# APPR large vs small carrier: the 2-million-passenger test

Source: https://airtravelrights.com/canada-appr/large-small-carrier/

> A small carrier''s delay compensation tops out at C$500 where a large one owes C$1,000 for a 9-hour-plus arrival delay. Here is the 2,000,000-passenger test.

# Large and small airlines under Canada's APPR

2,000,000 passengers a year, in each of the two years before the disruption, is the line the Air Passenger Protection Regulations draw between a large airline and a small one. That line changes the money: for a delay or a cancellation, a large carrier pays up to C$1,000, a small carrier up to C$500. It also changes how far the airline has to go to rebook you. Below is the test itself, the two amount scales side by side, and how a passenger works out which one applies. Verified against the in-force regulation text on 2026-09-15.

## What makes an airline a large carrier under APPR?

2,000,000 or more passengers worldwide, carried in each of the two calendar years immediately before the disruption, is what makes an airline a large carrier under the Air Passenger Protection Regulations. Fall short in either of those two years, and the airline counts as a small carrier instead, whatever its fleet looks like today.

Source: Air Passenger Protection Regulations (SOR/2019-150), s.1(2) - laws-lois.justice.gc.ca, checked 2026-09-15.

Section 1(2) puts it as "two million passengers or more" in each of the two preceding calendar years, counted worldwide. The test looks backward, not at the airline's current size. A carrier that only passed 2,000,000 passengers last year is still small this year, because the earlier of the two years being counted falls short. The Regulations set one number and two years; they name no airline directly, but the CTA's own guidance page does - see which carriers below.

An airline's size can also change year to year, so a status that held for last year's disruption may not hold for this year's. The accessibility regulations draw their own, lower line, which is why a small APPR carrier can be large there: see [flying with a disability in the US and Canada](https://airtravelrights.com/disability-flight-rights-us-canada/).

Example: an airline carrying 2,100,000 passengers worldwide last year and 1,950,000 the year before stays a small carrier under section 1(2), because one of the two years missed the threshold. Both years have to clear 2,000,000, not just the more recent one.

Ask your airline directly which category it applied to your flight, and ask it to name the two years it counted.

## When does a small carrier have large-carrier obligations?

Section 1(4) is the switch: when a small carrier flies passengers on behalf of a large carrier under a commercial agreement, it takes on the large carrier's rebooking, refund and compensation duties for that flight, not its own smaller-scale ones. Outside that arrangement, its own size-based rules apply as usual.

Source: Air Passenger Protection Regulations (SOR/2019-150), s.1(4) - laws-lois.justice.gc.ca, checked 2026-09-15.

This covers a capacity-purchase or codeshare-style arrangement, where a large airline sells seats that a smaller partner actually operates. The obligation follows the agreement, flight by flight, not the smaller carrier's everyday scale. One regional carrier flying several routes under contract to a major airline could owe the C$1,000 ceiling on those routes and the C$500 ceiling everywhere else it flies on its own account.

It matters most on a connection sold under one airline's flight number but flown by a different, smaller operator.

Check your ticket and boarding pass for the operating carrier's name, then ask which agreement covers that specific flight.

## How does carrier size change compensation?

C$1,000 is the large-carrier ceiling for an arrival delay of 9 hours or more. A small carrier's ceiling for that same wait is C$500, exactly half. Both scales start paying at 3 hours late and step up twice, at 6 and at 9 hours; only the money differs by size ([Missed connection compensation](https://airtravelrights.com/missed-connection-compensation/)).

| Arrival delay | Large carrier | Small carrier |
|:--|:--|:--|
| 3 to under 6 hours | C$400 | C$125 |
| 6 to under 9 hours | C$700 | C$250 |
| 9 hours or more | C$1,000 | C$500 |

Source: Air Passenger Protection Regulations (SOR/2019-150), s.19(1)(a)-(b) - laws-lois.justice.gc.ca, checked 2026-09-15.

A refund changes the number too, and it flattens by size rather than by how long the delay ran. Take the fare back under section 17(2) instead of rebooking, and a large carrier still owes C$400, a small one C$125, whatever the delay length was. Compensation is paid in money under section 21; another form counts only if it is worth more, disclosed in writing, never expires, and you confirm in writing that you accept it.

One figure ignores carrier size altogether. [Denied boarding compensation](https://airtravelrights.com/canada-appr/flight-delay-compensation/) runs C$900 under 6 hours, C$1,800 from 6 to under 9, and C$2,400 at 9 hours or more, the same scale whatever the airline's size.

A cancellation runs on the same two scales as a delay, and both are measured at your arrival, not at your departure. Land 9 hours or more after the arrival time on your original booking and the top band applies: C$1,000 from a large carrier, C$500 from a small one. Arrival is the moment a door opens and passengers are allowed to leave, not the moment the wheels touch down.

Both delay and cancellation scales pay only once the cause sat within the carrier's control, was not required for safety, and you were told 14 days or less before departure. That three-part test does not change with carrier size. Nor does the burden: once a complaint to the Canadian Transportation Agency raises the question, the disruption is presumed within the carrier's control and not required for safety until the carrier proves otherwise.

## How does carrier size change rebooking and refunds?

9 hours is how long a large carrier has, for a within-control disruption, to find you a seat on its own or a partner airline. Miss that and it owes any carrier within 48 hours, and failing that a nearby airport on any carrier. A small carrier owes only the next flight on its own or a partner airline.

Source: Air Passenger Protection Regulations (SOR/2019-150), s.17(1)(a)-(b) - laws-lois.justice.gc.ca, checked 2026-09-15.

That size gap holds only for disruptions within the carrier's control. Outside its control, the two sizes start on the same footing: rebooking on the carrier's own or a partner airline within 48 hours. From there, the fallback differs again, and the choice becomes yours: a refund of the unused portion, or a large carrier putting you on any airline, a nearby airport included, a small carrier only on its own or a partner's.

Either size, you can take a refund of the unused ticket instead, any time before a new reservation is confirmed.

Both the 9-hour and the 48-hour clock run from your original scheduled departure time, not from when the disruption was announced or from when you were actually told about the rebooking.

Example: a within-control disruption on a large carrier delays your connection by 10 hours. It has until the 9-hour mark to rebook you on its own or a partner's next flight; miss that, and it must find any airline departing within 48 hours of your original departure, and failing that a seat from a nearby airport.

Write down the time you were rebooked, then compare it against the 9-hour or 48-hour clock that matches your carrier's size.

## Which Canadian airlines are large or small?

6 airlines appear on the Canadian Transportation Agency's own list of large carriers under APPR, and 2 more as its examples of small ones. A second CTA page closes the gap the word "Examples" leaves: as of 26 February 2026, it says every other Canadian airline is small.

| Airline | APPR size, as the CTA labels it | Source for this row | Checked |
|:--|:--|:--|:--|
| [Air Canada](https://airtravelrights.com/airlines/air-canada/) (including Jazz and Rouge) | Large | [CTA, "Large and small airlines"](https://protection-passager-passenger.otc-cta.gc.ca/en/when-an-issue-happens/large-and-small-airlines); [CTA, "Flight delays and cancellations"](https://protection-passager-passenger.otc-cta.gc.ca/en/refunds-and-compensation/flight-delays-cancellations-rebooking-refunds-compensation) | 2026-09-17 |
| [WestJet](https://airtravelrights.com/airlines/westjet/) | Large | [CTA, "Large and small airlines"](https://protection-passager-passenger.otc-cta.gc.ca/en/when-an-issue-happens/large-and-small-airlines); [CTA, "Flight delays and cancellations"](https://protection-passager-passenger.otc-cta.gc.ca/en/refunds-and-compensation/flight-delays-cancellations-rebooking-refunds-compensation) | 2026-09-17 |
| [Sunwing Airlines](https://airtravelrights.com/airlines/sunwing/) | Large | [CTA, "Large and small airlines"](https://protection-passager-passenger.otc-cta.gc.ca/en/when-an-issue-happens/large-and-small-airlines); [CTA, "Flight delays and cancellations"](https://protection-passager-passenger.otc-cta.gc.ca/en/refunds-and-compensation/flight-delays-cancellations-rebooking-refunds-compensation) | 2026-09-17 |
| [Air Transat](https://airtravelrights.com/airlines/air-transat/) | Large | [CTA, "Large and small airlines"](https://protection-passager-passenger.otc-cta.gc.ca/en/when-an-issue-happens/large-and-small-airlines); [CTA, "Flight delays and cancellations"](https://protection-passager-passenger.otc-cta.gc.ca/en/refunds-and-compensation/flight-delays-cancellations-rebooking-refunds-compensation) | 2026-09-17 |
| [Porter Airlines](https://airtravelrights.com/airlines/porter-airlines/) | Large | [CTA, "Large and small airlines"](https://protection-passager-passenger.otc-cta.gc.ca/en/when-an-issue-happens/large-and-small-airlines); [CTA, "Flight delays and cancellations"](https://protection-passager-passenger.otc-cta.gc.ca/en/refunds-and-compensation/flight-delays-cancellations-rebooking-refunds-compensation) | 2026-09-17 |
| [Flair Airlines](https://airtravelrights.com/airlines/flair-airlines/) | Large | [CTA, "Large and small airlines"](https://protection-passager-passenger.otc-cta.gc.ca/en/when-an-issue-happens/large-and-small-airlines); [CTA, "Flight delays and cancellations"](https://protection-passager-passenger.otc-cta.gc.ca/en/refunds-and-compensation/flight-delays-cancellations-rebooking-refunds-compensation) | 2026-09-17 |
| Canada Jetlines | Small | [CTA, "Large and small airlines"](https://protection-passager-passenger.otc-cta.gc.ca/en/when-an-issue-happens/large-and-small-airlines) (small-airline examples) | 2026-09-17 |
| [Canadian North](https://airtravelrights.com/airlines/canadian-north/) | Small | [CTA, "Large and small airlines"](https://protection-passager-passenger.otc-cta.gc.ca/en/when-an-issue-happens/large-and-small-airlines) (small-airline examples) | 2026-09-17 |

Source: Canadian Transportation Agency (CTA), "Large and small airlines" (page's own date modified: 14 January 2026) - protection-passager-passenger.otc-cta.gc.ca/en/when-an-issue-happens/large-and-small-airlines, checked 2026-09-17.

This is the CTA's own plain-language guidance stating each carrier's category, not an adjudicated ruling in a specific complaint, and it publishes no carrier's actual two-year passenger count, only the label. For the six it labels large, that means delay and cancellation compensation on the C$400/C$700/C$1,000 scale, never C$125/C$250/C$500.

The eight above are the CTA's examples. The catch-all sits on a second CTA page, the one carrying the same compensation table shown earlier, in the Agency's own words: "All other Canadian airlines are small." That was its position on 26 February 2026, the date the page carries.

Source: Canadian Transportation Agency (CTA), "Flight delays and cancellations: rebooking, refunds and compensation" (page's own date modified: 26 February 2026) - protection-passager-passenger.otc-cta.gc.ca/en/refunds-and-compensation/flight-delays-cancellations-rebooking-refunds-compensation, checked 2026-09-17.

Size is not permanent. Neither page is a live feed: they carry modified dates of 14 January and 26 February 2026. The two-year passenger test can move a carrier across the line as its totals change, so a carrier that has crossed since those dates is whatever section 1(2) makes it - 2,000,000 or more passengers worldwide in each of the two years before your disruption - not what an older page implies. Your ticket settles it either way: the CTA points to the airline's tariff, which states the carrier's size, and you can ask in writing which category it applied. Download the named carriers, the catch-all and both scales as [CSV](https://airtravelrights.com/data/csv/canada-appr-carrier-size.csv).

Read the [Canadian delay and cancellation amounts](https://airtravelrights.com/canada-appr/flight-delay-compensation/) once you know your carrier's size, start from the [Canada APPR hub](https://airtravelrights.com/canada-appr/) for the full disruption categories, or see [how this project verifies its data](https://airtravelrights.com/how-we-verify/).

General information, not legal advice. For your specific case, contact the Canadian Transportation Agency or a lawyer.

## Sources

- Air Passenger Protection Regulations (SOR/2019-150), ss.1(2), 1(4), 17, 19, 21 - [laws-lois.justice.gc.ca](https://laws-lois.justice.gc.ca/eng/regulations/SOR-2019-150/FullText.html), checked 2026-09-15.
- Canadian Transportation Agency (CTA), "Large and small airlines" - [protection-passager-passenger.otc-cta.gc.ca](https://protection-passager-passenger.otc-cta.gc.ca/en/when-an-issue-happens/large-and-small-airlines), checked 2026-09-17.
- Canadian Transportation Agency (CTA), "Flight delays and cancellations: rebooking, refunds and compensation" (the second page carrying the same carrier list) - [protection-passager-passenger.otc-cta.gc.ca](https://protection-passager-passenger.otc-cta.gc.ca/en/refunds-and-compensation/flight-delays-cancellations-rebooking-refunds-compensation), checked 2026-09-17.
