All American Airlines Flagship Suites have received ACAA EADs, including the A321XLR

The Department of Transportation (DOT) has granted American Airlines’ equivalent alternative determination (EAD) to use its Flagship Suites, which do not have movable aisle armrests, for passenger services. In March 2025, the DOT cleared the business class suites to be used on its Boeing 777-300ER and 787-9 aircraft.

According to the filing, the Air Carrier Access Act (ACAA) stipulates that aircraft, which have 30 or more seats, need to have “movable aisle armrests on at least one-half of the aisle seats in rows in which passengers with mobility impairments are permitted to sit under FAA [Federal Aviation Administration – ed. note] or applicable foreign government safety rules.”

"Equivalent alternative means a policy, practice, or other accommodation that provides substantially equivalent accessibility to passengers with disabilities, compared to compliance with a provision of this Part."

In its initial EAD application, American Airlines noted the fact that its business class suites on the A321XLR do not have armrests. However, the business class suites have an “unobstructed space through which a passenger can make an assisted transfer into the seat without being lifted over any obstacles.”

The airline stated that assisted transfers will use a mechanical device with a harness attached to an overhead bar, which will lift and/or transfer the passenger into/out of the seat with guidance from its employees.

“American states that it will ensure personnel are trained to properly conduct the transfer procedure using this device. American provided diagrams of the seats as well as videos demonstrating assisted and unassisted transfers into and out of the aircraft seat.”

However, the diagrams were made confidential upon the request of American Airlines.

When it applied for the EAD, it said that the A321XLR should enter service in late 2025. American Airlines already took delivery of its first aircraft of the type in July 2025, yet the long-range narrowbody, registered as N300NY, is currently stored at Ostrava Leoš Janáček Airport (OSR), Czechia.

The aircraft is spending its time in Czechia while it awaits seats, with the carrier previously confirming that the A321XLR will be stored at OSR until supply chain constraints, related to the aircraft’s seats, are resolved.

DOT granted EADs to its 777-300ER and 787-9 aircraft in February 2025.

American Airlines has also yet to retrofit its 777-300ERs with Flagship Suites, with planespotters.net records showing that all of them still have the old configuration with 8 first class, 52 business class, 28 premium economy, and 216 economy class seats.

When the airline announced the new Flagship Suites in September 2022, it said that its 777-300ERs would be retrofitted starting late 2024.

The airline’s new 787-9 with the new Flagship Suites made its debut on June 5, 2025. One of the three premium-heavy aircraft that entered service that month, N846AN, had suffered numerous mechanical setbacks during its first few weeks of service. Latest Flightradar24 records showed that the 787-9 has been reliably flying for the past few months.

Nevertheless, similar to its EAD approval for the 777-300ER and 787-9, the DOT mandated that American Airlines provide specialized training to its employees and contractors, ensuring that they are aware of the proper procedures to transfer passengers and provide refresher training annually.

In addition, the carrier must retain individuals’ three-year training records, and every quarter for three years, it must provide the Department’s Office of Aviation Consumer Protection (OACP) “with copies of all complaints or incident reports, if any, regarding passenger transfers to and from the seats in the covered aircraft, or certify in writing that no such complaints or incident reports have been received.”

American Airlines’ A321XLRs will have 20 business seats, 12 premium economy seats, and 123 economy class seats, with the business class seat being based on the Collins Aerospace Aurora.