What are the APPR?
The Air Passenger Protection Regulations, SOR/2019-150, are federal regulations that establish minimum obligations for airlines when certain things go wrong during air travel. They were created under the Canada Transportation Act, came into force in stages in 2019, and were amended in 2022 to add refund rights for delays and cancellations outside an airline's control.
The Regulations currently remain organized around three categories of flight disruption: within the airline's control, within its control but required for safety, and outside its control.
The APPR is not an optional insurance program or compensation scheme that passengers have to purchase. Under subsection 86.11(4) of the Canada Transportation Act, the obligations created by the Regulations are deemed to form part of the terms and conditions in an airline's tariff unless that tariff gives passengers more advantageous rights. Section 2 of the APPR generally makes the carrier operating the affected flight responsible for the obligations in sections 7 to 22 and 24. If the applicable tariff provides more favourable obligations on the same matter, the passenger gets the benefit of those more favourable terms.
The Supreme Court of Canada upheld the APPR compensation scheme in International Air Transport Association v. Canada (Transportation Agency), 2024 SCC 30. The Court described APPR payments as "statutory entitlements under a consumer protection scheme" rather than individualized damages.
A passenger seeking standardized APPR compensation does not have to prove that the disruption caused $400, $700 or $1,000 worth of actual harm. The statutory conditions for the particular entitlement must still be established.
What do the Air Passenger Protection Regulations cover?
The APPR addresses much more than cash compensation.
It includes rules for tarmac delays, including food, water, ventilation, working toilets and communication while passengers remain on board. At a Canadian airport, passengers generally must be given an opportunity to disembark after three hours, subject to exceptions including where take-off is likely within three hours and 45 minutes and the required treatment can continue.
The Regulations also require airlines to provide information about delays, cancellations and denied boarding, including the reason for the disruption, possible compensation, applicable standards of treatment and available recourse. During a flight delay, status updates must generally be provided every 30 minutes until a new departure time is set or alternate travel arrangements have been made.
For qualifying delays and cancellations within the airline's control, including those required for safety, standards of treatment can include reasonable food and drink, communication and, where an overnight wait is expected, hotel or comparable accommodation and transportation to and from it.
Rebooking and refund rights apply more broadly, although the exact rules depend on the category of disruption.
The APPR also regulates denied boarding. Where the applicable rules apply, the airline must first ask for volunteers before involuntarily denying boarding and must give boarding priority to specified passengers, including unaccompanied minors, passengers with disabilities and passengers travelling with family members. Qualifying involuntary denied boarding can also trigger standardized compensation.
Other provisions require airlines to facilitate seating children under 14 near a parent, guardian or tutor without an additional charge, with the required degree of proximity depending on the child's age. The APPR also contains rules for lost, delayed and damaged baggage and requires airlines to establish tariff terms governing musical instruments.
The APPR applies broadly to flights to, from and within Canada, including connecting flights in qualifying circumstances. It does not replace other legal regimes that may apply to the same journey, including the Montreal Convention for international carriage.
APPR compensation amounts, large and small airlines
A large airline carried two million or more passengers worldwide in each of the past two years. Air Canada, WestJet, Porter, Air Transat and Flair are large. Everyone else is small.
Carrier status can change, so passengers should check the carrier's current status rather than relying on this list of airline names.
Delay and cancellation, section 19. Where the disruption is within the carrier's control, is not required for safety, and the other statutory requirements are satisfied, compensation is based on how late the passenger arrives at the destination shown on the original ticket:
| Arrival delay | Large airline | Small airline |
|---|---|---|
| 3 to under 6 hours | $400 | $125 |
| 6 to under 9 hours | $700 | $250 |
| 9 hours or more | $1,000 | $500 |
If the disruption otherwise qualifies for section 19 compensation and the passenger's ticket is refunded under subsection 17(2), section 19(2) instead provides minimum compensation of $400 for a large carrier or $125 for a small carrier.
A refund does not automatically create that compensation entitlement. The underlying disruption must still satisfy the conditions in section 12.
Denied boarding, section 20. Where the denied boarding falls within section 12—that is, it is within the carrier's control and not required for safety—the compensation is $900 if the passenger arrives less than six hours late, $1,800 for six to under nine hours, and $2,400 for nine hours or more.
These amounts do not vary according to whether the carrier is large or small. Compensation must be provided as soon as operationally feasible and no later than 48 hours after the denial of boarding.
Baggage, section 23. Baggage compensation works differently. It is not a flat APPR payment.
If the carrier admits the baggage is lost, the baggage remains lost for more than 21 days, or it is damaged, section 23 requires compensation equal to or greater than the applicable baggage fee plus the amount payable under the Carriage by Air Act or, where that Act does not apply, the amount that would be payable under the Montreal Convention framework incorporated by the Regulation. Temporary baggage loss of 21 days or less is also covered.
The current Montreal Convention baggage liability limit is 1,519 Special Drawing Rights per passenger. That is a liability ceiling for proven loss, not an automatic lump-sum payment, and its Canadian-dollar equivalent changes with exchange rates.
Compensation under sections 19 and 20 is assessed per passenger. A claim involving several passengers must properly include each passenger whose entitlement is being pursued, although passengers may in some processes authorize another person to act for them.
When monetary compensation is required under the APPR, section 21 requires payment in money unless the airline offers another form with a greater monetary value, tells the passenger its monetary value in writing, ensures it does not expire, and the passenger confirms in writing that they understand their right to money and nevertheless choose the alternative.
When you are eligible, and the exceptions
For standardized delay or cancellation compensation under section 19, four issues usually matter.
First, the disruption must fall within section 12: it must be within the carrier's control and not required for safety.
Second, the passenger must have been informed of the qualifying delay or cancellation 14 days or less before the departure time shown on the original ticket.
Third, where the passenger travels to the destination, arrival at the destination shown on the original ticket must be delayed by at least three hours. A separate reduced compensation provision applies where a qualifying disruption results in a refund under subsection 17(2).
Fourth, the passenger must submit the compensation request to the carrier before the first anniversary of the delay or cancellation.
Section 11 deals with disruptions that are within the airline's control but required for safety. The definition includes requirements imposed by law to reduce risks to passenger safety and certain safety decisions made by pilots or under an airline's safety management system. A qualifying mechanical malfunction can fall into this category.
Standardized section 19 compensation is not payable, but other obligations—including standards of treatment and alternate travel arrangements or refunds—can still apply.
Scheduled maintenance undertaken in compliance with legal requirements is expressly excluded from the definition of "required for safety purposes."
Section 10 deals with events outside the carrier's control. Examples include qualifying weather conditions, air traffic control instructions, airport operation issues, security threats, medical emergencies, collisions with wildlife, certain labour disruptions, manufacturing defects identified by the manufacturer or competent authority, and orders or instructions from state or law-enforcement officials.
Standardized section 19 compensation and section 14 standards of treatment generally do not apply to these disruptions, but the airline still has alternate-travel and refund obligations under section 18.
Earlier disruptions can also affect later flights. If the carrier relies on an earlier outside-control event under subsection 10(2), the later disruption must be directly attributable to the earlier one and the carrier must have taken all reasonable measures to mitigate its impact. Section 11 contains a similar rule for earlier safety-related disruptions.
Simply describing a later cancellation or delay as a "knock-on" effect does not end the analysis.
In a complaint to the Canadian Transportation Agency, there is now an important statutory presumption. If the dispute is about whether the delay, cancellation or denial of boarding was within the carrier's control, required for safety or outside its control, the event is presumed to have been within the carrier's control and not required for safety unless the carrier proves otherwise.
That statutory burden applies to the CTA complaint process. It should not automatically be assumed to govern every provincial court or tribunal proceeding.
Does the APPR apply to international travellers and foreign airlines?
Yes. The APPR applies broadly to flights to, from and within Canada regardless of whether the operating carrier is Canadian or foreign.
A Lufthansa flight from Frankfurt to Vancouver, for example, is within the regime's geographic scope.
Connecting flights entirely outside Canada require a little more care. An outside-Canada connecting segment may still fall within the APPR where it forms part of a single through fare connected to travel to or from Canada and the applicable operating-carrier relationship satisfies the required criteria.
Separate foreign flights assembled into an itinerary by a travel seller are not automatically brought within the APPR simply because another ticketed flight touches Canada.
For international carriage, the Montreal Convention may operate alongside the APPR.
The Supreme Court of Canada held in 2024 that standardized APPR compensation is not an "action for damages" under Article 29 of the Convention. That means APPR statutory compensation and Montreal Convention damages are conceptually different remedies.
The Convention may govern proven losses caused by international delay, such as qualifying accommodation or replacement-transportation expenses, subject to its own conditions, defences and limits.
Other passenger-rights regimes can also overlap. Subsection 3(3) of the APPR says an airline cannot refuse APPR compensation merely because the passenger is also eligible for compensation under another passenger-rights regime.
However, subsection 86.11(3) of the Canada Transportation Act prevents a passenger from receiving APPR compensation for the same event after compensation has already been received under another passenger-rights regime.
How to file an APPR compensation claim
- Preserve the evidence. Save the airline's emails, text messages and app notifications, and make a record of every reason it gives for the disruption. Keep the booking confirmation, boarding pass, actual arrival time and receipts for relevant expenses.
- Make the claim to the airline. For section 19 delay or cancellation compensation, the request must be submitted before the first anniversary of the disruption. State the flight, date, booking information, arrival delay, legal basis and amount claimed for each passenger. We recommend sending the claim in writing by registered mail or another trackable delivery method to an appropriate published address for the carrier. Keep a complete copy of the letter, every enclosure, the tracking record and proof of delivery. This creates a clear record of what was claimed and when the airline received it.
If you use an online claim form instead, save screenshots or a PDF of the submission, the confirmation number and every acknowledgment.
- Allow the airline 30 days to respond. Section 19(4) requires the carrier, within 30 days after receiving the compensation request, either to provide the compensation or explain why it is not payable. Keep the response. If the airline does not respond, keep the proof showing when the request was delivered and when the 30-day period expired.
- Decide whether to escalate. If the claim remains unresolved, one option is a complaint through the Canadian Transportation Agency's air-travel complaint process. Depending on the province and the nature and amount of the claim, a provincial court or civil tribunal may provide another route. In British Columbia, for example, the BC Court of Appeal confirmed in Air Passenger Rights v. WestJet Airlines Ltd., 2026 BCCA 357 that the Civil Resolution Tribunal can adjudicate APPR compensation disputes within its statutory jurisdiction.
Choose the forum deliberately. Different forums have different procedures, evidentiary rules, remedies, timelines and cost consequences.
What if the airline rejects your APPR claim?
Start with the reason the airline actually gives.
Common disputed classifications include assertions that the disruption was outside the carrier's control, was required for safety, or resulted from an earlier outside-control or safety-related event. Each has a specific legal framework under sections 10 to 12.
Ask the airline in writing to identify the specific cause of the disruption, when that cause arose, and the factual basis for the classification. Where an earlier disruption is relied on, ask how it was connected to your flight and what reasonable measures the airline took to mitigate its impact.
Preserve every explanation. If the reason changes between the airport, the compensation response and later proceedings, the different explanations may become relevant evidence.
If you file a CTA complaint, the statutory presumption in subsection 85.07(2) applies: the disruption is presumed to have been within the carrier's control and not required for safety unless the airline proves otherwise.
The current CTA process also requires complaint resolution officers dealing with the same flight to take prior decisions about that flight's disruption classification into account.
A CTA complaint can result in an order for compensation, a refund or qualifying reimbursement. The Agency currently warns that, because of complaint volume, it may take more than 24 months before a complaint is reviewed and assigned. Once a Start Notice is issued, the formal process is subject to a 90-day decision period.
The 2022 and 2023 amendments and what changed
September 2022. The APPR was amended to add refund rights for delays and cancellations outside the airline's control.
Under section 18, the carrier must first attempt the prescribed rebooking. If it cannot provide the initial required rebooking within 48 hours of the original departure time, the passenger obtains a choice between further alternate travel arrangements and a refund.
Separate refund rights already apply to within-control and safety-related disruptions under section 17 where the alternate arrangements offered do not accommodate the passenger's travel needs.
Required refunds are generally due within 30 days.
September 2023. Amendments to the Canada Transportation Act created the current air-travel complaint-resolution system.
Complaint resolution officers now handle eligible complaints, optional mediation can occur during the formal process, and unresolved complaints can proceed to a confidential and binding decision.
The legislation also created the statutory burden of proof described above for disputes about the cause of a disruption.
The 2023 amendments also require a system for recovering complaint-processing costs from airlines, but the particular fee proposed by the CTA has gone through a separate consultation process. It should not be described as though a fixed per-complaint airline fee is already necessarily being charged under the proposal.
Proposed changes. The federal government and CTA have consulted on substantial further changes to the passenger-protection regime, including a move away from the present three-category structure toward a narrower list of exceptions to compensation.
Those proposed regulatory changes are not yet reflected in the APPR currently in force. This guide describes the law currently in force, not the proposed replacement regime.