With reference to the Consumer Rights Act 2015, what assessment she has made of the potential impact of Ryanair's proposed requirement for all passengers to have digital boarding passes on (a) pensioners and (b) other passengers who do not possess a smartphone.
Under the Consumer Rights Act 2015, airlines must ensure that their terms and conditions are fair, transparent, and do not place certain consumers at an unfair disadvantage. The CAA is responsible for ensuring airline compliance with the Consumer Rights Act 2015. The Civil Aviation Authority (CAA) conducted a review of airline contract terms in 2019, including those relating to online check-in and the issuing of boarding passes. The review concluded that while online check-in requirements can be legitimate, such terms must be clearly communicated and any associated fees should be proportionate. Ryanair continues to require all passengers to check in online. According to their new digital boarding pass policy, passengers without access to a smartphone can obtain a boarding pass for free at the airport as long as they have checked-in online.