Web Accessibility Content Guidelines

By Minh Vu and Paul Kehoe

As we reported earlier this month, the Department of Transportation (DOT) issued regulations under the Air Carrier Access Act (ACA) making it easier for airline passengers with disabilities to access both airline websites and terminal kiosks.  These regulations provide a window into the Administration’s view of website and kiosk accessibility, and likely serve as a precursor to forthcoming regulations from the Department of Justice (DOJ) on these subjects for state/local governments and public accommodations.  Since all agencies have an opportunity to review proposed regulations during the interagency review process, we assume that DOJ had input into the new DOT rules.  Here is a closer look at key parts of the new DOT regulations:

Basic Website Requirements.  Airlines that operate at least one aircraft having a seating capacity of more than 60 passengers must make their primary website accessible in two phases.  First, by December 12, 2015, they must ensure that web pages on their primary website associated with core travel information and services (reservations, online check-in, flight status updates, itinerary access, frequent flyer account access, carrier contact information, etc.) conform with WCAG 2.0 Level AA.  Second, by December 12, 2016, all other webpages on the airline’s primary website must conform with these guidelines. The regulations also require airlines to consult with individuals with visual, auditory, tactile and cognitive disabilities, or organizations representing these disability types to test the usability of the updated websites.  The DOT did not indicate what, if anything, covered airlines should be doing to facilitate access for those individuals who cannot use the websites in the meantime.

The regulations also require airlines to provide web-based fare discounts, which are generally offered at a lower cost, and other web-based amenities, to customers with disabilities who are unable to use the airline’s website.  Also, ticket agents that are not small businesses will be required to provide the same web-based fares to customers with a disability who cannot use the agents’ website as of June 10, 2014.
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By Minh N. Vu

Last week, the Department of Transportation (DOT) issued final regulations that govern the websites and automated kiosks of U.S. and foreign air carriers.  The regulations have not yet been officially published in the Federal Register but we wanted to get the news (and the regulations) to you as soon as possible.