APPR changes: what's in force, what's proposed, and what it means for your claim

The Air Passenger Protection Regulations in force are the 2019 rules as last amended on September 8, 2022. Two further changes are proposed but not in force: draft amendments published in the Canada Gazette on December 21, 2024, which would narrow the exceptions that excuse compensation, and Bill C-31, which would move air travel complaints to the Minister of Transport. Until they take effect, claims use the current rules. Last checked October 17, 2026.

Whether your own flight qualifies depends on its details: the reason the airline gave, how late you reached your destination and how much notice you had. Check it free at landedlate.ca/check.

Status check

ItemStatus on October 17, 2026
Official text of the regulationsCurrent to September 30, 2026; last amended September 8, 2022
December 2024 draft amendmentsProposed. No final version found in Canada Gazette Part II
Bill C-31At committee stage in the House of Commons; no third reading, no royal assent
Complaint backlogAbout 98,000 (The Canadian Press, September 2026); the agency's last published figure was 84,398 at March 31, 2025
Confidentiality of agency complaintsBy October 5, 2026 the agency said a complaint that goes to a decision is on the public record; mediation stays confidential

Changes in force

  1. Most of the Air Passenger Protection Regulations take effect, including communication during disruptions, tarmac delays, being bumped (compensation and rebooking), and lost or damaged baggage.

    SOR/2019-150, s. 46(1)

  2. The rest take effect: food, drink and hotels during delays (section 14), the $400 to $1,000 compensation for delays and cancellations (section 19), the rebooking and refund rules for delays and cancellations (sections 17 and 18, held back until this date), and seating children near a parent (section 22).

    SOR/2019-150, ss. 34(2) and 46(2)

  3. Refunds for disruptions outside the airline's control: if it can't rebook you within 48 hours, you can choose a refund. Refunds must be paid within 30 days.

    SOR/2022-134

  4. The 2023 amendments to the Canada Transportation Act (Bill C-47, royal assent June 22, 2023) take effect: a streamlined complaint process, and in a complaint a disruption is presumed to be within the airline's control and not required for safety unless the airline proves otherwise (section 85.07(2)). The compensation changes need amended regulations to take full effect.

    S.C. 2023, c. 26, ss. 459 and 474(1)

Proposed or pending, not in force

  1. · draft amendments

    Published for comment in Canada Gazette Part I. The draft would list, exhaustively, the exceptional circumstances that excuse compensation, and they would excuse it only if the disruption couldn't have been avoided even with all reasonable measures. It would also give bumped passengers at least the lowest compensation amount even without a delay at arrival, unless an exceptional circumstance caused it, let passengers choose a refund once a delay reaches 3 hours without first waiting for rebooking, require refunds within 15 days, and require meals and hotels for up to 72 hours even when the cause is an exceptional circumstance such as weather.

  2. · Bill C-31 introduced

    According to the bill's own summary, the Budget 2025 Implementation Act, No. 2 would move responsibility for air travel complaints from the Canadian Transportation Agency to the Minister of Transport, let the government have complaints resolved by third parties, remove mandatory confidentiality, and raise the maximum penalty for corporations. The government has said fines for systemic breaches could reach $1 million. Part 4, Division 17 (the complaints changes) passed second reading in a separate vote on June 3, 2026. On October 17, 2026, LEGISinfo showed the bill at committee in the House of Commons, with no third reading or royal assent.

  3. · court ruling on confidentiality

    In Air Passenger Rights v. Attorney General of Canada (2026 ONSC 3983), the Ontario Superior Court of Justice read down the rule that keeps agency complaints confidential (section 85.09 of the Canada Transportation Act) so that it covers only mediation. The court suspended its order for 90 days from its July 8, 2026 reasons. As of October 17, 2026 we had found no appeal or further suspension, but couldn't confirm either way.

  4. · agency updates its confidentiality guidance

    The agency's page on complaint decisions, updated October 5, 2026, now says that if a complaint is resolved in mediation, what was filed stays confidential, but if it goes to a decision, the documents filed “will form part of the public record” unless the agency accepts a request to keep something confidential. The agency must also publish the flight number, the date, whether the cause was within the airline's control, and what was ordered (section 85.14). TravelPulse reported (in a story last updated October 7) that the agency plans to publish its decisions on its website every month starting in early 2027. If it does, rulings on your airline and your kind of disruption will be easier to find and cite in a claim.

What the draft would change for your claim

SituationRules in forceDecember 2024 draft
Cause outside the airline's controlAn open-ended category with examples (section 10)A closed list, and only if unavoidable with all reasonable measures
“Required for safety”Its own category: no compensation (section 11)The separate category goes, as the 2023 amendments to the Act require. Until new regulations are made, section 11 still applies
Meals and hotel when the cause is weather or similarNot required (section 10(3))Required, for up to 72 hours
Bumped from a flight$900 to $2,400, only if within the airline's control (section 20)At least the lowest amount, even if on time or refunded, unless an exceptional circumstance
Refund during a long delayAfter rebooking fails to suit you, or can't happen in timeYour choice once the delay reaches 3 hours
Refund deadline30 days (section 18.2)15 days

From the draft as published in Canada Gazette Part I. The final regulations may differ.

What to do now

Claim under the rules in force. Crew shortages, avoidable maintenance and vague “safety” reasons can already be challenged under today's rules. See the guides on crew shortages and weather, or run the five-question check. If the airline refuses, the complaint process in force is still the agency's: how to file a complaint.

Check a flight under today's rules

Questions

Are the new APPR rules in force?

No. The draft amendments published in the Canada Gazette on December 21, 2024 had not been made final as of October 17, 2026: we found no final version in Canada Gazette Part II, and the official consolidated text (current to September 30, 2026) still shows its last amendment as September 8, 2022.

Should I wait for the new rules before claiming?

No. Your claim must reach the airline before the first anniversary of the delay or cancellation (section 19(3)), and the rules that apply are the ones in force now. Claim under the current rules.

What would the December 2024 draft change?

It would replace the open-ended "outside the airline's control" category with an exhaustive list of exceptional circumstances that excuse compensation only if the disruption couldn't have been avoided with all reasonable measures. It would also give bumped passengers at least the lowest compensation amount even if they arrive on time, unless an exceptional circumstance caused it, let passengers choose a refund once a delay reaches 3 hours, require refunds within 15 days, and require meals and hotels for up to 72 hours even in exceptional circumstances. One listed exception is an unforeseeable technical defect, if strict conditions are met.

What is Bill C-31?

The Budget 2025 Implementation Act, No. 2, introduced May 6, 2026. According to the bill's own summary, it would move responsibility for air travel complaints from the Canadian Transportation Agency to the Minister of Transport, let the government have complaints resolved by third parties, remove mandatory confidentiality, and raise the maximum penalty for corporations. The government has said fines for systemic breaches could reach $1 million. On October 17, 2026, LEGISinfo showed it still at committee stage in the House of Commons (the finance committee met on it October 6 and 8), with no third reading and no royal assent, so the current complaint process still applies.

How big is the complaint backlog?

About 98,000 complaints, according to a Canadian Press report in September 2026. The agency's last published year-end figure was 84,398 at March 31, 2025, with 46,980 complaints received in 2024–25. The agency says it may take more than 24 months before an officer reviews a new complaint.

Sources

  1. Air Passenger Protection Regulations, SOR/2019-150 (Justice Laws: current to 2026-09-21, last amended 2022-09-08)
  2. Canada Gazette Part II: SOR/2022-134, Regulations Amending the Air Passenger Protection Regulations (June 22, 2022)
  3. Parliament of Canada, LEGISinfo: Bill C-47 (44th Parliament), Budget Implementation Act, 2023, No. 1
  4. Canada Gazette Part I: proposed Regulations Amending the Air Passenger Protection Regulations (December 21, 2024)
  5. Transport Canada (May 1, 2026): plan to clear the backlog of air travel complaints
  6. Bill C-31, first reading: summary of Part 4, Division 17 (Parliament of Canada)
  7. Parliament of Canada, LEGISinfo: Bill C-31 (45th Parliament), Budget 2025 Implementation Act, No. 2
  8. Canadian Transportation Agency: statistics 2024–2025
  9. The Canadian Press via BNN Bloomberg (September 24, 2026): backlog of about 98,000 complaints, Bill C-31 in committee
  10. Canadian Transportation Agency: complaints portal (wait may exceed 24 months)
  11. CBC News (July 9, 2026): court strikes down rule keeping complaint outcomes secret
  12. AHBL (August 25, 2026): the confidentiality ruling and its 90-day suspension
  13. Canadian Transportation Agency: information about air travel complaint decisions (modified October 5, 2026)
  14. TravelPulse Canada (last updated October 7, 2026): CTA responds to Ontario court confidentiality ruling

General information, not legal advice.