The Canada Transportation Act allows the CTA to issue fines of up to $25,000 per passenger per incident for violations of the APPR.
With respect to the main provisions of the APPR relating to compensation of passengers, I'm aware of only one fine very recently issued against WestJet for $11,000 for 55 violations. That was $200 per violation. Those were violations or provisions where the amount at stake—the compensation owed to passengers—was between $400 and $1,000, so it was actually cheaper for the airline to pay the fine than to compensate the passengers.
With respect to those issues, our recommendation would be to have mandatory minimum penalties for airlines that break the regulations and mandatory enforcement provisions, as well as to increase the limitation period from 12 months to 36 months or longer for the CTA to issue a notice to airlines.