Airline passenger rights compliance that works out who is owed what, under which rule, before the gate improvises
Every passenger's refund, care and compensation, planned before the gate improvises.
See one case, screen by screen ↓Airline Passenger Rights Compliance is a set of AI agents that checks each flight disruption against the DOT automatic refund rule (14 CFR Part 260), UK261, EU261 and Canada's APPR for an airline's passenger rights and compliance team. The eight agents work out which regime covers each passenger, test the extraordinary-circumstances defense against case law, and build one plan for care, refunds, compensation and notices — which the passenger rights compliance manager approves and signs before anything is paid.
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One disrupted flight can owe different duties to the people on board. A London–Chicago cancellation owes everyone a cash refund on the DOT clock if they decline the alternative, care and a written notice of rights under UK261, £520 in compensation — and €600 to the passengers whose single booking began in the EU, C$1,000 to those flying on to Canada under APPR. Operations codes a cause for operations, not for law, and the passenger rights team finds out which regime applied claim by claim, months later.
The cost sits in the gaps. A station desk hands out travel vouchers where the DOT automatic refund rule requires cash. A claims team refuses compensation on a crew-illness defense the UK courts have rejected — the Court of Appeal in 2021, the Supreme Court in 2024 — or pays the same passenger under UK261 and EU261. And when DOT, the UK CAA or the Canadian Transportation Agency writes, the evidence is rebuilt by hand from email and spreadsheets.
Estimated staff hours for a cancellation touching four regimes, worked by hand and with the solution.
Eight specialist agents resolve every itinerary, test the cause and build one plan for four regimes; the compliance manager decides and signs.
Corvane Airways CV 88, London Heathrow to Chicago O'Hare, Thursday, October 15: a Boeing 787-9 with 284 passengers booked. At 11:48 BST the first officer and two cabin crew call in sick. Here is what airline passenger rights compliance looks like next, screen by screen, in the working solution.
Elena opens Today in Chicago. Seven disruptions with passenger duties, $254,888 of compensation exposure at treasury rates and 112 DOT refunds on the clock, none late. Four items need her: the CV 88 duty plan, nine vouchers at London desk 4 where cash refunds are owed, CV 1406 with counsel, and a DOT letter due October 22.
Elena: “Tell me who is owed what, under which rule — before London starts handing out vouchers.”
Operations cancels CV 88 and codes the cause CRW-SICK, crew illness — outside control. The disruption reader picks it up at 12:06: 189 protected on tomorrow's CV 88, 64 rerouted today, 31 declined travel. The regime resolver reads all 284 itineraries: DOT Part 260 and UK261 cover everyone, EU261 covers 17 whose single booking began in CDG, AMS, DUB or FRA, and APPR covers 18 ticketed on to Toronto or Montreal.
“DOT and UK261 cover all 284. 17 began in the EU on one booking, so EU261 covers them whole; 18 fly on to Canada: APPR.”
The defense tester searches 214 decisions on crew absence and reads Corvane's own reserve roster. Crew illness is part of normal operations under Lipton v BA Cityflyer, upheld by the UK Supreme Court in 2024, and the three London reserves were assigned at 09:40 to CV 92. Verdict: the outside-control defense will not hold, 93% sure — above the 85% line, so Elena decides and counsel is copied.
The defense tester never refuses compensation; it recommends, and a person decides.
The challenger makes the airline's best case: three crew called in sick within four minutes, two hours before departure. The defense tester answers that Lipton does not turn on timing, and that reasonable measures fail on the airline's own record. Every citation opens the passage it relies on, highlighted, so Elena reads the court's words before she accepts the finding.
Challenger: “I could not find a decision that accepts timing as enough.”
The care planner asks Elena one thing before it finishes: shall it plan compensation for 247 passengers, setting the operations code aside? She answers “Yes, plan it”. The combined plan meets the strictest duty of all four regimes, each line with its rule: meals for 284, hotels and coach transfers for 140, meals tomorrow for 189, refunds for 31, compensation for 247 and a written notice of rights for all — $171,350 compensation, $39,636 care, $38,412 in fares returned.
Care planner: “Shall I plan compensation for 247 passengers (≈ $171,350), setting the operations code aside? Helen Ashdown is copied.”
Every passenger has one row in the pay-once ledger. The 17 EU journeys are owed €600 under EU261 — more than £520 — so their UK claim is recorded as covered. The 18 Canada passengers get C$1,000 under APPR. Thirty-seven are owed no compensation — 14 non-revenue staff tickets, 6 lap infants and 17 rerouted inside the window — and all still get care.
“The regime that pays, the amount, and the others recorded as covered.”
The station guide wrote plain-words guidance for each passenger group, tied to its rule, for the gates and the call center. Reading the desk log, it finds nine $300 travel vouchers issued at LHR desk 4 between 12:40 and 13:05 to passengers who asked for their money back. It proposes writing to the nine today with a full cash refund of $12,024, and letting them keep the voucher only if they choose it. Elena approves the fix.
“The DOT rule requires a refund in the original form of payment unless the passenger chooses otherwise.”
The airport hotels are sold out at the $165 contract cap; 140 rooms are free at $176, 90 on Bath Road and 50 in Colnbrook, so Elena raises the cap to $176 with a reason. The care planner rechecks plan v4 against all four regimes: care $39,636, still the strictest duty in each. She signs with reason code PLN-01, plan as proposed, with edits. The payment batch is over $50,000, so Dario Whitfield, customer recovery lead, countersigns and refunds and compensation are released.
Nothing is booked or paid before the plan is signed.
The refund clock keeper started 31 clocks at 12:04 BST, not at a request: 27 card refunds due Monday, October 26 (7 business days) and 4 other forms due Wednesday, November 4 (20 days), each staged in the original form of payment. Across the airline, 112 refunds are open and two from CV 1422 are due Monday, October 19, both staged.
The refund clock keeper never pays a voucher in place of cash unless the passenger chose it.
Six CV 88 claims arrive in the first hour and each is matched to the plan; none is paid until it is signed. Camille Dumont claimed €600 under EU261 directly and £520 under UK261 through Velmora Claims — she is paid once, €600. Max Corrigan traveled on a non-revenue staff ticket, which the regulation excludes; the claims matcher proposes the rejection with the rule, and a person approves it.
“A person must approve every rejection.”
The same cancellation, seen by the four people who carry it — from operations control to counsel — what their day looked like, and what it looks like now.
Eight specialist agents resolve every itinerary, test the cause and build one plan for four regimes; the compliance manager decides and signs.
Picks up every cancellation or long delay from the operations log and reads the cause, the crew messages, departure control and the new times.
Reads each passenger's itinerary — where the journey began and ends, the carrier and the ticket type — and works out which of DOT, UK261, EU261 and APPR apply, and which one pays.
Tests the extraordinary-circumstances defense against case law and the airline's own roster and notices; a challenger argues the airline's best case so the verdict is tested before anyone relies on it.
Builds one plan that meets the strictest duty of every regime — care, rerouting, refunds, compensation and notices — prices it at treasury rates, and rechecks it after every edit.
Writes gate and call-center guidance for each passenger group, sends the written notice of rights, and watches the station desk log for actions that break a rule.
Starts each DOT refund clock at the cancellation or significant change and stages the refund in the original form of payment.
Matches direct and claim-agency claims to signed plans, blocks double payment through the pay-once ledger and proposes rejections with reasons.
Assembles the evidence for a DOT, CAA or CTA letter from signed plans and the refund ledger, and drafts the reply.
Approves with a reason and signs. The agents propose; a named person decides.
Ask the agents about any disrupted flight, passenger, refund, claim or rule — or tell them what to do. Every answer cites the rule, the case or the airline's own record, and changes are proposed for approval.
Which CV 88 passengers are paid under EU261, and why?
17 passengers began their single booking at an EU airport — CDG 7, AMS 5, DUB 3, FRA 2. A single-booking journey from the EU is covered whole, so each is owed €600 instead of £520.
Are any refunds at risk of missing the DOT clock?
None is late. Two CV 1422 card refunds are due Mon, Oct 19 and both are staged; one PayPal refund waits for bank details and goes by check on Oct 22 if none arrive.
Why won't the crew-illness defense hold on CV 88?
The UK courts held — the Court of Appeal in 2021, upheld by the Supreme Court in 2024 — that crew illness is inherent in an airline's normal activity; the CJEU says the same of mass staff absence. And the roster shows the LHR reserves were spent at 09:40 on CV 92.
Draft the reply to the DOT refund letter
The draft for OACP-2026-0417 is ready: 1,903 of 1,906 refunds on time, three late on expired cards and paid by check. Helen Ashdown signs before anything is sent.
13 screens from the working solution, on its sample data. Pick one to see it large.
The regimes, caps and approval lines every disruption is checked against are settings; every change needs a reason and is logged.
| Setting | Default | Choose from |
|---|---|---|
| Regimes and rules | DOT Part 260, customer service plan §4.2, UK261, EU261, APPR, pay once | Each switched on or off · rules library v2026.10, each citing its text |
| Hotel cap per night · LHR | $165 contract · $176 for Oct 15 | Set per city; a change needs a reason |
| Hotel cap per night · ORD | $149 | Set per city; a change needs a reason |
| Meal voucher | $18 per 3 hours of waiting | Edited with a reason; logged |
| Counsel decides below | 85% confidence | Edited with a reason; logged |
| Second approver for payment batches over | $50,000 | Edited with a reason; logged |
| Plan approval | Always required · reason code and signature | PLN-01 with edits · PLN-02 as proposed · PLN-R2 return: defense needs counsel · PLN-R3 reject: amounts or caps wrong |
| EU261 reform rules | Staged · off | Simulate on today's flights · switch on the day it applies |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (49 U.S.C. 41712 and 46301 as amended in 2024 — up to $75,000 per violation; DOT consumer penalties of $166 million in the three years to mid-2024; IATA, A4E and ERA, January 13, 2026 — EU261 costs airlines an estimated €8.1 billion a year; 14 CFR 260.6 on refunds; UK261 and EU261 Art 5, 7, 9, 14; APPR s.12 and s.19; Lipton v BA Cityflyer [2021] EWCA Civ 454, upheld [2024] UKSC 24; CJEU Krüsemann C-195/17; CJEU Wegener C-537/17). Corvane Airways and the people, flights, claim agencies and aircraft named on this page are fictional — characters and sample data in the working solution.
Airline Passenger Rights Compliance is a set of AI agents that checks each flight disruption against the DOT automatic refund rule (14 CFR Part 260), UK261, EU261 and Canada's APPR for an airline's passenger rights and compliance team. The eight agents work out which regime covers each passenger, test the extraordinary-circumstances defense against case law, and build one plan for care, refunds, compensation and notices — which the passenger rights compliance manager approves and signs before anything is paid.
Under 14 CFR 260.6, a refund for a cancellation or significant change the passenger declines is due within 7 business days for card purchases and 20 days for other forms of payment, in the original form of payment unless the passenger agrees otherwise. The refund clock keeper starts each clock at the cancellation, not at a request, and stages every refund ahead of its due date.
Not on the case law the solution cites: the UK Supreme Court held in Lipton v BA Cityflyer [2024] UKSC 24, upholding the Court of Appeal, that crew illness is inherent in an airline's normal activity. The defense tester checks every cause code against such decisions and the airline's own roster, says when a defense will not hold, and a challenger agent argues the airline's side first.
The solution pays each passenger once, under the regime that gives them the most, and records the others as covered. On the sample flight, 17 passengers whose single booking began in the EU are paid €600 under EU261 rather than £520 under UK261, and a claim-agency duplicate is caught and matched to the payment already made.
For a large carrier, APPR pays C$400, C$700 or C$1,000 by arrival delay when the cause is within the carrier's control and not required for safety. The regime resolver applies it to passengers ticketed on to Canada; when a cause may be required for safety and the agents are below 85% confidence, regulatory counsel decides.
The regulator responder assembles the evidence from signed plans, the refund ledger and the audit trail — for a DOT refund inquiry, the flights in scope, refunds issued and the share inside the clock — and drafts the reply. It never sends anything; regulatory counsel reviews and signs.
Yes. The agents propose and cite; the passenger rights compliance manager approves, edits or rejects each plan with a reason code and signature, counsel decides calls below 85% confidence, and payment batches over $50,000 need a second approver. Agents never pay, refuse a claim or write to a passenger outside an approved template.
The Agentic Solution Engine builds and deploys it from your requirements and documents — your customer service plan, rules, caps and a sample of past disruptions and claims — and it goes live once every quality gate has passed. We will walk you through it on your own cancellations first.
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