedures to be consistent with current Departmental and 
Administration policy and to ensure that OACP is carrying out its 
enforcement responsibilities in a fair and just manner. The substantive 
text of the proposed updated notice, including its attachment, is 
produced for public comment following this section.
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    \1\ https://www.transportation.gov/airconsumer/Notice_Investigatory_Enforcement_Policies_Procedures.
    \2\ 90 FR 10583 (Feb. 25, 2025).
    \3\ https://www.transportation.gov/administrations/office-general-counsel/general-counsel%E2%80%99s-enforcement-memorandum.
    \4\ 90 FR 20956 (May 16, 2025).

    Signed in Washington, DC, on December 31, 2025.
Blane A. Workie,
Assistant General Counsel, Office of Aviation Consumer Protection, U.S. 
Department of Transportation.

Notice Regarding Investigatory and Enforcement Policies and Procedures

    The U.S. Department of Transportation's Office of Aviation Consumer 
Protection (OACP), a unit within the Office of the General Counsel, is 
responsible for monitoring airline and ticket agent compliance with the 
Department's aviation consumer protection, civil rights, and economic 
licensing requirements. The office has broad authority to investigate 
violations of these requirements and the discretion to determine 
whether and how to conduct such investigations and initiate enforcement 
actions. OACP also has authority, under 49 U.S.C. 46301, to assess 
civil penalties. This notice is being issued to ensure alignment 
between OACP's investigatory and enforcement policies and practices and 
the Administration's directives and priorities.
    Executive Order 14219, issued on February 25, 2025, directs Federal 
agencies to de-prioritize actions to enforce regulations that are based 
on anything other than the best reading of a statute or go beyond the 
powers vested in the Federal Government by the Constitution. Consistent 
with this Executive Order and the Department's enforcement objectives, 
OACP intends to modify its enforcement program to ensure that all 
enforcement actions taken against affected parties are founded on a 
positive grant of statutory authority and that monetary penalties, if 
sought, are based upon statutory text that clearly grants the 
Department the authority to impose such penalties for the asserted 
violations. In the proper exercise of enforcement discretion, OACP will 
apply the best reading of the statutory text and not adopt or rely upon 
overly broad interpretations of the governing statutes or regulations.
    In addition, consistent with the Administration's enforcement 
philosophy, OACP's enforcement focus will be on ensuring compliance 
with civil rights and consumer protection regulations rather than 
finding and penalizing entities for violations. Proactive measures to 
promote compliance benefit the public by creating a culture of 
compliance where regulated entities work to prevent violations from 
happening in the first place. OACP intends to work with the regulated 
entities to ensure that they understand and meet their obligations. If 
OACP finds violations, it will attempt to address the problem by 
issuing a warning letter to help the regulated entity achieve 
compliance and resolve the issues before pursuing enforcement actions, 
which may result in negotiated settlement orders assessing civil 
penalties. When OACP has evidence of widespread, systemic, egregious, 
or intentional violations, it may determine that enforcement action is 
appropriate. In all enforcement actions, OACP will carry out its 
responsibilities in a fair and just manner, which includes ensuring 
that the affected parties are provided

[[Page 387]]

due process and ensuring actions are based on established law and 
grounded in factual evidence.
    Once OACP has determined that enforcement action is appropriate, it 
will attempt to negotiate an order assessing a reasonable civil penalty 
and requiring reasonable corrective actions such as ensuring consumers 
are made whole. If the regulated entity and OACP are not able to reach 
agreement on the terms of a consent order, OACP may seek resolution of 
the matter by filing a formal complaint before the Department's Office 
of Hearings for a decision by an Administrative Law Judge (ALJ). A 
civil action in a district court of the United States may also be 
initiated to enforce violations of aviation consumer protection and 
civil rights statutes or regulations. OACP's approach of prioritizing 
compliance efforts before resorting to enforcement action is a more 
effective and efficient way to improve the air travel environment for 
consumers.

How OACP Learns About Potential Problems

    Most of OACP's investigations and enforcement actions are based on 
consumer complaints. OACP receives complaints directly from consumers 
about services they received or requested from an airline or ticket 
agent that do not relate to airline safety or security. A team of 
Transportation Industry Analysts reviews consumer complaints and tracks 
trends to identify problematic practices. OACP also learns about 
potential problems through its own investigation by monitoring 
websites, advertisements, and other materials produced by airlines and 
ticket agents. OACP may also learn about potential problems through 
inspections of airline headquarters or airports, referrals from other 
government agencies, required submissions from airlines, reports from 
airline competitors, and media stories. OACP's Aviation Complaint, 
Enforcement, and Reporting System (ACERS) manages consumer complaints 
and reports submitted by regulated entities.

Investigation Process

    Consistent with due process, once sufficient facts are established 
for OACP to open an investigation, OACP generally sends an 
investigation letter to the alleged violator. This letter advises the 
regulated entity of the potential problematic conduct, requests 
additional information, and allows the respondent to inform OACP of 
defenses, mitigating circumstances, or additional facts while 
encouraging voluntary cooperation. When an investigation letter is sent 
to a regulated entity, OACP considers the entity to be on sufficient 
notice of OACP's jurisdiction over the particular conduct and the legal 
standards applicable to that conduct. OACP may also contact third 
parties to conduct interviews or obtain documents for review. Once OACP 
has received enough information to determine whether a violation 
occurred and the extent of the violation(s), OACP evaluates and decides 
how to resolve the matter.

Results of Investigations

    OACP investigations can result in a finding of a violation, no 
violation, or insufficient information if there is not adequate 
evidence of whether a violation occurred. If a violation is found, OACP 
will work with the airline or ticket agent to ensure that corrective 
action is taken. OACP may also initiate enforcement action if 
appropriate. If OACP finds that no violation occurred following an 
investigation, OACP will close the investigation without prejudice to 
further investigation and will inform the entity being investigated of 
the decision (if the entity was previously made aware of the 
investigation or other pre-enforcement activity). If there is 
insufficient information to identify whether a violation occurred, OACP 
may close the case or decide to monitor the practices of the entity 
being investigated.

Types of Enforcement Action

     Consent Orders: OACP generally takes enforcement action 
when it sees a pattern or practice of violations. If enforcement action 
is warranted, OACP primarily resolves these cases by negotiating with 
the alleged violator and reaching a settlement agreement in the form of 
a consent order. The consent order is an order directing the alleged 
violator to cease and desist from the problematic practice. In many 
cases, the consent order will assess an administrative civil penalty. 
All settlements are made public through OACP's website and the 
regulations.gov public docket.
     Enforcement Proceeding in Front of the Office of Hearings: 
If OACP and a regulated entity cannot reach a satisfactory resolution 
of an enforcement matter using the negotiated consent order process, 
then OACP may choose to pursue such violations through the initiation 
of a formal enforcement proceeding before an ALJ as expressly 
authorized by 49 U.S.C. 46301. In accordance with 49 U.S.C. 46301, 
these enforcement actions likely would seek civil penalties, cease and 
desist provisions, and other remedial relief deemed appropriate by 
OACP. The formal complaint that OACP files with the ALJ becomes public 
on OACP's website. Following the ALJ's decision, parties may file for 
further review from the Department decisionmaker.
     Civil Action in District Court: OACP is not limited to 
initiating a proceeding before an ALJ and also has the option to bring 
a civil action in a United States District Court as authorized by 49 
U.S.C. 46106 and 46107.
     Warning Letters: If OACP determines that enforcement 
action through an order, an administrative proceeding before an ALJ, or 
a civil action in district court is not warranted (for example, if the 
violating entity took sufficient corrective action prior to OACP's 
learning about the violation), OACP plans to exercise its discretion 
and send a warning letter to the violating entity. The letter places 
the violator on notice that OACP is aware of the violation and may 
pursue enforcement action if similar violations occur in the future.

Voluntary Self-Disclosure

    A regulated entity's voluntarily self-disclosing violations of the 
Department's requirements in a timely manner will strongly weigh in 
favor of no enforcement action or reduced penalties for that entity. 
OACP will consider the entity's disclosure and corrective actions in 
determining whether to take enforcement action and the remedies if 
action is taken. Depending on the level of consumer harm, OACP may 
determine enforcement action is not warranted if the entity has 
corrected the issue and made whole any consumers negatively impacted by 
the violations. In the alternative, OACP may take the self-disclosure 
into account as a factor in determining the civil penalty assessed 
against the entity. A self-disclosure is not considered voluntary if 
the disclosure is required by law.

Case Closure

    OACP may close a case if it determines that no violation occurred, 
if there is insufficient information to decide, if OACP's resources are 
better utilized elsewhere, or if the violation has been remedied and no 
further action is required.

Sanctions

    OACP's enforcement program focuses on ensuring compliance with 
Departmental requirements rather than penalizing entities for 
violations. The office's enforcement program seeks to encourage 
voluntary compliance,

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including voluntary self-disclosure of violations, before pursuing 
enforcement actions that could include assessment of civil penalties. 
When warranted, civil penalties are meant to change the violator's 
behavior and bring about compliance. Civil penalties should be 
reasonable and proportional to the violation and its impacts, and the 
bases for penalty assessments should be consistent and transparent to 
the public. OACP continually reevaluates its penalty structure to 
ensure that its administrative civil penalties are set fairly and 
consistent with statutory authority.
    Within the boundaries of statutory authority, multiple factors may 
impact the level of a civil penalty assessment. These include the scope 
and scale of the violation, the degree of harm caused, the violator's 
history of non-compliance, the violator's ability to pay, the 
Department's past actions for similar violations, the possibility of 
incentivizing or deterring future actions, and the size of the business 
in question. Penalties are assessed on a per-violation basis. If civil 
penalties are insufficient due to the criminal nature of the violating 
conduct, OACP may refer the case to the Department's Office of the 
Inspector General for review, investigation, and potential prosecution. 
OACP may also refer matters to the Department of Justice (DOJ) for 
civil enforcement, where appropriate. For a full list of criteria used 
by OACP in calculating a sanction, please see the Attachment ``Criteria 
Considered in Setting Civil Penalties.''
    This notice supersedes the previous notice dated January 3, 2023.

Attachment

U.S. Department of Transportation

Office of Aviation Consumer Protection

Criteria Considered in Setting Civil Penalties

    The Office of Aviation Consumer Protection (OACP) considers the 
factors listed below in determining the civil penalty it would seek 
or settle for in an enforcement proceeding and considers other 
relevant factors as appropriate. The civil penalty amounts 
referenced in this document are annually adjusted based on inflation 
pursuant to statute.\5\ OACP will update the penalty amounts in this 
attachment when that occurs and include the date of this change.
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    \5\ The Department's civil penalties are adjusted annually 
pursuant to the Federal Civil Penalties Inflation Adjustment Act of 
1990 (FCPIAA), Public Law 101-410, as amended by the Federal Civil 
Penalties Inflation Adjustment Act Improvements Act of 2015 (2015 
Act), Public Law 114-74, 129 Stat. 599, codified at 28 U.S.C. 2461 
note. The FCPIAA and the 2015 Act require Federal agencies to adjust 
minimum and maximum civil penalty amounts to preserve their 
deterrent impact. The 2015 Act specifically required an initial 
catch-up adjustment, followed by annual adjustments of civil penalty 
amounts using a statutorily mandated formula.
    For example, violations by entities not qualifying as a small 
business concern occurring from May 3, 2021 to March 20, 2022 are 
subject to a maximum civil penalty amount per violation up to 
$35,188. Revisions to Civil Penalty Amounts, 86 FR 23241 (May 3, 
2021) (codified at 14 CFR 383.2). For violations occurring from 
March 21, 2022, to January 5, 2023, the applicable maximum civil 
penalty amount per violation is up to $37,377. Revisions to Civil 
Penalty Amounts, 87 FR 15839 (March 21, 2022). For violations 
occurring from January 6, 2023, to December 27, 2023, the applicable 
maximum civil penalty amount per violation is up to $40,272. 
Revisions to Civil Penalty Amounts, 88 FR 1114 (January 6, 2023). 
For violations occurring from December 28, 2023, to May 15, 2024, 
the applicable maximum civil penalty amount per violation is up to 
$41,477. Revisions to Civil Penalty Amounts, 88 FR 89551 (December 
28, 2023). The FAA Reauthorization Act of 2024, Public Law 118-63, 
increased the maximum civil penalty amount to $75,000 for each 
violation occurring on or after May 16, 2024.
    Furthermore, under 49 U.S.C. 46301(a)(7), a violation of section 
41705 that involves damage to a passenger's wheelchair or other 
mobility aid or injury to a passenger with a disability may be 
increased above the otherwise applicable maximum amount to an amount 
not to exceed 3 times the maximum penalty otherwise allowed.
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    (1) The maximum assessable amount of the civil penalty under 49 
U.S.C. 46301 and 14 CFR part 383, as adjusted for inflation. As of 
2025, the maximum civil penalty assessable per violation is as 
follows:
     The General Penalty Provision for violations of Title 
49 and Department orders and regulations is $75,000 per violation 
for all entities, other than small business or individuals, to which 
a general penalty amount of $1,875 per violation applies. For OACP 
purposes, the $1,875 per violation penalty is usually applicable 
only in cases involving reporting violations by small carriers.
     For small businesses, as defined in 13 CFR part 121, 15 
U.S.C. 632, and individuals, three specialized penalty amounts apply 
to specific kinds of violations:
     $17,062 for violations of certain provisions of chapter 
401 (see statute for specifics), including the anti-discrimination 
provisions of section 40127 and those applying to passengers with 
disabilities (49 U.S.C. 41705) and related rules and orders;
     $8,531 for violations of 49 U.S.C. 41719 (related to 
essential air service) and related rules and orders;
     $4,267 for violations of 49 U.S.C. 41712 (unfair and 
deceptive practices) and related rules and orders.
     For continuing violations, each day a violation 
continues is a separate violation for penalty purposes.
    (2) The number of violations.
    (3) How long the violations continued, especially after the 
alleged violator's management became aware of them.
    (4) The harm caused by the violations, as well as steps taken to 
reimburse passengers or otherwise correct the harm.
    (5) Whether the violations were inadvertent or deliberate.
    (6) The alleged violator's enforcement history.
    (7) The alleged violator's compliance disposition:
    a. did the entity expend resources to prevent such violations?
    b. did the entity have procedures in place to prevent such 
violations?
    c. did the entity provide training to employees in the area?
    d. how quickly was the problem corrected after OACP 
notification?
    e. what resources did the entity expend to correct the situation 
(e.g., for training, new equipment, new procedures, additional 
personnel)?
    (8) The alleged violator's ability to pay (e.g., carrier in 
financial distress).
    (9) The Department's history and past practices in assessing 
penalties for similar violations, adjusting for statutory penalty 
increases and inflation.
    (10) The alleged violator's experience/sophistication level 
(e.g., new airline or established carrier; foreign carrier with 
limited service to U.S.).
    (11) The need to eliminate/disgorge any profits attributable to 
the violations.
    (12) Any valid excuses for the violations (e.g., were they 
beyond the alleged violator's control?).
    (13) Whether the violations were voluntarily self-reported by 
the alleged violator In addition, to encourage future compliance, 
OACP may permit the inclusion of a suspended civil penalty amount, 
as appropriate for each case. This amount becomes immediately due if 
the regulated entity violates the cease-and-desist or payment 
provisions of the order within a set period, usually one year from 
the issuance date of the order. The office also may include 
``offsets'' in settlements for expenditures the violator makes that 
go above and beyond the Department's aviation consumer requirements, 
e.g., providing compensation to consumers when not required under 
the Department's regulations, or purchasing equipment or 
implementing systems that will provide tangible consumer benefits in 
the future beyond what is required to comply with the law.
    Finally, it should be noted that virtually every settlement the 
office enters into involves the issuance of a cease-and-desist order 
with findings of violations. Consent orders become final orders of 
the Department 10 days after issuance, unless a petition for review 
is filed or the Department takes review on its own initiative. 
Consent orders have become a valuable source of Department 
enforcement case precedent, but they do not create new regulatory 
obligations for entities that are not named in the order.

[FR Doc. 2025-24282 Filed 1-5-26; 8:45 am]
BILLING CODE 4910-9X-P