Which is the best passenger rights regime for flight delays: EU261, US DOT, or APPR?

EU261 is the strongest for fixed delay compensation. US DOT is the strongest for mandatory refunds on cancellations. APPR combines elements of both. The 'best' regime depends on your route and disruption type.

Does EU261 apply to flights from the US?

EU261 applies to US-originating flights operated by EU or UK carriers. A British Airways flight from New York to London is covered by UK261 (the UK version of EU261). A United Airlines flight from New York to London is covered by EU261 only for the London-to-New York return leg (EU departure).

Can I claim under more than one regime for the same flight?

In theory, some routes are covered by multiple regimes. A US carrier flying from Canada to Europe could face both APPR (Canadian departure) and EU261 (European arrival on a US carrier where EU carrier rules apply). In practice, passengers typically invoke one regime based on their departure airport and carrier.

Why does the US not have fixed delay compensation like EU261?

The US relies on market forces and voluntary airline commitments rather than mandated fixed compensation for delays. US DOT has issued customer service rules requiring refunds and voluntary commitments on amenities, but Congress has not enacted EU261-equivalent legislation.

I fly frequently between Canada and the EU. Which rights apply?

For Canadian departures: APPR. For EU departures: EU261 (or UK261 for UK airports). For transatlantic routes, each leg is typically governed by the departure country's regime. Check both your outbound and return legs separately.

Does the US DOT require airlines to pay for meals during delays?

Not by law for all carriers. Major US airlines have voluntarily committed (through DOT customer service plans) to providing meals for delays of 3+ hours caused by the airline. Weather delays are typically not covered by these voluntary commitments. EU261 and APPR mandate meals as a right.

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Passenger RightsMay 2, 2026•8 min read

EU261 vs US DOT vs APPR: The Ultimate Global Passenger Rights Guide

Loren Castillo

Founder, TravelStacks

EU261, the US DOT framework, and Canada's APPR are the world's three most important passenger rights regimes. Here is a complete side-by-side comparison of what each requires, what each pays, and which applies to your flight.

Quick Comparison

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Regime: EU Regulation 261/2004 (EU261) vs US DOT Rules vs Air Passenger Protection Regulations (APPR)
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Jurisdiction: EU/UK departures (any carrier) + EU/UK carriers globally (EU261) vs US domestic + US departures on any carrier (US DOT) vs Canadian departures (any carrier) + Canadian carrier arrivals (APPR)
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Fixed delay compensation: Yes, 250 to 600 euros by distance (EU261) vs No fixed compensation for delays (US DOT) vs Yes, CAD $400 to $1,000 for large carriers (APPR)
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Refund for cancellations: Yes, Article 8 (EU261) vs Yes, mandatory DOT refund (US DOT) vs Yes, with rebooking options (APPR)
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Denied boarding compensation: Yes, 250 to 600 euros (EU261) vs Yes, $775 to $1,550 (US DOT) vs Yes, CAD $900 to $2,400 (APPR)
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Care rights: Yes, meals + hotel (EU261) vs Varies by airline + DOT customer service plans (US DOT) vs Yes, meals + hotel (APPR)
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Best for: Long-haul delays from EU airports, compensation regardless of ticket cost (EU261) vs Cancellations and denied boarding on US routes, fast mandatory refunds (US DOT) vs Long delays on Canadian routes, rebooking on competitor carriers (APPR)
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Verdict: EU261 is the strongest for delay compensation. US DOT is strongest for mandatory refunds. APPR bridges both with delay compensation and strong rebooking rights.

US DOT: Strong on Refunds, Weak on Delay Compensation

The US Department of Transportation does not require airlines to pay fixed compensation for flight delays (unlike EU261 and APPR). The DOT's strength is in mandatory refund rights: airlines must refund cancelled or significantly changed flights promptly, regardless of fare type.

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Mandatory refunds: Airlines must refund cancelled or significantly changed flights to the original payment method within 7 business days (credit card) or 20 calendar days (cash).
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Denied boarding: Up to $775 for delays of 0 to 2 hours, up to $1,550 for delays over 2 hours at the domestic destination.
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No fixed delay compensation: A 5-hour mechanical delay on a US domestic flight does not entitle you to any mandated cash payment beyond your ticket refund if you choose not to fly.
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DOT Customer Service Plans: Major US airlines have voluntarily committed to providing meals for delays of 3+ hours and hotels for overnight delays. These are not legally mandated for all carriers.

For the full US DOT framework, see how to get a refund from an airline.

EU261: The Gold Standard for Delay Compensation

EU Regulation 261/2004 is the most generous of the three frameworks for flight delay compensation. Fixed cash amounts regardless of ticket price, broad coverage (any carrier departing EU airports, EU carriers on all routes), and a 3-hour arrival delay trigger make EU261 the benchmark.

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250 euros: Flights up to 1,500 km with 3+ hour arrival delay.
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400 euros: Flights 1,500 to 3,500 km with 3+ hour arrival delay.
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600 euros: Flights over 3,500 km with 3+ hour arrival delay.
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Refund right: Full refund for cancellations regardless of cause (care exception applies).
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EU carrier global coverage: EU261 applies to EU-registered carriers even on routes departing outside the EU (e.g., a British Airways flight from New York to London is covered by UK261 on the New York departure because BA is a UK carrier).

For the full EU261 rights framework, see the EU261 rights overview.

APPR: The Balanced Middle Ground

Canada's APPR combines elements of both EU261 (fixed compensation) and US DOT (strong mandatory refunds) with added rebooking rights requiring airlines to book passengers on competitor carriers when necessary.

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CAD $400 to $1,000 for delays of 3+ hours on large carriers when within airline control.
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Strong refund rights for cancellations and significant delays.
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Competitor carrier rebooking if the airline cannot rebook within 9 hours.
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Communication requirements: Airlines must update passengers every 30 minutes during delays.

For the full APPR guide, see Canadian APPR rules. For Air Canada specifically, see Air Canada delay rights and APPR. For the EU261 vs APPR head-to-head, see EU261 vs APPR comparison.

Which Regime Applies to Your Specific Flight

Understanding which regime applies to your specific flight is the most practically important question.

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New York to London (US carrier): US DOT for the New York departure. UK261 for the London departure return.
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New York to London (British Airways): UK261 applies to both legs because BA is a UK carrier. US DOT also applies to the US departure.
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Toronto to London (Air Canada): APPR for the Toronto departure. UK261 for the London departure return.
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Toronto to Chicago (United): APPR for Toronto departure (Canadian airport). US DOT for the Chicago departure return.
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US domestic flights: US DOT only. No EU261 or APPR coverage.
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EU to Australia: EU261 applies for the EU departure. Montreal Convention applies for both legs.

Denied Boarding: How All Three Compare

Denied boarding (involuntary bumping) compensation varies significantly across the three regimes.

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US DOT (IDB): $775 (0 to 2 hours delay) or $1,550 (2+ hours delay) at destination. Cash or check.
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EU261: 250 to 600 euros based on distance.
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APPR (large carrier): CAD $900 to $2,400 based on delay at destination.

For a transatlantic route, a passenger involuntarily bumped at a US airport on a US carrier is covered by US DOT IDB rules. The same passenger bumped at a European airport is covered by EU261 IDB rules. Different amounts apply.

Frequently Asked Questions

Common questions about how EU261, US DOT, and APPR compare globally.

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