DOT fined airlines $155 million for withholding refunds. It collected $33 million.

When an airline sits on a passenger's refund, the Department of Transportation's Office of Aviation Consumer Protection (OACP) is the office that's supposed to make it pay.▸ Between 2018 and 2023 it assessed $155.55 million in civil penalties against 14 airlines for exactly that — failing to provide prompt refunds. A Department of Transportation Inspector General audit published September 17, 2025 went looking for where the money actually went, and found that most of it never moved at all.

A civil penalty sounds like money changing hands.▸ Mostly it wasn't. OACP let airlines reduce what they owed by "crediting" penalty amounts against refunds or vouchers the airline swore, in its own statement, it had already issued or would issue later — with no independent check that any of it happened. The OIG report found OACP "does not verify the airlines' supporting documentation for the refund amounts they provide consumers," relying instead on sworn self-certification.

Just $33 million — 21 cents of every dollar assessed — was ever collected in cash.▸ $39.2 million was wiped out as a "credit" for refunds airlines said they'd already paid. $72 million more, almost all of it a single Southwest Airlines settlement, was "offset" against a promise of future vouchers instead of collected as a penalty at all. None of the underlying refund data behind those credits and offsets was verified. And $11 million of Southwest's $140 million penalty — the largest civil penalty in aviation consumer-protection history, imposed December 15, 2023 for the airline's December 2022 operational collapse — was still unpaid, due in January 2026, as of the audit.

Southwest alone accounts for 90% of every dollar assessed against every airline over six years.▸ Take that one case out and the other 13 airlines combined were fined $15.55 million across five years of settlements — sums in the hundreds of thousands to low millions, the kind of penalty an airline can absorb as a cost of doing business rather than a deterrent.

The credits and offsets aren't the only place the system gave way.▸ OACP's job starts with reading every complaint. It stopped being able to.

Refund complaints ran under 1,600 a year before the pandemic.▸ In 2020 they hit 89,518 — a 57-fold jump in a single year, as airlines cancelled flights and stalled on refunds. OACP's response was to scale back, not up: in spring 2020 it stopped analyzing every airline's response to a complaint, switching to spot checks. In January 2021 it "streamlined" complaint coding, and soon after stopped coding complaints altogether — officials told the inspector general this was "due to high volume and staffing limitations." As of April 2025, per the audit, OACP had still not resumed the analysis it dropped in 2020. Separately, the office missed five consecutive congressionally mandated annual reports on airline consumer-protection compliance — required since 2019, not delivered until years later — leaving Congress without the data those reports are supposed to provide.

The Department has not stood still on refunds themselves: a rule requiring automatic cash refunds took effect in 2024, and DOT has continued to amend and enforce it, including a January 6, 2026 notice proposing to revise OACP's investigation and enforcement policies.▸ But the same rulebook has also moved the other way: on December 5, 2025, DOT announced it would not enforce refund requirements for flights that are cancelled and rebooked under a new flight number, pending a fresh rulemaking — one more case where the enforcement line moved before the verification problem underneath it was fixed.

This piece covers DOT's own civil-penalty enforcement against airlines for withheld refunds; it does not cover the separate, larger population of refund complaints airlines resolved directly with passengers outside the enforcement process.