May 12, 2026
By issuing Determination A-2026-31, the Canadian Transportation Agency (“Agency”) has introduced some crucial changes to how domestic and international air carriers shall comply with tariff-related obligations under the Canada Transportation Act (“CTA”) and the Air Transportation Regulations (“ATR”).
Key Exemptions Granted
The Determination provides two notable exemptions applicable to all carriers, ensuring competitive neutrality across the Canadian aviation sector:
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International services: Air carriers are no longer required to file tolls (fares, rates, and charges) with the Agency.
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Domestic services: Air carriers are no longer required to publish tolls on their websites.
These changes signal a shift away from centralized filing and publication requirements, allowing air carriers greater flexibility in how pricing information is managed and disseminated, while ensuring accountability and keeping consumers informed.
Continued Tariff Obligations
Despite these exemptions, the Agency declined to relieve carriers from the requirement to set out tolls in their tariffs for both domestic and international services, recognizing the obligation remains critical for consumer protection and regulatory oversight. To comply, air carriers must continue to:
- Maintain a tariff that includes all applicable tolls and related terms and conditions in compliance with Part V, Division I of the ATR for domestic services and Part V, Division II of the ATR for international services;
- Apply the tolls set out in their tariffs to their services;
- Ensure tariffs are available for public inspection, including tolls, in accordance with applicable CTA and ATR; and
- File general terms and conditions of carriage for international services with the Agency, in compliance with Part V, Division II of the ATR.
Practical Implications for Carriers
With the removal of international toll filing requirements with the Agency, air carriers must now clearly identify where their tariff information will be maintained. This can include:
- Air carrier’s internal pricing management systems; or
- Third-party platforms such as Airline Tariff Publishing Company (“ATPCO”) or International Air Transport Association’s (“TACT”) system.
Air carriers must notify the Agency of their chosen approach. Additionally, depending on the storage method adopted, air carriers will be required to update or file related documentation (e.g., powers of attorney, concurrences, or tariff advice etc.) to remain compliant with the ATR.
Tariffs, both domestic and international, must also be amended to reflect where toll information is maintained, including updates to general terms and conditions of carriage.
Transition and Compliance
The Agency has indicated that it will work collaboratively with ATPCO and TACT during the transition period. Further guidance is expected from the Agency, particularly as coordination continues with tariff distribution systems.
