New DOT Rules for Emotional Support Animals (2022 Update)
This article was last updated in January 2022.
Major airlines are banning emotional support animals (ESAs) under a new United States Department of Transportation (DOT) ruling.
In December 2020, the DOT announced it was providing new regulations for animals that travel by air and amending its definition of ESAs. The rules officially went into effect upon the start of 2021. If you had an Emotional Support Animal prior to 2021, this is major news.
In this DJANGO Dog Blog article, we cover everything you need to know about the DOT's new rules and how it affects ESA and pet airline travel including:
- How emotional support animals are now defined in the United States
- How the new DOT regulations affect pet owners that want to fly with an ESA in 2021 and beyond
- Which U.S. airlines have since banned emotional support animals
- How to successfully fly with your dog or cat in-cabin going forward
New DOT Rules for Emotional Support Animals
In December 2020, the U.S. Department of Transportation revised rules around flying with emotional support animals and stated it no longer considers ESAs to be service animals. The new regulations were updated in the DOT's Air Carrier Access Act (ACAA) which regulates the transportation of service animals by air.
Service animals are governed under the Americans with Disabilities Act (ADA) and are allowed by law to be able to accompany their owners in commercial airplane cabins for no fee. Because ESAs are no longer considered service animals by the DOT, airlines no longer have to accept them on board their aircraft. Rather, many airlines are now banning ESAs entirely from their cabins and classifying these non-service animals as regular pets.
Were emotional support animals previously considered service animals?
Yes and no. Before 2021, emotional support animals fell under the broad definition of service animals under the DOT's Air Carrier Access Act. Although ESAs were not trained to perform a specific task, i.e. guiding a blind person or bringing medication to a diabetic, they provided emotional support and therefore fell under the DOT's definition of a 'service animal'.
This stance on ESAs meant that airlines had to allow the animals to accompany their owners in commercial cabins for no fee. The DOT did not specifically define ESAs as a certain type of animal (i.e. dog, cat, pig, peacock), so all animals could technically be an ESA.
Unlike the DOT, the Americans with Disabilities Act has consistently defined service animals as dogs that are individually trained to do work or perform tasks for a person with a disability. Because airlines must abide by DOT regulations, airlines always must adopt and set policy around the DOT's definition of ESAs.
What is the DOT's new definition of a service animal?
The DOT now defines a service animal "as a dog that is individually trained to do work or perform tasks for the benefit of a person with a disability", including physical, sensory, psychiatric, intellectual, or other mental disabilities.
Because the DOT specifically states that service animals are dogs, it "no longer requires airlines to accommodate miniature horses, cats, rabbits, birds, and all other service animals" that airlines were previously required to transport.
When accompanying their owners on airplanes, service dogs are allowed to fly in the cabin with their owner free of charge, regardless of breed, as long as they can fit in their handler’s foot space.
What does this mean for owners of emotional support animals?
Unless the ESA can perform psychiatric work or tasks (e.g. wake up a person having a nightmare or get water/medication), airlines do not have to recognize the ESA as a service animal. This means the ESA is not guaranteed a spot in the cabin with their owner, even with a letter from a mental health professional.
ESAs are now considered pets, not medical tools. As a result, owners will have to pay a pet fee and follow the airline's pet policy, which includes size, breed, and weight restrictions.
To be clear, the DOT makes clear that psychiatric service animals (those trained to perform psychiatric work or tasks), must be treated by airlines the same as other service animals.
Why did the DOT revise its rules on emotional support animals?
The DOT stated it was revising the Air Carrier Access Act to “to ensure a safe and accessible air transportation system." If you've read any headlines about ESAs over the past few years, it is pretty clear why the DOT took action.
The DOT revised the Air Carrier Access Act after years of complaints that travelers were exploiting a loophole to avoid paying pet fees. In some cases, pet owners tried to bring onboard comfort lobsters, squirrels, opossums, kangaroos, and Appaloosa horses. A New York artist famously tried yet failed to bring her peacock named Dexter onto a United Airlines flight.
In June 2017, Marlin Jackson was mauled by an emotional support dog on a Delta flight. He needed 28 stitches in his face, according to a $140 million lawsuit filed by Jackson against both the airline and the dog's owner. In July 2019, an emotional support dog bit a flight attendant on Flight 3506 from Dallas to Greensboro, North Carolina. He needed five stitches on his left hand.
Since 2016, the number of ESAs grew from 500,000 to over 1 million. The ESA boom caused Airlines for America and 80 other organizations to urge the DOT to “adopt the definition of a service animal from the Americans with Disabilities Act.”
FLYING WITH AN EMOTIONAL SUPPORT ANIMAL
Emotional support animals that no longer qualify as service animals may travel as carry-on or cargo pets, as long as they meet size and weight requirements. Owners will have to pay pet fees, ranging from $99 each way on Frontier to $200 each way on Delta.
Large dog breeds can be transported as cargo. Cargo fees are based on the total weight of the dog and crate. According to PetRelocation, a Great Dane can cost up to $1,000 to ship.
We’ve listed the pet fees, cabin/cargo options, and size/weight restrictions for Alaska, Allegiant, American, Delta, Frontier, JetBlue, Spirit, Southwest, and United Airlines.
Airlines Pet Policy and Cost Comparison Chart (January 2021)
|
Airline |
Price per pet (One-way) |
Allowed in the cabin? |
Allowed in cargo? |
Size restrictions |
Weight restrictions |
|
Alaska Airlines |
Cabin: $100 Cargo: Varies by weight |
Yes |
Yes |
Hard kennels: 17” x 11” X 7.5” Soft kennels: 17” x 11” x 9.5” Cargo: 30” x 27” x 40” |
20 lbs |
|
Allegiant Airlines |
$100 |
Yes |
No |
9” x 16” x 19” |
20 lbs |
|
American Airlines |
Cabin: $125 Cargo: Varies by weight |
Yes |
No, due to COVID-19 |
All kennels: 19” x 13” x 9” Cargo: 40" x 27" x 30" |
20 lbs |
|
Delta Airlines |
$125 to/from US, Canada, Puerto Rico $75 to/from Brazil $200 Virgin Islands/International |
Yes |
No, due to COVID-19 |
Airbus A318, A319/ A320: 24" x 15. 5" x 9.5" Embraer E190: 18" x 13.5" x 10" |
No limit |
|
Frontier Airlines |
$99 |
Yes |
No |
Personal item: 8” x 14” x 18” Carry-on bag: 10” x 16” x 24” |
20 lbs |
|
JetBlue Airlines |
$125 |
Yes |
No |
17” x 12.5” x 8.5” |
20 lbs |
|
Spirit Airlines |
$100 |
Yes |
No |
Soft kennels: 18” x 14” x 9”
|
40 lbs |
|
Southwest Airlines |
$95 |
Yes |
No |
18.5” x 8.5” x 13.5” |
No limit |
|
United Airlines |
Cabin: $125 Cargo: Varies by weight |
Yes |
No, due to COVID-19 |
Hard kennels: 17.5” x 12” x 7.5” Soft kennels: 18” x 11” x 11” Cargo: No crates taller than 30” |
No limit |
AIRLINES THAT HAVE BANNED EMOTIONAL SUPPORT ANIMALS
ALASKA AIRLINES
Alaska will accept ESAs that were booked before January 11, 2021, for flights prior to March 1, 2021. After March 1, it will allow two service dogs per person in the cabin. This includes psychiatric service dogs that provide assistance to people with “emotional or mental illnesses and specific learning disabilities.” Owners will need to electronically complete a Service Animal Air Transportation form that confirms their service dog’s health, behavior, and training at least 48 hours before travel.
AMERICAN AIRLINES
American Airlines (AA) will not allow ESAs in the cabin after January 31, 2021. Owners will have to electronically submit a DOT form to the Special Assistance Desk at least 48 hours before their flight. Before AA issues a Service Animal ID (SVAN ID), employees may “ask certain questions to determine if your dog is a service animal acceptable for travel.” The SVAN ID is valid for 12 months or until the dog’s vaccination expires.
ALLEGIANT AIRLINES
ESAs that were booked before January 11, 2021 are eligible to fly until May 1, 2021. After that date, Allegiant will allow two fully-trained service dogs per disabled passenger. Service animals in training, K9s, and search/rescue dogs are permitted on a case-by-case basis. Owners should email a DOT form at least 48 hours before departure. They should also arrive “at least two hours before their scheduled departure to ensure the animal verification process is completed.”
DELTA AIRLINES
Delta Airlines will accept ESAs that were booked prior to January 11, 2021, but new bookings for ESAs are not allowed. Customers may travel with two trained services dogs. “Delta will lift its ban on pit bull-type dogs provided they meet documentation requirements for trained service animals,” according to a statement from the airline. Owners will need to submit a government-approved form through the Accessibility Service Request Form located in My Trips. If the flight is longer than eight hours, they will also have to fill out a Relief Attestation form. It verifies their “dog will not relieve itself in the aircraft or can do so in a sanitary manner.”
FRONTIER AIRLINES
Frontier will allow trained dogs, cats, and miniature horses to travel through Jan. 31. On Feb. 1, it will accept two service dogs per person. Customers should submit a Service Animal Air Transportation form at least 48 hours before departure. Employees may ask “how an animal has been trained to assist with a disability or what work it has been trained to perform.” Service dogs may sit on the floor or in the customer’s lap (as long as they weigh less than 30 pounds). While they are not required to be in a pet carrier, they cannot extend into the aisle, occupy an empty seat, or encroach upon a neighboring seat.
JETBLUE AIRLINES
JetBlue will honor booking made for ESAs before December 20, 2020, for flights through March 1, 2021. Service dogs in training are not permitted. A DOT form must be electronically submitted 48 hours before departure. JetBlue also watches the behavior of all service dogs to make sure that safety requirements are met before approving them for travel. Service dogs must be harnessed, leashed, or otherwise tethered. Small dog breeds can sit in their owner’s lap if they don’t touch any part of the seat or table tray. Additional seats can be purchased for service dogs that do not fit within the handler's foot space.
SPIRIT AIRLINES
On January 11, 2021, Spirit Airlines banned companion cabin animals. Service animals in training and ESAs (i.e., dogs, cats, birds, and rabbits) are still allowed to travel onboard as pets. The ultra-low-cost carrier does not require a health certificate for in-cabin pets. Though service dogs should have a service animal vest, harness, ID card, and registration. A Spirit team member will also ask for “assurance that your dog is trained to perform a task for a disability.”
SOUTHWEST AIRLINES
Until Feb. 28, Southwest will continue to allow ESAs. Starting March 1, owners will need to complete a DOT form at the ticket counter or gate on the day of travel. They will also be asked to provide “credible verbal assurance that their animal is a trained service animal.” Employees may also “ask fact-finding questions to determine whether an animal is a trained service animal or eligible to be accepted as a pet.” Owners that make false statements may be subject to fines and other penalties.
UNITED AIRLINES
United Airlines will accept ESAs that were booked prior to January 11, 2021 for travel through February 28, 2021. Starting March 1, passengers will be allowed to travel with two service dogs that are over the age of 4 months. They will be asked to complete a Service Air Transportation form and a Service Animal Relief Attestation form (for flights that are longer than 8 hours). Service dogs in training are allowed on board with a certified dog trainer.
Should airlines ban all ESAs from riding in their cabins for free (even with a doctor’s note)? Will the DOT’s new ESA rule change the way you travel with your dog? Please leave us a comment below! We would love to hear from you.
Additional Resources
- CAN LARGE DOGS FLY IN CABIN ON AIRLINES?
- INTERNATIONAL AIRLINE PET POLICIES FOR IN-CABIN TRAVEL
- PET TRAVEL TO GREAT BRITAIN AFTER BREXIT
18 Responses
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DJANGO
@LAUREN Hello! Yes, dogs are permitted to travel FROM the UK to the US in cabin so long as they fit in an airline-friendly pet carrier. It is US-to-UK in cabin pet travel that is prohibited for all pets but service animals. With that said, not all airlines allow pets in cabin on UK-to-US airlines.
When we last checked about 2 years ago, Air France, KLM and Lufthansa all allowed in-cabin pet travel from the UK to the US. At that same time, these airlines did NOT allow in-cabin pet travel from the UK to the US: Air Lingus, American Airlines, British Airways, Delta, United, and Wow.
Although the information is clearly dated, it’s a great place to start when researching airlines that work for your route. I suggest contacting the airlines above that allowed in cabin pet travel from the UK to the US and see if they can still accommodate your dachshund in cabin.
Best of luck to you with your upcoming travels!
Lauren
Hi there! I was wondering if (upon paying a fee) it would be possible for a small dachshund, chipped, up to date on meds, and with a passport, to travel one way from the UK to the US in cabin? I am moving back home and I’m concerned about my boy having to be in the hold or quarantined. Thanks! Lauren
DJANGO
@KRYSTA Hello! I am so glad to hear that you’ve been finding this article and other DJANGO Dog Blog articles. Since your dog is trained to perform specific tasks that aid in a disability (in your case, waking you up from recurring nightmares), then he or she is likely eligible to to become a service dog.
The good news is that it is not a requirement to have a service animal trained by a third-party. In other words, training done by you and/or your partner is acceptable. The next key steps towards certification is to pass a Public Assess Test. Your dog has to show that he can handle himself properly in public (i.e. not get over-exited, not be unruly or aggressive, be calm in new environments). The final step will be obtaining service dog certification and registration. Although these are not technically required in the US, they’re typically helpful to have, especially if you plan to bring your service animal in public places where pet dogs are not welcome.
Here is a great FAQ resource for you directly from the ADA.gov website (copy/paste into new browser bar).
>> https://www.ada.gov/regs2010/service_animal_qa.html
I hope this helps! All the best to you and your dog.
Krysta H
Thank you so much for all of your information. This website has been so helpful for planning our trip from US to UK. We trained our support dog to wake me from nightmares ourselves. How do we get official certification to prove this?
Thanks again,
Krysta
DJANGO
@CHRIS Hello!
This DJANGO Dog Blog article should answer your question: Flying with Pets In-Cabin to the United Kingdom (copy/paste link into new browser bar)
>>> https://djangobrand.com/blogs/news/flying-with-pets-in-cabin-to-the-united-kingdom <<<
In a nutshell, unless your Jack Russell is a service animal (or unless she is an ESA AND you can find an airline that still allows ESAs in cabin), then flying with a pet in cabin to the United Kingdom is not possible. The UK government does not allow pet dogs or cats to fly in cabin into the United Kingdom. They were allowing Emotional Support Animals on US airlines, but most airlines (if not all) have since banned ESA travel.
The article I linked to above includes other safe travel options for you and your Jack Russell Terrier’s upcoming trip to the UK.
Chris
Hello
Thank you for this article. Still a little confused
We have a 16lb jack russel that fits in the small carrier under the seat. Is there an airline that flys from the US to the UK that will allow in cabin as long as he fits in carrier under the seat.
DJANGO
@JOSIE Hello! Thanks for the questions, and I’m happy to help in any way I can! I understand that you’re trying to fly from Dublin, Ireland to JFK, New York in June 2021.
We definitely are familiar with the UK-USA route, and we detail the requirements for bringing a dog to the USA in this DJANGO Dog Blog article (copy and paste the link into your browser):
https://djangobrand.com/blogs/news/how-to-bring-your-pet-dog-to-the-usa
Generally speaking, the arrival in JFK with your dog should be straightforward and uncomplicated. So long as you have your required health certificate (or valid EU/UK pet passport) and rabies vaccination certificate with you, you should you have no problems departing the airport. My husband and I passed through JFK when coming home from France. Before leaving the baggage terminal, we had to go to a customs officer responsible for animals and agriculture. He reviewed our dog Django’s EU Pet Passport (which we had just gotten while in France) and rabies vaccination certificate, and we were then on our way back home.
Regarding your ESA questions. Unfortunately, we are not aware of any airlines that still acknowledge and allow emotional support animals in cabin given the recent US DOT changes.
You mentioned Lufthansa. Their website specifically states that “Pursuant to 14 C.F.R. Part 382, emotional support animals are no longer classified as service animals under U.S. DOT regulations, and Lufthansa will no longer accept or accommodate the emotional support animal classification.”
Unless your Irish Bedlington Terrier is “trained to do work or perform tasks for the benefit of a person with a disability,” including physical, sensory, psychiatric, intellectual, or other mental disabilities — then unfortunately he won’t be classified as an ESA going forward.
Regarding Are Lingus, they used to allow ESAs in cabin and their website still suggests they do. I would call them to confirm. My suspicion is they simply have not updated their website ESA policy page and will no longer accept ESAs in cabin to the USA.
Lastly, if your Irish Bedlington Terrier, he at least can fly with you in cabin within an airline-friendly pet travel carrier. I do realize that the breed, however, can be well over 20lbs which may exclude him from standard in cabin pet travel.
Hope this helps! Best of luck with your upcoming travels.
Josie
Hi! I have just found your blog and found it sooooo helpful in these bizarre times! You seem like a v knowledgeable person so I hope you don’t mind me asking for your advice?
My husband and I are planning to fly to JFK, USA from Dublin, Ireland around June 20th. I will be bringing my Emotional Support Dog, (an Irish Bedlington Terrier) with me.
We have not used preclearance before – And I was wondering, do you know anyone who has done that before with an ESA?
So far from my researching the internet I think I have found Aer Lingus and Lufthansa *may*Both do this and still acknowledge his ESA status and allow him to fly in the cabin with me. However I was wondering if you know if even if they do, if the new DOT rules complicate our arrival process and how he is received in New York?
I have found from talking to the CDC and NYC agriculture that he may need a rabies jab, as well as full health check up and pet passport which is no problem + I will arrange pre flying.
I think I can fly in first class with him from Lufthansa too from your blog, which would be awesome.
Do you know of any other airlines fly transatlantic and acknowledge ESAs despite the new DOT change?
Many thanks for your help, we are so grateful!
Josie
Sent from my iPad
DJANGO
@FRANK Yes we do! Here is a great resource we published a few years back and update twice a year. We’re actually in the middle of updating the resource now. Just copy and paste the below article link into your browser.
DJANGO Dog Blog – International Airline Pet Policies for In Cabin Travel
https://djangobrand.com/blogs/news/international-airline-pet-policies-for-in-cabin-travel
Frank
Hi Django – thanks so much for the fast response!
Do you have a resource showing all airlines you’re aware of that currently allow dogs to fly in cabin/cargo? It’s so difficult finding an up-to-date list!
Thank you!
DJANGO
@FRANK Hello! To clarify, the chart and airline information we included above confirms which airlines (1) banned emotional support animals from flying in the cabin (2) the pricing for bringing a dog or cat (not a service animal) in the cabin in an airline-approved pet travel carrier (3) updated pricing for pets to fly in cabin or via cargo.
Most airlines continue to allow pets to fly in cabin and via the hold or cargo area. Pets that are flying in the cabin must be in an airline-approved pet travel carrier that meets the airline’s height/width/length max requirements. Pets can similar fly in cargo unless they are disqualified from this service (an example would be a snub-nose breed). So you can absolutely fly with your pet and have two options to do so: (1) via the cabin if your pet fits in an airline-approved pet travel bag AND you pay the pet travel fee (2) via cargo assuming your pet is not a snub-nose breed.
Does this make sense? Let us know if you have any follow up questions of course!
DJANGO
@STEPHANIE It’s nice to hear from you! I totally appreciate how difficult it is for owners of medium and large sized dogs who do not fit under a plane seat in a standard airplane friendly pet travel carrier. Although most larger dogs do fine in cargo, it’s obviously not a good option for nervous or skittish dogs. And in general, I’m with you — I would not feel comfortable putting my dog Django in cargo. Have you considered having a friend, family member, or pet sitter watch your dog inside your home while you’re away? Perhaps your dog will be a little more comfortable with someone if she’s in the comfort and safety of her own home… Just a thought. I realize it’s a tough situation regardless.
Frank
The most recent to the chart above shows that every airline except Alaska has stopped allowing cargo pets. Does this mean that if our pet is not a service dog, we cannot fly with it right now?
Stephanie
I don’t mind paying for my dog to travel as a pet, but she is just slightly too big. I wish they would change the size requirements for in cabin travels, because I don’t want to put my dog through cargo as I have heard that can be traumatic. I don’t live in the country I grew up in, all my friends and family live in Europe while I am in the US, and I need to quite frequently travel back. I can’t leave my dog with anyone as she is quite skittish of everyone else :(
DJANGO
@DESIREE Thank you for the comment! I agree that something had to change. For years there were many random websites that sold inauthentic and unverified “ESA” letters to anyone who paid for them (and ESA vests, service animal vests, etc, as you pointed out). Unfortunately, this allowed many people to bring an “ESA” in cabin—whether it was a dog, cat, or peacock—before airlines starting cracking down and requiring more documentation from licensed medical professionals. Too many unfortunate events caused the Department of Transportation and major U.S. airlines to finally take action, as we saw in December 2020. I just hope the new changes do not prevent people with true needs for a psychiatric service animal from flying successfully with their dog in cabin.
Desiree
These changes were absolutely necessary! People with ESAs are going too far passing off their ill or non trained pet as a service dog or expecting their pet to have the same status as one! These animals often endanger other people and true service dogs with unruly and often a dog with poor temperament that should never be in public places without training and a responsible handler. Now if the websites that sell service dog vests and fake IDs and registrations can be stopped! I can see the ESA people using and abusing these fake credentials with businesses who don’t know the difference!
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