Refund of Airline Tickets to Air Passengers: Strengthening Accountability Under CAR Series M (Feb 2026)

 March 01, 2026

Thank you, DGCA.

Refund governance is where passenger trust is tested most visibly — not during booking or boarding, but during cancellation.

With the revised Civil Aviation Requirement (CAR), Series M, Part II dated 24 February 2026 — governing the “Refund of Airline Tickets to Passengers of Public Transport Undertakings” and effective 26 March 2026 — the Directorate General of Civil Aviation reinforces a critical principle:

Accountability must be unambiguous.

This revision is not dramatic.
It is disciplined.

1. Refund Timelines – Certainty with Defined Boundaries

The CAR provides clear refund timelines:

• In case of credit card payments, refunds must be processed within 7 days of cancellation.
• In case of cash transactions, refunds must be made immediately at the airline office where the ticket was purchased.
• Where tickets are booked through travel agents or online portals, the airline remains responsible and must ensure the refund process is completed within 14 working days.

These distinctions matter.

Refund processing involves airline accounting systems, payment gateway cycles, and, in intermediary bookings, additional coordination layers. By defining 7 days for direct credit card refunds and 14 working days where agents or portals are involved, the CAR acknowledges operational complexity while preserving regulatory certainty.

Defined timelines serve three purposes:

• They establish enforceable compliance benchmarks.
• They reduce interpretational flexibility in passenger communication.
• They create measurable expectations.

Without defined outer limits, refund interactions often drift into indefinite responses — “under process,” “awaiting reconciliation,” or “pending from bank.”

Timelines compress uncertainty.

In grievance-sensitive sectors, certainty is protection.

By distinguishing booking channels while keeping accountability anchored with the airline, the CAR balances operational reality with passenger clarity.

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2. Clause 3(c) – Anchoring Responsibility

Among the provisions, Para 3(c) carries particular operational weight.

It clarifies that when tickets are booked through travel agents or online portals, refund responsibility remains with the airline, since the agent acts as its appointed representative.

This addresses a common friction point.

During cancellations, passengers have often encountered directional deflection:

• The airline directs the passenger to the portal.
• The portal points back to the airline.

The passenger remains suspended between two entities.

While backend commercial agreements may be clearly structured, passengers rarely have visibility into those arrangements.

Clause 3(c) simplifies the outward accountability chain.

It does not alter internal settlement processes or agency contracts.

It defines responsibility at the passenger interface.

For the passenger, there is one accountable entity.
For the regulator, one compliance anchor.
For the airline, ownership is explicit.

In regulatory design, clarity of responsibility outweighs multiplication of obligations.

When accountability is singular, enforcement is cleaner.
Cleaner enforcement strengthens compliance.

Improved compliance reduces disputes.

This clause strengthens structural coherence in the refund ecosystem.

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3. Free Look-In – Defined Eligibility

The CAR continues the 48-hour Look-In option for eligible bookings, subject to departure-linked conditions.

Clear eligibility boundaries reduce interpretational disputes and unintended penalties.

The operational implications merit a separate discussion.

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4. Credit Shell – Consent Reaffirmed

Retention of funds in a credit shell must remain the passenger’s prerogative.

A refund is a financial entitlement.
Conversion into credit must be voluntary.

This framework deserves deeper analysis separately.

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5. Refund Break-Up Transparency

Airlines must clearly indicate the refundable amount and its components.

Upfront clarity reduces downstream friction.

This area too warrants granular examination later.

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Broader Context

In November 2025, I submitted a citizen note to DGCA outlining suggestions on refund clarity, Free Look-In communication, credit shell practices, and oversight visibility.

Regulatory refinement is institutional and multi-layered. It evolves through consultation, feasibility assessment, and legal calibration.

It is encouraging to see continued reinforcement of accountability in an area central to passenger trust.

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Conclusion

The February 2026 revision does not redesign the aviation ecosystem.

It clarifies it.

Responsibility is anchored.
Timelines are defined.
Consent is reaffirmed.
Transparency is strengthened.

In aviation governance, clarity is not cosmetic.

It is structural.

Thank you, DGCA.

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The Joy of Digital Transactions

Nayakanti Prashant
Citizen Advocate — Digital Transaction Day (April 11)

👉 https://movethebarrier.blogspot.com/April11