EU261, DOT, or UK261: Which Compensation Law Applies to Your Flight?

A US passenger flying Air France from Paris to New York has EU261 rights worth up to EUR 600 per person. Most of them have no idea. They land, lose a day of their trip, and move on. The airline certainly doesn't send a reminder.

This guide exists because the single biggest reason passengers don't file is not giving up, it's not knowing which law applies to their flight. There are three major frameworks:

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  EU Regulation 261/2004 (EU261): Covers flights departing from EU airports on any airline, and flights arriving in the EU on an EU-based airline.

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  UK Retained Regulation 261/2004 (UK261): The UK's post-Brexit equivalent, almost identical to EU261, covering flights departing from UK airports on any airline and flights to the UK on UK or EU carriers.

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  US Department of Transportation (DOT) rules: Cover flights to, from, and within the US. No fixed cash amounts for delays, but strong refund rights and involuntary bump compensation.

The golden rule: Your rights are determined by where your flight DEPARTS and which airline operates it, not by your passport, your citizenship, or where you bought the ticket.

Here is what each law actually covers, without the legalese:

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  EU261 (europa.eu): Applies to all flights departing from any EU member state airport, regardless of airline nationality. Also applies to flights arriving in the EU operated by an EU-based carrier. Covers delays of 3+ hours at destination, cancellations with less than 14 days' notice, and denied boarding. Fixed compensation: EUR 250, 400, or 600 based on distance. Full EU261 rights explained.

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  UK261: Identical framework to EU261, adopted into UK law after Brexit. Covers flights departing from UK airports on any airline, plus flights arriving in the UK on UK or EU carriers. Amounts are in GBP. Distance thresholds match EU261. Full UK261 rights explained.

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  US DOT rules: Cover all flights within the US and all international flights to or from the US. No fixed delay compensation for weather or operational delays (unlike EU261). Strong mandatory refund rights when a flight is cancelled or significantly changed. Involuntary denied boarding (bumping) carries fixed compensation: 200% of one-way fare (up to $775) for 1 to 4 hour delays, 400% (up to $1,550) for over 4 hours. Full US DOT rights explained.

One critical difference: EU261 and UK261 pay fixed amounts for delay regardless of what caused the delay (with a limited extraordinary circumstances exception). US DOT rules have no equivalent fixed delay compensation. A 4-hour delay on a US domestic flight does not trigger automatic cash, but the same delay on a Paris departure triggers EUR 250 to 600.

If your flight departs and arrives within the United States, only DOT rules apply. There is no state-level equivalent of EU261. The key rights for US domestic flights:

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  Cancellations: Mandatory cash refund to your original payment method if the airline cancels, regardless of reason.

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  Significant delays: Mandatory cash refund if you choose not to travel after a delay of 3 or more hours (domestic) or 6 or more hours (international).

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  Involuntary bumping: Fixed cash compensation of 200% to 400% of one-way fare, paid at the airport.

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  No fixed delay compensation: Unlike EU261, there is no EUR 250 to 600 equivalent for delay alone on US domestic routes.

Common misconception: Many US passengers assume they have no rights for flight delays. That is not entirely true. You have a mandatory right to a full cash refund if the airline significantly delays your flight and you choose not to fly. You just don't have a fixed delay payment on top of that.

If your flight departs from an airport in France, Germany, Spain, Italy, or any other EU member state, EU261 applies regardless of which airline you are on. American Airlines flight from Paris? EU261 applies. Delta from Amsterdam? EU261 applies.

The only exception: flights to non-EU destinations operated by non-EU carriers are covered only on the outbound leg (departure from the EU). The return leg from the US on American Airlines is not covered by EU261, since it departs from a non-EU airport on a non-EU carrier.

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  Paris CDG to New York JFK on Air France: EU261 applies (EU airport, EU carrier). Both directions potentially covered.

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  Paris CDG to New York JFK on American Airlines: EU261 applies on the Paris departure. The return JFK to CDG on American is NOT EU261 covered (non-EU departure, non-EU carrier).

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  Frankfurt to Chicago on Lufthansa: EU261 applies on Frankfurt departure. Return Chicago to Frankfurt on Lufthansa: EU261 applies (EU carrier, even departing from outside EU, if arriving in EU).

See the full EU261 compensation guide for exact amounts and how to file. And for the question of whether Americans can claim EU261 rights, see our dedicated guide on whether Americans can claim EU261 compensation.

After Brexit, the UK adopted its own version of EU261, called UK261 (officially the Air Passenger Rights and Air Travel Organisers' Licensing (Amendment) (EU Exit) Regulations 2019). It is substantively identical to EU261 for most purposes.

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  UK departure on any airline: UK261 applies. Ryanair from Stansted, American Airlines from Heathrow, all covered.

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  UK departure on a UK or EU carrier (arriving in UK): UK261 applies in both directions.

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  Amounts: Same thresholds as EU261 but paid in GBP rather than EUR.

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  Enforcement: The Civil Aviation Authority (CAA) at caa.co.uk is the UK enforcement body.

Overlap case: A flight from London Heathrow to Paris CDG on British Airways might trigger both UK261 (UK departure) and potentially EU261 (EU arrival on EU-adjacent carrier). In practice, you file under UK261 since that is the departure country. The protections are equivalent.

Here are the cases passengers most often get wrong, presented as a quick reference table in plain text:

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  New York to London on British Airways: DOT rules on the JFK departure (US rules). UK261 on the LHR return (UK rules). Two different laws for two legs.

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  New York to London on American Airlines: DOT rules on the JFK departure. UK261 applies on the LHR return (UK departure, even on a non-UK carrier).

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  New York to Paris on United Airlines: DOT on the JFK departure. EU261 on the CDG return (EU airport departure, any carrier).

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  London to New York on Delta Air Lines: UK261 on the LHR departure. DOT on the JFK return.

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  Chicago to Frankfurt connecting through London on British Airways: The Chicago to London leg is DOT. The London to Frankfurt leg is UK261 (UK departure). If you miss the Frankfurt connection due to the first leg, EU261 may apply at Frankfurt since the connecting flight is EU-departing.

Connecting flights are where it gets genuinely complex. If a delay on a US domestic segment causes you to miss a connection that was booked as a single itinerary and the missed flight was an EU or UK departure, you may have EU261 or UK261 rights for the downstream disruption. For more on this, see our comparison of EU261 and US DOT rules.

Single itinerary rule: EU261 and UK261 both look at the entire booked journey, not individual flight segments. If your delay on a first leg causes you to miss your connecting EU/UK departure, the disruption may still be covered even if the first leg was not.

Use this decision tree to identify which law applies to your delayed or cancelled flight:

1. 1

   Where does the disrupted flight depart from? If it departs from an EU country: EU261 applies. If it departs from the UK: UK261 applies. If it departs from the US: go to question 2.

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   Is it a US domestic flight? If yes: DOT rules apply (refunds and bump compensation, no fixed delay cash). If it's international (departing from the US): go to question 3.

3. 3

   Is the airline a US carrier or a foreign carrier departing the US? Either way: DOT rules apply to the US departure. Check separately whether the return leg triggers EU261 or UK261 based on where it departs from.

4. 4

   Did the disruption happen on a connecting flight booked as a single itinerary? If yes, and the booking departed from an EU or UK airport at any point in the journey: EU261 or UK261 may still apply to the downstream disruption, even if the individual delayed segment was US-based.

If you're still unsure after the decision tree, TravelStacks will assess your claim for free before you commit to filing. We check which law applies, whether your flight qualifies, and what the estimated payout is.