The Airline Website That Failed 34 of 38 Accessibility Checks
What is the Air Carrier Access Act (ACAA)? The Air Carrier Access Act is the US federal law that requires airlines operating at least one aircraft with..
What is the Air Carrier Access Act (ACAA)?
The Air Carrier Access Act is the US federal law that requires airlines operating at least one aircraft with more than 60 passenger seats – and any foreign carrier marketing air transport to US consumers – to make their public-facing website meet WCAG 2.0 Level AA. The Department of Transportation enforces it with per-violation civil penalties capped at $37,377 per violation.
Video: The Airline Website That Failed 34 of 38 Accessibility Checks
Of 38 WCAG criteria evaluated in the Vueling Airlines enforcement case, only 4 were met. Spain’s National High Court confirmed the €90,000 fine in 2024, noting that “the degree of non-compliance remained practically the same as in 2016.”
Vueling spent eight years fighting that ruling and lost. The court record shows what 26 failed WCAG criteria look like when they become a wall blocking disabled travellers from booking a flight. The same failures now carry enforcement risk on both sides of the Atlantic for any travel site taking bookings.
What Happened: The Vueling Airlines Ruling
The case began in 2016, when Spain’s national disability authority first inspected Vueling’s website and found it substantially inaccessible. A resolution followed, imposing a €90,000 fine and a six-month ban on competing for government contracts.
Vueling appealed. In 2024, the Audiencia Nacional – Spain’s National High Court – dismissed that appeal and confirmed the original penalty. The court’s finding was blunt: eight years after the first inspection, the site had barely changed.
The audit breakdown from the court record: of 38 WCAG criteria evaluated, 4 were met (10.5%), 26 failed (68.4%), and 8 were not applicable (21.1%). Net result: Vueling satisfied only 4 of the 30 criteria that actually applied to its site.
The practical consequence was that users relying on keyboard navigation or a screen reader could not independently book a flight, select a seat, check in, or manage a reservation.
Can Airlines Be Fined for Inaccessible Websites?
Yes. Under the ACAA, the Department of Transportation can fine airlines up to $37,377 per violation for inaccessible websites. In the EU, the European Accessibility Act came into force on June 28, 2025, requiring any business with 10 or more employees or €2M or more in turnover selling into EU markets to meet WCAG 2.1 AA, with national penalties reaching €250,000 in France and €200,000 in Sweden. The Vueling case produced a confirmed €90,000 penalty. The DOT’s 2018 consent order against Scandinavian Airlines (SAS) produced a $200,000 fine. That SAS case matters beyond the number: DOT fined the airline specifically for creating a separate accessible website rather than fixing the primary one, calling that approach a perpetuation of unequal access. Any business still treating a parallel “accessible version” as a viable workaround should treat the SAS outcome as a direct answer.
What 26 Failed Checks Look Like Inside a Booking Flow
Here is what abstract WCAG criteria become when a real user tries to book a flight.
SC 2.1.1 – Keyboard: Flight date pickers and seat selectors were drag-and-click controls only. A keyboard user could not open the calendar, navigate to a date, or reach the seat map. The seat map itself was a static image, not a navigable element.
SC 1.3.1 / SC 3.3.2 – Info and Relationships / Labels: Passenger detail fields, passport inputs, and payment fields lacked programmatic <label> associations. A screen reader announced each one as “edit text” with no context about what the field was for. The same pattern, unlabeled controls that leave assistive technology with nothing useful to announce, is covered in Meaningful Link Text: Stop Writing Click Here.
SC 1.4.3 – Contrast Minimum: Fare class labels, disabled calendar dates, and inline error messages failed the 4.5:1 contrast ratio. For a user with low vision, validation errors were effectively invisible.
SC 1.1.1 – Non-text Content: Icons used as the sole indicator for baggage rules and fare alerts carried no alt text or ARIA label. Blind users received no information about conditions that directly affected their booking.
Every failed check maps to a moment where a user hit a dead end and could not continue without sighted assistance.
Five Booking-Flow Checks Every Travel Site Should Run Today
These apply to any travel or booking website, not just airlines.
Date picker keyboard access. Can a keyboard-only user open the calendar, navigate to a date, and confirm a selection without a mouse? (SC 2.1.1)
Form field labels. Does every input in your booking or checkout flow have a visible <label> element programmatically linked to the field, not placeholder text that disappears on focus? (SC 1.3.1, SC 3.3.2)
Seat or product selector coding. Are interactive selection components coded as accessible tables or list elements, not static images? (SC 1.3.1)
Error message text. When a booking form fails validation, does the error appear as visible, specific text rather than a color change or an icon alone? (SC 3.3.1)
Icon-only labels. Do any icons (baggage class, fare type, seat features) carry meaning without an accessible text alternative? (SC 1.1.1)
Run a free website accessibility checker against your booking pages to surface missing labels, contrast failures, and missing alt text automatically, then use this list to prioritize the interactive fixes automated scanning cannot reach.
The Vueling timeline is the clearest available data point: first inspection in 2016, fine confirmed in 2024, only 4 of 38 criteria met throughout. Eight years of deferred fixes ended in a court-confirmed penalty and a public record of failure.
With the EAA enforceable across the EU since June 28, 2025, and DOT enforcement active under the ACAA, the “future problem” framing no longer holds. According to UsableNet’s 2025 Year in Review, approximately 3,117 federal web accessibility lawsuits were filed in 2025, a 27% increase over 2024, with total cases exceeding 5,000 when state court filings are included.
