If you follow accessible travel at all, you’ve probably noticed an uptick of articles about the possibility of staying in your own wheelchair to fly. A few airlines have released prototypes of “accessible” flip up seating units with wheelchair tie-downs; and a number of disability rights organizations have championed the “flying in your wheelchair” movement.
Enacted in 1986, the Air Carrier Access Act, covers access-related travel issues on all US airlines, and on foreign airlines on flights to and from the US. And as with many regulations, it’s continually updated. The 2025 Air Carrier Act updates include minor wording changes and definitions, updated training requirements, and some specific changes in existing regulations. This update of the regulations focuses mainly on preventing and mitigating wheelchair damage, and providing timely and appropriate repairs when it does occur. Here are the highlights of what to expect in 2025. These 2025 Air Carrier Access Act Updates will take effect January 16, 2025 unless otherwise noted.
As of December 17, 2025, airlines covered by the Air Carrier Access Act will be required to notify passengers when their assistive devices have been loaded and unloaded from the cargo hold.
Airlines will be required to publish the dimensions of their cargo holds — and any limitations they may have — on their websites. This applies to all the aircraft in their fleet.
As of June 6, 2025 airlines will be required to deliver delayed assistive devices within 24 hours for a domestic flight, 12 hours for an international flight, and 30 hours for a long international flight (more than 12 hours). The passenger will have the choice of picking up the delayed assistive device at the airport or having it delivered to a reasonable location.
Passengers will be reimbursed for accessible ground transportation should they decide to pick up their delayed assistive device at the airport.
As of March 17, 2025 carriers must offer passengers a choice in regards to repair or replacement of damaged assistive devices. Passengers can opt to have the carrier arrange for repair or replacement, or the passenger can arrange for repair or replacement at their chosen vendor. If the latter option is chosen, the carrier will transport the assistive device to the repair location and pay for the needed repairs.
It should be noted that the Montreal Convention still remains in effect for the liability limits for assistive devices damaged or lost on international flights. The carrier liability limit for this is $1731.
If the airline provides a loaner assistive device because of loss or damage, and it does not meet the passenger’s needs, the passenger can find an appropriate substitute elsewhere. If this happens, the airline must reimburse the passenger for the rental within 30 days. The airline can require receipts, invoices or other documentation.
If a passenger’s assistive device will not fit into the cargo hold, the airline must book the passenger on the next available flight that can accommodate it. This will be done at no additional charge, even if a partner carrier is used.
Finally, the 2025 Air Carrier Access Act updates include requirements for new safety standards and accessibility features for on-board wheelchairs. These include adequate padding, locking wheels, restraints and new size requirements. They go into effect for new aisle chairs purchased on twin aisle aircraft and aircraft with over 60 seats on October 2, 2026. And they go into effect for all other covered aircraft on October 2, 2031.
For more information about your rights under the Air Carrier Access Act, visit https://emerginghorizons.com/the-disabled-air-travelers-bill-of-rights/
Flying with a child who lacks trunk support may appear impossible at first glance. Although the process is manageable with infants, as children grow it can become more difficult. That said, with a bit of research, preparation and education, flying can become a reality for toddlers, teens and even young adults who lack trunk support. With that in mind, here’s what you need to know to have a safe and comfortable flight.
Infants are pretty easy, as far as air travel is concerned. Basically you just need to bring along a Federal Aviation Association (FAA) approved Child Restraint System (CRS) – more commonly known as a car seat. It can be a forward or rear facing model, but it must have two FAA approved labels on it. One label must include the text, “This child restraint system conforms to all applicable federal motor vehicle safety standards”. The other label must include (in red) the text “This restraint is certified for use in motor vehicles and aircraft.” Alternatively, it’s acceptable to have the two labels merged into one if all the appropriate text is included.
It’s important to remember that under FAA regulations, no carrier may prohibit a child (any passenger under 18) from using an approved CRS as long as they have purchased a seat, fall within the manufacturer’s height and weight limits for the CRS, and are accompanied by a parent or guardian.
As a child that lacks trunk support grows, parents have to explore other options. The FAA limits what type of seating devices may be brought aboard the aircraft, but many parents use neck pillows, towels and blankets to help support their children. Seating the child next to the window sometimes helps too, as they can lean on it for support. That said, you have to be careful with what you bring aboard, because unless it’s FAA-approved, any homemade device that straps to the seat or is too big and bulky will usually get the boot.
The CARES Harness (amsafe.com/kidsflysafe-com/) may be an option for some children. This FAA-approved harness straps to the seat and can be used on children over one year old who weight between 22 and 44 pounds and can sit in their own seat.
Another option is buy a first-class seat and physically help help the child maintain his balance during takeoff and landing. After that he can recline, and because of the extra room in first-class, the seat goes back further.
A number of companies also offer FAA-approved CRS for toddlers. They all have height and weight limits, so it’s best to check the company’s website carefully for these restrictions. It’s also important to remember that in order to take any CRS on an airplane, it must be labeled that it is FAA approved for use on an aircraft. If a CRS does not have this label, it will not be accepted, even if the manufacturer says it’s approved. Labeling is extremely important.
Once a child gets older and gains more weight, flying with a child who lacks trunk support can be more difficult. That said, if you plan to travel throughout Europe, you may be able to use the Meru Travel Chair (merushop.org/product/travelchair-enabling-disabled-children-to-fly/).
This seating device is designed for children from 3 to 11 years old, who weight up to 35 kg (77 pounds). It was developed with the support of the UK Civil Aviation Authority and families with disabled children. The chair fits into an airplane seat and has an adjustable headrest, footrest and a body harness that allows for various levels of support. It should be noted that the Meru Travel Chair is designed for an upright airline seat, and once installed the seat cannot recline.
The Meru Travel Chair is approved by the European Aviation Safety Agency (EASA), but it is not approved by the FAA. And if you do plan to use the Meru Travel Chair, it’s essential to give the airline at least 48 hours notice or more, to make sure that the aircraft can accommodate the seating device.
In the US, if you want to use a Meru Travel Chair or any other non-approved CRS, or if your child exceeds the height and weight limits for an approved CRS, you need to file for an FAA exemption.
You will need to file a petition for exemption from section 121.311(b) of Title 14, Code of Federal Regulations (www.ecfr.gov/current/title-14/chapter-I/subchapter-G/part-121/subpart-K/section-121.311). This is the section that specifies that “each child aboard an aircraft operated under part 121 must occupy an approved seat with a separate safety belt secured about him or her, and must not exceed the specified weight limit for the restraint system.”
Many exemptions have already been granted for children who lack trunk support. With that in mind, sometimes it helps to look at these granted exemptions to know how to correctly word a request for accommodations. Two well written examples are #7831 (Joseph Castasus) and #9834 (Avery Ottenbreit). Although they are older, many people have successfully patterned their petitions after them.
If your exemption is granted, it’s good for five years and it’s valid on all US airlines. Most exemptions also carry over into adulthood if a child turns 18 before it expires. After a child reaches adulthood, they need to file for an exemption on their own behalf.
The FAA recommends filing an exemption at least 120 days prior to your travel dates; however you’re not required to hold any reservations in order to file for an exemption. There’s no cost to file for an exemption, so it’s worth a shot if you plan on flying with a child who lacks trunk support. For more information about how to file an exemption, visit www.faa.gov/regulations_policies/rulemaking/petition/.
There are also a few things you need to know about accessible air travel before you head to the airport. First and foremost, know your rights (emerginghorizons.com/the-disabled-air-travelers-bill-of-rights/) under the Air Carrier Access Act. These rules apply to US airlines and to foreign airlines on flights to and from the US. Learn the law, so you know what to expect.
It’s also advisable to check with the airline in advance if you are traveling with a toddler or an older child who uses a CRS, as some small aircraft may not be able to accommodate a larger CRS. Additionally, some seating restrictions — such as no exit row seating — may apply to passengers who travel with a CRS. And it’s always a good idea to give the airline plenty advance notice if you are traveling with an exemption, so there are no surprises or delays at the airport.
Regulations about flying with a CRS vary around the world. Some are more restrictive, while others are more liberal. Copious research is needed for international travel. Never assume that policies will be the same overseas, as they are in the US.
Finally, if you experience an issues about your CRS on a US airline or on flights to and from the US, contact the Complaints Resolution Official (emerginghorizons.com/flying-with-a-wheelchair-remember-the-cro/). This airline employee is specifically trained to resolved access-related issues, and all covered airlines must have a CRO available by phone or in person. The CRO can be your best ally when you run into an access problem.
I have a portable dialysis machine that I’ve taken on many road trips, but my next trip requires an airplane flight. Can I take it aboard the aircraft, and can it be carried in the passenger cabin? Will I have to pay an additional baggage fee if I take it with me? Can I also bring my dialysis liquid and supplies with me?
The Air Carrier Access Act requires airlines to permit disabled passengers to bring assistive devices aboard the aircraft, provided they comply with applicable safety, security and hazardous materials rules. A portable dialysis machine is considered an assistive device, so yes, the airlines will usually transport it. Contact you airline well in advance of your flight to find out what documentation is required, and for instructions on how to pack your equipment.
Your portable dialysis machine will be given priority over all other passenger baggage brought into the cabin, provided you preboard the aircraft. If it cannot be accommodated in the passenger cabin (due to size or other issues) it will be transported in the baggage compartment. Since it is considered an assistive device, it will not be counted against your baggage allowance, and you will not be charged for it. And if you run into problems, ask to speak to the CRO (emerginghorizons.com/flying-with-a-wheelchair-remember-the-cro).
All of the above is dependent on the size of your machine. Airlines are not required to transport larger machines, as it would be considered an undue burden to them. Although that determination is made on a case-by-case basis, the Department of Transportation (DOT) feels that dialysis machines that weigh 100 pounds or slightly more (including the case) are of a reasonable size to transport in the baggage compartment.
Dialysis supplies are also included in the assistive device category, however the DOT considers a large supply to be an undue burden to the airlines. The DOT believes that it is reasonable for airlines to limit the quantity of dialysis liquid carried to a one-day or two-day supply. So you may have to plan ahead and ask your supplier if you can have your supplies shipped directly to your hotel or vacation home.
Under the Air Carrier Access Act (ACAA), US airlines are required to accept service animals on all their flights. Additionally, foreign air carriers are required to accept service animals on all flights to and from the US. Psychiatric service animals are treated the same as service animals under the ACAA. Additionally, after the ACAA update in 2021, airlines are no longer required to accommodate emotional support animals. They are now treated as pets and are subject to pet rules and additional charges. So here’s what you need to know about flying with a service animal.
Under the law, a service animal is defined as a dog that is trained to do a specific task or tasks for a person with a disability. Miniature horses are no longer accepted under the ACAA. And under no circumstances are US airlines required to accept unusual species, such as snakes, other reptiles, ferrets, rodents and spiders. Foreign carriers, that fly to and from the US are also required to accept dogs as service animals.
Service animals must be at least four months old; and air carriers are not required to accept service animals in training. There are no breed or weight restrictions; and although most passengers only travel with one service animal, two are allowed if they perform different tasks for the passenger. Additionally, airlines cannot restrict the number of service animals on any flight.
Airlines can require passengers flying with a service animal to submit DOT designed forms that attest to the service animal’s health, behavior and training. Additionally they can require attestation that the service animal will not need to relieve itself, or can relieve itself in a sanitary manner, on flights over eight hours. This documentation must be submitted at least 48 hours prior to departure.
Although most airlines process these DOT forms seamlessly on their own websites, a few use third-party vendors to accomplish this task. And although the same 48-hour advance notice is required, sometimes it’s difficult for third-party vendors to process the forms within this time frame. Check the airline website and allow yourself plenty of extra time if they use a third-party vendor.
Airline personnel are also allowed to seek credible verbal assurance from passengers that they have a disability and require a service animal. If the passenger’s disability is not apparent, airline personnel may question the passenger to determine their need for a service animal, even if the animal has a harness, tag or vest. And finally, if the airline refuses to accept an animal as a service animal, they must explain the reason, and provide written documentation of that decision within 10 days.
Beginning August 1, 2024 any dog entering the US (including service animals) must also meet the new Centers for Disease Control and Prevention (CDC) requirements. All dogs must:
Dogs entering the US must receive the rabies vaccine at least 28 days before entry. It’s recommended that handlers carry duplicate copies of all forms, in case border agents need to retain a copy. Additionally, if a dog is deemed to have a contagious disease by border agents, then additional testing, examination and isolation may be required at the owner’s expense.
These requirements are for animals that are visiting or returning from rabies-free countries. There are additional requirements for animals coming from high-risk rabies countries. For more information about the CDC requirements, visit https://www.cdc.gov/importation/dogs/enter-the-us.html.
Passengers who fly with service animals are allowed to preboard the aircraft; and the service animal must remain tethered and under the passenger’s control for the entire flight.
Passengers who fly with a service animal are guaranteed bulkhead seating under the ACAA; however they are permitted to sit anywhere on the aircraft, except the emergency exit rows. The service animal must not obstruct the aisle or other areas that must remain clear under FAA safety rules. Additionally, the service animal must fit in the handler’s lap or in their foot space, and it must not encroach on another passengers space. If this is a problem, the airline must allow the handler and the service animal to move to another seat where the animal can be accommodated; however they are not required to upgrade the passenger.
Last but not least, service animals must behave appropriately aboard the aircraft, which is usually not an issue for properly trained service animals. And when the airplane lands, airlines are required to provide service animal relief areas for passengers with a service animal. For more information about the updated ACAA that went into effect in 2021, visit https://www.ecfr.gov/current/title-14/chapter-II/subchapter-D/part-382
Last but not least, it’s important to understand that most foreign countries also have specific health requirements for all animals — including service animals — that enter the country. This is in addition to any DOT requirements for service animals. For example, even though the DOT forms require information about the animal’s rabies vaccination status, an additional health certificate may be required at the port of entry. Every country is different, and these requirements change often. For more information on specific country requirements, visit https://www.aphis.usda.gov/aphis/pet-travel/take-pet-to-foreign-country. Do your research and plan ahead to avoid disappointment.
Travel by its very nature requires a good amount of preparation, especially when it includes air travel. Factor a disability into that equation and the complexity increases. With that in mind, here are some helpful tips for flying with a wheelchair.
Flying with a wheelchair for the first time can seem pretty intimidating. That said, it doesn’t have to be. As they say, knowledge is power, and in this case that knowledge comes from the Air Carrier Access Act (ACAA). Not only does this legislation spell out the rules of accessible air travel in the US, but it also covers air travel for foreign airlines on direct flights to and from the US. Additionally it mandates an on-site problem solver for accessible air travel problems. This problem solver is called the Complaints Resolution Official, or the CRO for short. So before your next flight, it pays to learn about the ACAA and the CRO. Not only will this help you know what to expect when you fly, but it will also give you a valuable resource should things go wrong.
Many people incorrectly believe that air travel in the US is covered by the Americans with Disabilities Act (ADA). It is not. It is covered under the ACAA, which actually predates the ADA. And it specifically lays out the rules for accessible air travel on US airlines, as well for foreign airlines on flights to and from the US.
And the good news is that this piece of legislation is written in a user-friendly format. In other words it’s not a jumble of legal terms and phrases, but instead it’s presented as a series of questions and answers about accessible air travel. It covers everything from airport assistance and boarding, to seating, wheelchair stowage and even wheelchair damage. And the best thing that you can do to prepare yourself for your flight is to read the ACAA in it’s entirety at www.ecfr.gov/current/title-14/chapter-II/subchapter-D/part-382
Reading this legislation is especially important if it’s your first time flying with a wheelchair. Why? Because it will give you a good idea of what to expect when you get to the airport, board the airplane and even arrive at your destination. And once you know what to expect, you will also know when something is going wrong. That’s when the CRO comes into play.
The ACAA also mandates that covered airlines must have a CRO on duty during their operating hours. They can have the CRO available in person or by phone, but they do have to be available when someone requests one. These employees know the ACAA and they have the power to solve problems on the spot. They have the power to overrule every other airline employee — including third party contractors — except the captain of the aircraft.
Once you know the rules for accessible air travel, you will also know when something isn’t going according to the rules. And that’s when you need to speak up for yourself. For example, if an airline employee says that wheelchair-users are not allowed to have aisle seats, and instead insists that you have to sit by the window, then you need to ask for the CRO. In this case, it would first be a good idea to first tell the airline employee that under the ACAA, the only place a wheelchair-user can’t sit is the emergency exit row. And if you still get push back, ask to speak to the CRO.
Now if the airline employee doesn’t know who or what the CRO is, ask to speak to a supervisor. The supervisor definitely knows who the CRO is, and in fact they may even be a CRO. Sometimes inexperienced employees don’t know about the CRO, so don’t be afraid to work your way up the chain of command.
It’s also a good idea to bookmark the ACAA, so you will have easy access to it when you travel. Then if you run into something questionable, you can easily pull it up and show it to the airline employee. Sometimes that works, but in the end the CRO is your best source for immediate resolution.
Although the CRO is the person that can help solve your access related problems on the spot, there are a few more things you should do if you encounter difficulties when you are flying with a wheelchair. Of course first and foremost, you need to address the issue at hand, and try to get it solved by the CRO. But there are also a few more things that you should do when you return home.
First off, file an official complaint with the airline, especially if there was some damage done to your wheelchair or other assistive device. Address the issue and ask for appropriate compensation. When an access-related complaint is filed directly with the airline, they are required to track the resolution and report back to the Department of Transportation (DOT). It should be noted this is the only way to receive monetary damages from an airline, short of going to court.
Finally, it’s also a good idea to file an official ACAA complaint with the DOT after you return. This will not help solve your problem, nor will it get you any monetary compensation, but it could result in airline fines by the DOT. The DOT looks at patterns and if it gets numerous complaints on the same airline about the same thing, it may issue fines to the airlines involved. And remedial training is usually also required when an airline is fined. Although an ACAA complaint won’t benefit you personally it may help effect change and make air travel more accessible for everyone. And it’s easy to do on this online form — secure.dot.gov/air-travel-complaint.
So the next time you encounter problems when flying with a disability, make sure you take all of these measures to remedy the problem.
