ACAA vs EU261: Disabled Passenger Rights on International Flights

ACAA EU261 disabled passenger rights on international flights involve three independent frameworks that apply simultaneously and stack. (1) ACAA (Air Carrier Access Act) and 14 CFR Part 382 cover US flights and US-handling carriers, including foreign carriers operating to or from the US. (2) EU Regulation (EC) 1107/2006 covers EU airports and EU-carrier flights, providing mobility assistance and accessibility rights. (3) EU261 provides general delay, cancellation, and denied boarding compensation independent of disability status. Wheelchair passengers on a transatlantic trip have rights under all three simultaneously. Stacking: ACAA mobility assistance on the US legs, EU 1107 mobility assistance on the EU legs, EU261 cash compensation on EU-departing legs, and Montreal Convention damage liability on any international leg.

ACAA, EU 1107, and EU261 are independent frameworks that stack on transatlantic flights. Wheelchair passengers have rights under all three simultaneously.

ACAA (49 USC 41705) and 14 CFR Part 382 apply to US carriers and to foreign carriers operating to or from the US. Coverage includes: mobility assistance throughout the airport experience (gate to aircraft, jet bridge, in-cabin, deplaning, baggage claim), priority rebooking on delays and cancellations, escort or attendant assistance, accessibility of in-flight entertainment, accessible lavatories on aircraft over 60 seats, and damage liability for mobility devices. Enforcement: DOT complaints at transportation.gov/airconsumer with civil penalties up to USD 27,500 per incident or higher for repeat or systematic violations. See ACAA rights for US passengers with disabilities and wheelchair passenger flight delay: extra rights under ACAA.

EU Regulation (EC) 1107/2006 (Persons with Reduced Mobility) covers passengers with reduced mobility on EU airports and EU-carrier flights. Coverage: assistance from arrival at the EU airport through to the aircraft and onward at destination, no charge for mobility assistance, special service request (SSR) coordination through the booking system, accessibility of airport facilities, and damage liability for mobility devices. Enforcement: complaints to the airport authority or the relevant national enforcement body (CAA in UK, DGAC in France, etc.). The framework is more procedurally consistent across EU member states than ACAA's US implementation. See EC 1107/2006: European disability air travel rules and disability and medical flight rights 2026 guide.

EU261 provides cash compensation, refund rights, and duty of care on EU-departing flights and EU-carrier flights to or from the EU. The compensation is the same for wheelchair passengers as for any other passenger: EUR 250 to 600 per passenger for delays, cancellations, and denied boarding. Disability-specific issues (mobility assistance failures, wheelchair damage, accessibility refusals) are not covered under EU261 directly. They run under EU 1107/2006. The two frameworks are independent and stack on the same disruption: EU261 cash plus EU 1107 mobility assistance plus EU 1107 damage liability.

EU261 is disability-independent. It provides the same cash compensation to wheelchair passengers as to any other passenger. The disability-specific protections come from EU 1107/2006, separately and additionally.

On a typical transatlantic trip with mobility assistance involved, the three frameworks stack. Example: JFK to LHR round trip on Delta-marketed Virgin Atlantic-operated flights, the LHR to JFK return cancelled. The wheelchair passenger has: ACAA mobility assistance on the US leg (JFK departure, JFK arrival), EU 1107 mobility assistance on the UK leg (LHR departure, LHR arrival under EU equivalent UK framework), UK261 cash compensation against Virgin Atlantic for the cancelled UK-departing return (GBP 520 long-haul), US DOT cash refund against Delta for the marketing carrier role, Montreal Convention Article 17 damage liability for any wheelchair damage on international carriage. Total recovery on a single disruption with no damage: GBP 520 plus the ticket value back. Total recovery with wheelchair damage: GBP 520 plus the ticket value plus full repair or replacement under Montreal Convention. See acaa rights for US passengers with disabilities.

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  Mobility assistance scope: ACAA covers gate-to-aircraft and onward; EU 1107 covers from arrival at airport.

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  Notification requirements: EU 1107 explicitly requires SSR notification 48 hours before departure; ACAA is more flexible but recommends similar advance notice.

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  Damage liability cap: ACAA defers to Montreal Convention or domestic baggage caps but DOT enforcement pressure pushes voluntary higher payouts; EU 1107 defers to Montreal Convention or equivalent.

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  Enforcement infrastructure: ACAA enforced through DOT with civil penalties; EU 1107 enforced through national bodies with varying penalty regimes by member state.

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  Cash compensation: EU261 provides EUR 250 to 600 fixed cash on disruptions; ACAA does not have a separate cash compensation mechanism beyond the DOT refund rule.

1. 1

   Document the disruption with timestamps, photos, witness names, and any mobility assistance failures.

2. 2

   If wheelchair damage occurred, file the PIR at the airport before leaving.

3. 3

   Identify operating and marketing carriers from boarding pass and e-ticket.

4. 4

   File US DOT cash refund directly with the marketing carrier (the airline that sold the US-handled ticket).

5. 5

   File EU261 or UK261 cash compensation directly with the operating carrier on EU/UK-departing legs.

6. 6

   File ACAA complaint at transportation.gov/airconsumer for any US-leg mobility assistance failures or wheelchair damage on US-handling.

7. 7

   File EU 1107 complaint with the relevant national enforcement body (CAA UK, DGAC France, etc.) for EU-leg mobility assistance failures.

8. 8

   File Montreal Convention Article 17 damage claim against the operating carrier for any wheelchair repair or replacement.

9. 9

   Track all deadlines independently: 7 business days (US DOT credit card refund), 21 days (Article 31 notice), 2 years (Article 35 court action).

10. 10

    Stack with travel insurance and credit card mobility device coverage where applicable.

For the disability rights pillar, see disability and medical flight rights 2026 guide. For the broader business travel pillar, see business travel flight disruption compensation. Start a claim with TravelStacks for a flat fee.

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  Filing only EU261 and missing ACAA: misses the US-leg disability protections and any wheelchair damage liability.

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  Filing ACAA complaint and assuming it covers cash compensation: ACAA does not provide the EUR 250 to 600 cash compensation. EU261 does. File both.

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  Filing against the wrong carrier: EU261 against operating, US DOT against marketing. The framework determines respondent.

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  Missing the Article 31 notice on wheelchair damage: 7 days for damage, 21 days for delayed or lost mobility device. File the PIR immediately.

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  Settling for a depreciated baggage formula on wheelchair damage: most carriers pay full repair or replacement on wheelchairs voluntarily because of DOT enforcement pressure. Reject the formula in writing.