Booked via an agency, who owes you the refund

My agency says it is waiting for the airline, is that true?

Usually true about the cash, and irrelevant to the deadline. Question 13 of the Department of Transportation's Small Entity Compliance Guide for the refund final rule says a ticket agent must provide refunds within 7 business days or 20 calendar days of receiving a confirmation from the airlines that a refund is due, even if the funds are not yet returned to the ticket agent. Once the airline says a refund is owed, the clock runs on the agency whether or not it has been paid.

That is the sentence the standoff turns on, and nobody reads it out on the phone. The same question also obliges the airline to tell the agency without delay whether you are eligible, and to transfer your funds promptly if it is holding them. Neither is a condition on the agency paying you.

Two things have to be right first. The duty applies on request, not automatically, so waiting is not a strategy. And in most bookings the money is not with the agency at all.

The guide says on its face that it is not a regulation, and that the final rule prevails where they differ. Treat it as the Department's compliance guidance, which is still the clearest statement of the agent's own deadline it publishes.

How do I tell whether the agency or the airline has my money?

Read the name on your card statement for the ticket charge. That is the whole test. Question 12 of the guide defines a merchant of record as the entity responsible for processing payments by consumers as shown in the consumer's financial charge statements, and the Department's consumer refunds page says the same.

The merchant of record is the party that owes the refund. If the airline's name is on the charge, the agency was a booking screen and the refund is the airline's automatic duty. If the agency's name is on it, the agency owes you, on request.

The odds are not what the standoff implies. PIRG's account of the rule records the Department's figure that in 92 percent of cases the airline is actually the merchant of record. So the party arguing with you is usually not the party holding your money, and the faster demand is aimed at the airline. The same gap turns up in fares, where one site gives two answers on the same flight.

How long does the agency have once the airline confirms?

Seven business days if you paid by credit card, 20 calendar days for anything else, counted from the moment the agency receives the airline's confirmation that a refund is due. Question 11 defines a prompt refund that way, and defines a business day as Monday through Friday excluding Federal holidays in the United States. A confirmation landing on the Friday of a holiday weekend buys the agency days, not weeks.

The start of the clock is the part an agency will not volunteer, because it is the one date it controls and nothing rewards it for asking the airline early. That is why the request below asks for that date and not only for the money.

One wording to ignore. The Department's consumer refunds page describes the non-credit-card deadline in one place as 20 business days. The compliance guide and the final rule both say 20 calendar days, and the rule prevails.

Do I have to request the refund, or is it automatic?

You have to request it, and this asymmetry costs travellers more time than anything else in the rule. Question 1 splits the duty in one line, airlines provide automatic refunds of airfare, while ticket agents provide them upon request when they are the merchant of record. Waiting for an agency to act on its own waits on an obligation that has not started.

Send it in writing, through the agency's own support ticket or address, and keep the timestamp. The request starts the obligation, the timestamp proves the deadline ran, and a phone call leaves you nothing to point at.

• Ask for the airfare back to the original form of payment, and say you are not accepting a wallet balance, credit or voucher.
• Name whose entity appears on the ticket charge on your card statement, closing the merchant of record question before it opens.
• Ask for the date the airline confirmed to the agency that a refund is due. That date is what the deadline counts from.
• Quote question 13, that the refund is due within 7 business days or 20 calendar days of that confirmation even if the funds have not reached the agency.
• Ask the airline separately to confirm the refund authorisation to you in writing, which removes the agency's last argument.

Who refunds the baggage fee if the booking site charged it?

The airline, whoever sold the ticket. This is the one place the card statement does not decide it. The Department's consumer refunds page states that ticket agents are not responsible for refunding optional service fees if the service is not provided, or baggage fees if a checked bag is significantly delayed or lost, and that you must request that refund from the airline even where the agent was the merchant of record.

The compliance guide names which airline. Question 19 puts a delayed-bag refund on the airline that operated the flight, or the last segment of a multi-carrier itinerary. Question 15 puts every other ancillary service paid for and not provided, a seat you paid to select, Wi-Fi that never worked, on the carrier that operated the flight on which it failed.

The two sources read the mechanics differently, so do both. Question 18 makes the bag fee refund automatic once you file a mishandled baggage report, while the Department's consumer page tells you to request it from the airline. The guide's thresholds are 12 hours after a domestic flight arrives, then 15 or 30 hours after an international flight, split by whether the segment between the United States and the foreign point runs over 12 hours.

What do I do when the deadline passes and nothing arrives?

You hold a dated request, a dated confirmation and a deadline on the record, which is what every escalation route asks for and almost nobody has. Run them together rather than in sequence, because none is a precondition for another.

• File a complaint with the Department of Transportation's Office of Aviation Consumer Protection against the agency and the airline, using the DOT consumer complaint form.
• Dispute the charge with your card issuer. It came from the merchant of record, so the dispute lands on the party the rule says owes you.
• If a leg was to or from the EU or on an EU carrier, run that claim in parallel on its own deadlines, set out in the EU261 guide.

What closes the argument I was winning?

Two things. Accepting a wallet credit or voucher to close the file, when the rule's default is a refund in the original form of payment. And claiming on trip cancellation cover while the refund is in dispute, since the insurer will deduct what the airline or agency already owes you, which the travel insurance guide sets out.

Two smaller facts. The 24 hour free cancellation requirement does not apply to tickets bought through a booking site or agent at all. And denied boarding is the other Department rule with a fixed amount rarely quoted to you, which we cover in a separate post on being bumped or volunteering. Every figure here was read on the pages below on 15 September 2026, per our method.