DOT Moves Forward on Mandating How and Where Airline Fees Should be Displayed

The Department of Transportation (DOT) is at it again. In its latest proposed rulemaking, DOT tackles a lot of issues behind the veil of trying to protect the consumer. In a shocking move, most of them aren’t bad. In fact, many are downright good ideas. But I’m going to talk about the bulk of those tomorrow. Today, I’m just going to focus on the one biggest piece of the 100+ page document. Let’s talk about airline fee disclosure.

DOT Fee Rules

Over the last several years, as airlines have added fees, DOT has created a variety of rules to try to make them transparent, or something like that. In general, I’d say the rules have been fairly benign and not all that useful. For example, airlines have to disclose a change in bag fees on their website homepage. Whoop de doo.

So DOT has decided to take another stab at this issue, and airlines have long been fearful of what it would look like. I have generally sided with airlines on this one, but now that we see the proposal, DOT is leaving the door open here to treat it with actual finesse. I didn’t think that was something DOT was capable of doing.

There are really two pieces being debated here. The first is how fees should be distributed to third party travel sellers, and the second is how the fees should be disclosed during travel search and booking. And since this is a proposed rulemaking, DOT has provided multiple options and is asking for public feedback. (You can give your feedback here. Just click the big blue “comment now” button.)

Airline Fees and Third Parties
The first question is centered around whether or not airlines should be forced to distribute real-time fee data to third parties, and if so, how should they do it? The Global Distribution Systems (GDS), the big central reservation systems like the behemoth in the US market, Sabre, have been lobbying hard to make this happen. Granted, you might not see it since it’s usually hidden behind third parties so it looks like “Americans for Freedom” or something that sounds impossible to refute. But the intent here is to get the data spoon fed in a format that is already supported by the GDS. The airlines don’t like that.

The airlines think that it should be a business decision. If the GDSs want to get the data spoon-fed to them, then they need to negotiate it. It’s way more complex than that, but the airlines are really trying to just get some leverage back from the GDSs and move forward with better technology. It’s a big struggle.

With that background, DOT decided to dive in. The general consensus is that real-time fee data needs to be disclosed in a timely fashion, but DOT has so far kept this broad. There are two proposals. One would require fee information to be provided to ticket agents and GDSs while the other would only require it be given to ticket agents.

Here are a few bullet points on what this is and what this isn’t.

  • No proposal would require that airlines allow third parties to sell their ancillary products, though DOT asks for comments on if that should be required. (My answer: no way.)
  • No airline would have to distribute frequent flier information so that the third parties would be able to show discounts associated with frequent flier status. In other words, the airlines would just have to distribute the rack rates for fees.
  • The proposed rule doesn’t say anything about how the data would have to be distributed. Any reasonable format would work, in theory. (I’m guessing writing it in crayon and mailing it daily would not be reasonable.)
  • We’re just talking about four core fees here. It’s the first checked bag, second checked bag, carry-on bag, and seat fees that would need to be distributed.

Looking at both these proposals, I like the one that mandates distribution only for ticket sellers. Why should it matter if the GDS has it as long as the ones actually selling tickets have it? Though I don’t know for sure, I’m assuming the airlines could simply provide direct links to the information on their own sites or provide an API if they wanted. The third party sites could then just integrate links into their booking path.

This gets the right information to the person buying the ticket, but it doesn’t take away the airline’s ability to negotiate for better access to fee data. And of course, it leaves it up to the airline and third parties to negotiate to allow the sale of those ancillary offerings.

How Fee Data Needs to be Displayed
The other part of the issue is about how it has this fee data has to be displayed publicly. This would apply to airline websites as well.

Sites would be required to show those four core fees on the first page where an itinerary-specific fare is shown. It doesn’t have to be listed – it could be via a link or a mouseover, but it would have to show accurate fees as they pertain to that set of flights.

This is good for bags though bag fees are fairly uniform among those who charge them. This is way more useful for seat fees which can vary so much. On most airline websites now, you have to put in fake passenger information just to see the seat map with individual seat pricing. This would make them move that part of the process forward. Why hasn’t this been done yet? Well, it’s probably because it’s expensive to get the systems to behave this way. But it would be a big improvement for the traveler.

It should be noted that none of these proposals would do something silly like require the fees be included in the total price. It would just require that the fees be made available in real time early in the booking process.

Like I said, this was just one part of the rulemaking. I’ll review the rest tomorrow. But this one has turned out to be much less painful that I was expecting.

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29 Comments on "DOT Moves Forward on Mandating How and Where Airline Fees Should be Displayed"

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What is meant by “seat fee” here? Is it a fee to reserve any seat? Or is it the fee to reserve premium seats in the class (eg domestic economy-plus or exit rows)? How does the proposal mandate things when different seats cost different fees to reserve?


It is not that different from Europe where the essential fees should be available early in booking, so prices on different airlines can be reasonably compared.

Don Beyer

Rental Cars need these pricing rules. I just rented a car in MSP. Mandatory fees and taxes are 60% of the rental charge. Alamo 2 day rental is 21.20. Taxes, mandatory fees are 12.57. Alamo shows total cost on first page. Others don’t.


Good morning cranky I hope is well. Why would it be silly to include the fees in the total price? By selecting all the options you have upfront with seat location, bag fees and other amenities and getting a ticket price would be the best way to pick and choose which option to go with.


Seat fees are difficult because theoretically you can have as many distinct fees as there are seats; in practice, some airlines do have more that 10 different seat fees for each flight (I’m thinking of Allegiant). It makes little sense to pick your seat fee upfront — a seat fee has to be tied to an actual seat that’s available on a particular flight.

David SF eastbay

If you can see the prices upfront when looking at a menu, walking the aisles of a store, ro driving past a gas station, why can’t you check all the prices first thing when checking the price of an airline ticket?


Personally I think airlines (some more than others) are walking on shaky ground with the fees, aka, tying products. Upfront disclosure is often murky and in some cases it’s near impossible to avoid paying a fee. I applaud the DOT for anything that would provide uniformity across all airlines and GDS. That said, the fees are at least fixed prices. Actual ticket prices and the taxes/fees hidden in there is much more frustrating. Comments on the Transparent Airfares Act?

Except not all the fees are the same. Spirit charges different prices for each seat depending on aisle/window/middle. What about regular vs. preffered seating? Extra legroom? What if a customer wants their seat unassigned to avoid the fee? Is it really helpful to a customer to see “fees of $0-$100 to select a seat may apply”? Bag fees can vary by status, destination, fare bundle, etc. The hard part about making fees “transparent” or like a “menu” is that airlines are not all offering the exact same items at flat prices. I applaud the DOT for trying to find ways… Read more »
jonathan reed
On some airlines the seat fee just gets you an assigned seat. This has two advantages. Say you and a companion are travelling together. With assigned seats you sit together. Without assigned seats on a full flight both of you probably end up in middle seats in different locations. If you are travelling by yourself the assigned seat lets you pick an aisle or window rather than getting stuck in a middle seat. Air Canada Rouge, a downscale offshoot by Air Canada with most seats having a knee-busting 29″ pitch, for one price will sell you an assigned seat and… Read more »
I chuckle. I’m actually reading this notice of proposed rulemaking. As to others reading it, my guess is that they too, grew up collecting airline timetables. Probably subscribed to ATPCO tariffs, too. Whatever! Have at it, DOT, but I still don’t understand why we have to enlist a separate govenrmental group to do all this stuff to “enhance protections for air travelers and to improve the air travel environment” when we already have an agency, the FTC, that handles this for most if not all of the rest of the industries in this county. Give them the the statutory authority.… Read more »

I have to disagree with you about not requiring all-inclusive fares. I think that a fare should include first and second bag fees, meals, seat assignment, carry-on, non-alcoholic drinks, oversize for the seat fees, etc. This feeing people to death needs to stop, an all-inclusive fare would be a step forward in the airline industry.


Mharris, the product you are asking for exists: First class. It has every service that you’ve demanded at a fair market price and everything is included.

Nick Barnard

Maybe airlines need to sell first class tickets that are assigned in coach for MHarris.. just like they do the other way around..


And when do we apply taxes to some of these fees? Splitting things out from the base fare, and selling them as a la carte items with fees that aren’t taxed, is a form of tax avoidance.

Frank of America
Putting fees upfront in the buying process is just a matter of programming. In my view airlines should disclose all fees before the ticket is purchased as well as the total cost of the ticket including tax. If they want to show the tax as a separate line item that’s fine. Show everything as a separate line item, including fuel surcharges, various “Q” charges – everything. And tell us what they’re for! As a corporate travel director, having ancillary products available for sale in the GDS so they show up to a corporate travel agent and also in our online… Read more »

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Looking forward to the time when airlines link up with booking websites to provide premium seat pricing on available seats. Every day passengers arrive at the airport with seat numbers printed on their itineraries that they didn’t know they had to pay extra for so they don’t really have a seat. This can be a disaster for passengers who check in after all the seats are assigned on an oversold flight.

Bill Hough

I support any rules that make it easier to calculate the total cost of a flight which is what the customer is actually interested in. A few years ago, airlines started low-balling the fare but tacking on fees for basically everything. This is dishonest advertising and should be stopped. Failing that, full disclosure should be regulated by DOT. And the customer should not have to plow through pages of incomprehensible legaleze on a web site to know what the total cost will be. Airlines do this because it makes it difficult to comparison-shop.


[…] Flier reviewed DOT’s plans for making airline fees more transparent, even on third party aggregator sites like Kayak and Google Flights. Today he went back to those […]


[…] END IS NEAR: Fascinating stuff from Cranky Flier via View From the Wing! Apparently the airlines have raised enough of a fuss over being forced to […]