On December 21, 2024, the Canadian Government published comprehensive amendments to the Air Passenger Protection Regulations (APPR) in the Canada Gazette, Part I. Aiming to redesign the rights of airline passengers across the country, the proposed changes could be a major reform in Canada’s consumer rights framework. The new version seems to address endless complaints from travelers and aligns the country's standards more closely with global best practices, such as the European Union’s EC 261/2004.
As only a couple of months remain before its final version comes into effect, this article explores the background of Canada’s APPR, the content of the proposed regulatory amendments, what makes these changes significant, how they compare to EU rules, and what this means for the aviation sector and consumers in Canada and overseas.
Canada’s APPR were first introduced in two phases in 2019 under the enforcement of the Canadian Transportation Agency (CTA). The regulations aimed to standardize practices across airlines and enhance transparency around passenger rights.
However, the rules quickly came under fire. Critics highlighted ambiguities around compensation eligibility and a heavy reliance on sorting flight disruptions into three tiers:
Airlines often referred to the last two categories, mostly "safety", to avoid paying compensation. Consumer rights groups claimed the burden of proof was unfairly left on passengers’ shoulders and that the system lacked meaningful sanctions.
The COVID-19 pandemic further revealed the fault lines in the system, particularly around refunds. Airlines issued credits instead of refunds and often left passengers waiting months to get their money back. Public pressure for reform intensified steadily and urged the federal government to commit to legislative changes no later than 2022.
The proposed revisions mark a remarkable shift in the design and enforcement of passenger rights in Canada. Here are the key reforms:
Under the new rules, the previous three-tiered disruption categorization is put an end. Instead, a simplified and traveler-oriented approach is created as compensation is now required for all delays and cancellations within 14 days of departure, unless the airline can prove the event was caused by an “exceptional circumstance.”
This change is critical as it reverses the responsibility that previously discouraged many passengers from filing claims. Now, airlines carry the burden of demonstrating why a disruption should not trigger compensation.
The term “exceptional circumstance” has been defined to limit abuse. Now, it includes:
It will also be considered as an exceptional circumstance if the flight disruption was directly attributable to a delay or cancellation on an earlier flight using the same aircraft. However, in the case of a large carrier, the flight in question must be scheduled to depart within 24 hours of the scheduled departure time of that earlier flight.
Notably, the new demarcation puts pressure on carriers to better manage operations or face payouts since personnel shortages or mechanical failures are not considered “exceptional” any longer.
This echoes the reasoning lying beneath EU Regulation 261/2004, which also carves out exceptions for truly unforeseeable events and holds airlines accountable for most operational issues.
Under the proposed rules, airlines must provide meal vouchers, communications access such as Wi-Fi or phone calls, and hotel accommodation once a passenger is delayed by two hours or more, regardless of the cause of disruption. Be careful, however, as this does not apply if passengers are informed 12 or more hours before their original departure time.
For ongoing disruptions due to exceptional events, assistance obligations of airlines end after 72 hours, after which passengers can seek rebooking or refunds independently.
According to the recent changes, airlines must do the following even in cases deemed “exceptional”:
Here, law makers draw a firmer line between financial compensation, which can be avoided, and basic service obligations, which can’t.
Carriers must collect passengers’ preferred electronic communication method
This ensures that travelers are kept informed and enables them to exercise their rights.
As an endeavor to fulfil a 2024 federal budget commitment to make air travel more equitable for families, children aged 14 and under must be seated next to an accompanying adult at no additional cost.
In order to discourage airlines from violating the rules or engaging in prolonged disputes over passenger claims ,the CTA’s maximum penalty for non-compliance is set to increase tenfold, i.e. from $25,000 to $250,000 per violation. Repeaters will also be subject to public reporting and additional scrutiny.
Canada’s proposed regulations appear to echo the core structure of EU 261/2004, one of the world’s most robust passenger protection frameworks. Key similarities include:
| Feature | EU 261/2004 | Canada (Proposed) |
|---|---|---|
| Compensation eligibility | Delays more than 3 hrs, cancellations | Delays more than 3 hrs, cancellations |
| Exceptions | “Extraordinary circumstances” | “Exceptional circumstances” |
| Refund timeline | Prompt (no fixed days) | Within 15 days |
| Rebooking duty | Yes, same | Yes, on other carriers if needed |
| Child seating | Not covered by default | Required for under 14s |
| Fines | Varies by member state | Up to $250,000 CAD |
| Response time | No time limit specified for airlines | Airline’s must respond within 30 days |
| Burden of proof | On the airline | On the airline |
While the EU has more jurisprudence, particularly from the European Court of Justice, Canada's proposed rules show a decisive move to align with this gold standard (or even exceeding in some features) while also tailoring features to Canadian geography and regulatory culture.
To support the implementation and enforcement of these revised rules, the Canadian government allocated $76 million CAD over four years in its 2024 federal budget.
This includes:
The funding reflects a major institutional shift toward proactive enforcement, not just reactive response.
In Canada, where distances are vast and air travel is often essential, revised APPR framework could be a critical consumer protection tool.
With travel volumes bouncing back to pre-pandemic era and new challenges emerging such as climate disruptions, Canadians have repeatedly expressed frustration with airlines’ handling of delays, cancellations, and refunds. The updated regulations directly address many of those sore points:
The proposals were available for public comment until March 6, 2025. The final version of the regulations is expected to be published in Canada Gazette later in 2025. The measures are likely to come into force by late 2025 or early 2026.
Canada’s most recent makeover of its air passenger protection laws is not just regulatory maintenance, it represents a philosophical shift in how passenger rights are perceived and enforced. With a simplified system, stronger protections, and greater penalties, the new APPR could make Canada one of the leading countries for air travel fairness, transparency, and accountability. The new APPR probably won’t reduce the number of flight complaints, but it seems that passengers will no longer have to wait months for a decision after submitting a compensation claim for a delayed or cancelled flight.
As airlines, regulators, and passengers test the limits, it remains to be seen whether these reforms will hold up in practice. For now, though, Canada’s skies may be on the verge of becoming friendlier, fairer, and more predictable for millions of travelers.
We hope this article has helped clarify what Canada’s updated APPR mean and how they’re designed to give passengers stronger protections when dealing with airlines.
That said, flight disruptions aren’t going away. Even a short delay can disrupt your plans, let alone wasted hours at the airport or lost connections. Airlines are required to provide care and support in such situations but they don’t always make that easy.
That’s exactly why Click2Refund is here: we stay on top of the latest Canada’s APPR updates so you don’t have to, ensuring you know exactly what you can claim.
We take the stress out of the compensation process. Whether your flight was delayed, cancelled,or overbooked, we handle everything, including legal follow-ups. You just tell us what’s happened, and we do the rest.
✔ No-Win, No-Fee PromiseYou pay nothing unless we win your case. No upfront payments, no hidden fees.
✔ Fast and Simple ProcessFiling a claim takes just a few minutes. There are no long forms or confusing steps. With us, getting the compensation you deserve is just a quick and easy process
✔ Proven Track RecordWith a 98% success rate, we’ve helped passengers who were turned away by other services. Many were surprised at how easily we turned their cases around.
✔ Clear Communication, Real SupportOur clients appreciate how informed they feel throughout the process. Clear updates, responsive support, and no need to chase us for answers.
We also stay up to date on the latest air passenger protection rules, including recent changes to Canada APPR or EU Regulation 261. That means we know how to strengthen your case under the most current legal standards.
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