The airline ticketing landscape governed by the Airline Reporting Corporation (ARC) has evolved substantially in the past decade, particularly regarding the regulations that apply when one agency issues tickets on behalf of another. Previously, the ARC’s Agent Reporting Agreement (ARA) contained explicit clauses prohibiting agencies from issuing tickets for other agencies that were either not ARC-appointed or whose ticketing privileges had been revoked. These rules aimed to maintain accountability but raised significant antitrust concerns by effectively enabling group boycotts among agencies.
It was this tension between regulatory control and legal competition frameworks that led to the removal of such prohibitions from the ARA in its major revisions over ten years ago. Today, ARC’s regulations do not expressly forbid an agency from ticketing on behalf of another, even if that agency has lost ARC appointment or a carrier-specific ticketing privilege. This shift reflects a more flexible, albeit complex, regulatory environment that recognizes operational realities while attempting to avoid anticompetitive practices.
The Critical Role of Individual Airline Appointments
Despite the ARC’s relaxation on prohibiting ticketing for nonappointed vendors, the airlines themselves maintain stringent control over who they authorize to sell their products. Airlines grant appointments as a unilateral right and reserve the authority to terminate these appointments at their discretion. This authority allows carriers to enforce policies addressing risks such as fraud, financial instability, or noncompliance with industry standards.
These airline-level appointments come with their own bespoke contracts and conditions, which often carry greater weight than ARC’s broad regulations. For example, American Airlines stands out for its extensive and detailed “Addendum to Governing Travel Agency Agreements,” a document spanning nearly 9,500 words. This addendum explicitly prohibits agencies from facilitating ticket sales or bookings on behalf of other agencies that have lost American’s authorization. The language is unambiguous: agencies must not engage in actions that support “unauthorized” third parties via methods such as sharing pseudo-city codes or other operational devices unless expressly permitted.
In practice, this means that even if ARC does not prohibit issuing tickets on another agency’s behalf, airlines like American prioritize their own risk management and compliance through contractual clauses. Engaging in facilitating unauthorized ticketing relationships with agencies that have been suspended or terminated by the airline can jeopardize your access to issue tickets for that carrier altogether.
Balancing Operational Trust with Regulatory Compliance
Agencies faced with requests from terminated or suspended counterparts must navigate this regulatory mosaic with caution. Beyond legal and contractual prohibitions, there is a fundamental question of risk management and trust. Accepting reservation records from an agency that has lost their ARC or carrier appointment poses substantial financial and reputational hazards, potentially exposing the issuing agency to financial losses, chargebacks, or regulatory scrutiny.
Even when ARC rules appear permissive, airline-specific agreements or internal policies may impose tighter restrictions or sanctions for indirect facilitation of unauthorized sales. The discretion to withdraw appointment rights without cause makes the operating environment precarious; agencies that facilitate ticketing on behalf of nonappointed or suspended counterparts risk becoming entangled in these disputes.
Contextualizing the Implications for Agencies
Agencies might be tempted to assist former or terminated agencies to preserve business continuity. However, the evolving regulatory and contractual landscape necessitates meticulous due diligence. Absent clear authorization from the airline concerned, issuing tickets on behalf of another agency—particularly one barred by the airline—can trigger severe penalties, including the loss of airline-specific issuing rights.
Moreover, agencies should not overlook the broader legal implications. Although ARC’s relaxed stance mitigates antitrust concerns, airlines’ decisions remain unilateral and heavily enforced. This disparity creates a tension between maintaining competitive practices and adhering to corporate risk frameworks imposed by carriers.
Agencies must therefore strike a careful balance: lean on ARC’s regulatory framework as a baseline but prioritize strict adherence to the specific carrier agreements governing ticket issuance. Developing robust internal controls and transparent verification procedures is essential to ensure compliance and mitigate risks associated with issuing tickets on behalf of third parties.
The Bottom Line on Facilitating Ticketing for Suspended Agencies
The landscape today is clear: ARC no longer blocks agencies from issuing tickets for terminated or nonappointed counterparts. However, carriers maintain firm unilateral control, and airline-specific agreements—especially those from major players like American Airlines—explicitly forbid the facilitation of ticketing by unauthorized parties. Agencies choosing to disregard these carrier-imposed mandates face significant consequences, including the revocation of their ticketing privileges. The modern reality for travel agencies is to navigate between broader ARC allowances and tighter airline-specific regulations, understanding that carrier contracts often hold the decisive power over who can legally issue their tickets.