Is the Canadian Air Passenger Complaint Backlog Really Nearing Three Years?

The Canadian Transportation Agency backlog for air passenger complaints has reached a critical point.

New analysis suggests the average CTA resolution time is nearing three years. This figure, however, is being challenged by both the regulator and passenger rights advocates.

The Three-Year Claim and Data Debate

Legal technology company Courtready released an analysis showing a significant delay. The report found that air passenger complaints take an average of 987 days to resolve as of September 2025. This timeline is measured from the original flight date to the final decision date. This marks the longest wait time observed since January 2024.

Tom Macintosh Zheng, co-founder of Courtready, stated the analysis uses data published by the CTA. He noted this "end-to-end timeline" is important for Canadians to understand. The data also shows the CTA is processing fewer cases overall. Decisions dropped from 7,076 in the third quarter of 2024 to 4,301 in the third quarter of 2025. This is despite a current backlog of about 92,500 complaints.

Why the 987-Day Figure is Disputed

Air Passenger Rights advocacy group president Gabor Lukacs cautioned against this analysis. He argues that measuring from the flight date overstates the delay. Passengers do not file a complaint with the CTA immediately. They must first attempt to resolve the issue directly with the airline. Passengers can take up to one year after an incident to file a complaint. Therefore, the flight date is not an accurate start for the CTA's processing clock.

The CTA also pushed back on Courtready’s conclusions. The agency stated the analysis does not reflect the actual time complaints wait to be processed. The study relies only on published orders, which is just one way complaints are resolved. The CTA reported closing 3,247 complaints in September 2025. This is significantly higher than the 1,348 decisions cited in the Courtready study. The agency is currently trending toward its fourth straight year of receiving over 40,000 complaints.

Structural Issues Driving the Backlog

Experts suggest the growing backlog is not just a staffing issue. It is instead driven by structural problems that encourage airlines to contest claims. The complexity of the Air Passenger Protection Regulations (APPR) is a major factor. Courts have noted that the APPR requires extensive legal analysis. This is true even for relatively small flight disruption compensation claims. This complexity increases the time needed for CTA officers to resolve each case. The CTA states that once an officer begins work, it takes an average of 60 days to close a case. This does not include the long waiting period in the backlog.

The Role of Regulatory Gaps

Another critical factor is the lack of a cost-recovery fee for airlines. Parliament approved this fee in 2023. The fee would make airlines help pay for the complaint resolution process. Its absence means airlines can deny compensation at little cost. This shifts the burden to passengers and the public system. Without financial consequences, it can be more profitable for airlines to delay or refuse compensation.

Path to Resolution and APPR Reforms

Addressing the massive Canadian Transportation Agency backlog requires multiple actions. Lukacs suggests simplifying the APPR and implementing the approved cost-recovery fee. Stronger enforcement powers are also needed to deter repeat violations.

• The federal government launched consultations to revise the APPR, but reforms are not yet in effect.
• Proposed amendments were published in December 2024.
• These changes aim to clarify "exceptional circumstances" for airlines.
• They also propose requiring airlines to provide refunds within 15 days, down from the current 30 days.

For passengers, the long delays undermine access to justice. Some Canadians are now turning to provincial courts for faster outcomes. The ongoing debate over the CTA resolution time highlights the need for greater transparency and systemic reform in air travel consumer rights.

Learn more about the Canadian Transportation Agency (CTA) and its mandate.

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