Docket ID No DOT-OST-2025-0831
Download this comment (PDF)
Introduction
On July 1, 2026, the US Department of Transportation (DOT) issued a Notice of Proposed Rulemaking titled Enhancing Flexibility of Air Fare Price Advertising. The proposed rule would weaken DOT’s Full Fare Rule4 (FFR) by eliminating the requirement that the total price be advertised more prominently than the components of the price. The proposed rule would also eliminate nine airfare price advertising guidance documents.
As an alternative to the proposed rule, DOT is also considering completely repealing FFR, which would allow airlines and ticket agents to advertise only the base fare upfront, and disclose taxes and fees separately.
Since FFR took effect in January 2012, it has benefited consumers by informing them clearly of the total price they have to pay for commercial airplane tickets. The rule has enabled consumers to make more informed choices when booking reservations. To the extent it undermines the existing FFR framework, the proposed rule would harm consumers, forcing them to spend more time comparing competing flight itineraries and causing many to pay more for the flights they ultimately purchase.
If implemented, the proposed changes would make it more difficult for consumers to identify the total price of an airline ticket, thus resulting in higher search costs and more buying mistakes. Yet the proposed rulemaking notice fails to recognize the harms to consumers from modifying or eliminating the FFR and makes no attempt to quantify them.
I recommend leaving the FFR unchanged, as well as any implementing guidance. The Full Fare Rule requires airlines and travel agents to state the total price, including taxes and fees, in their advertisements to consumers. The total price must be the first price that consumers see. The base fare, government taxes, and fees may be displayed separately as components of the total price, but only in a smaller font than the total price. Prior to FFR, airlines and travel agents could advertise the base fare first and disclose taxes and fees separately.