The compliance requirements for airlines participating in the payroll support and loan programs initially instituted under the CARES Act in the United States continue to increase in volume and complexity with the passage of the American Rescue Plan Act of 2021. Like previous emergency funding packages, the $14 billion of direct aid for payroll support comes with many restrictions, and airlines should invest ample time and resources to understand the complex requirements and their potential impacts.

This article outlines those requirements and offers key questions airline teams should consider as more details around funding requirements are disclosed.