Is UK261 basically the same as EU261?

Yes, in structure, rules, and most substantive provisions. UK261 was enacted by retaining EU261 in UK law at Brexit. The main differences are the currency (GBP vs EUR), the enforcement system (UK CAA and ADR vs EU national bodies), and the specific flights each covers.

Which applies for a flight from London Heathrow to Paris CDG?

UK261 applies on the Heathrow-departure leg (UK airport). EU261 applies on the CDG-departure return leg (EU airport). If the carrier is British (BA), UK261 also applies on the CDG to LHR direction because BA is a UK carrier arriving in the UK.

Is EU261 compensation worth more than UK261 in USD?

At current exchange rates, EU261 amounts in EUR tend to be worth more in USD than UK261 amounts in GBP. For example, 600 EUR is typically worth more than £520 in USD. However, exchange rates fluctuate.

Can I file both UK261 and EU261 claims for the same delay?

You can file under both if both technically apply to the same leg (for example, a British carrier on an EU-departure flight). However, you can only collect compensation once for the same delay. You cannot stack both payments.

Does Ryanair fall under UK261 or EU261?

Ryanair has two entities post-Brexit. Ryanair DAC (Irish entity) is the EU carrier for most routes, covered by EU261. Ryanair UK is the UK entity for UK-specific routes, covered by UK261. Check which entity is operating your specific flight.

What is the time limit to file a UK261 claim?

UK261 claims have a limitation period of six years in England and Wales, five years in Scotland. However, file promptly. Evidence fades, airlines may close their records, and earlier filing typically leads to faster resolution.

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UK261May 2, 2026•8 min read

UK261 vs EU261 After Brexit: Which Rights Apply to Your Flight?

Loren Castillo

Founder, TravelStacks

Post-Brexit, UK261 and EU261 are nearly identical regulations that apply to separate sets of flights. UK261 covers UK-airport departures and UK carrier arrivals into the UK. EU261 covers EU-airport departures and EU carrier arrivals into the EU. This comparison explains which applies to your specific flight.

Quick Comparison

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Short name: UK261 (UK retained EU law) vs EU261 (EU Regulation 261/2004)
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Short-haul compensation: UK261 £220 vs EU261 €250
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Medium-haul compensation: UK261 £350 vs EU261 €400
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Long-haul compensation: UK261 £520 vs EU261 €600
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Departure coverage: UK261 = UK airport departures (all carriers). EU261 = EU airport departures (all carriers).
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Carrier coverage: UK261 = UK carrier flights to UK from non-UK airports. EU261 = EU carrier flights to EU from non-EU airports.
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Enforcement: UK261 = UK CAA + ADR (CEDR, Aviation ADR). EU261 = national enforcement bodies in each EU state.
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Extraordinary circumstances: Identical definition in both regulations.
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Best for: UK261 for UK flights and UK carriers. EU261 for EU flights and EU carriers.
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Verdict: Nearly identical rights. Main practical difference is currency (GBP vs EUR) and enforcement authority.

Which Regulation Covers Your Flight

The determining factors are the departure airport and the carrier's nationality. Post-Brexit, the UK is a separate regulatory jurisdiction from the EU. Flights between UK and EU airports can simultaneously fall under both regulations: UK261 on the UK-departure leg and EU261 on the EU-departure leg.

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London Heathrow to Paris CDG: UK261 applies (UK departure, any carrier).
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Paris CDG to London Heathrow: EU261 applies (EU departure, any carrier).
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CDG to LHR on British Airways: EU261 applies (EU departure). UK261 also applies (UK carrier to UK). Claim under either.
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New York to London on BA: UK261 applies (UK carrier arriving UK from non-UK).
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New York to Paris on Air France: EU261 applies (EU carrier arriving EU from non-EU).
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New York to London on United: Neither on the US-departure leg. UK261 on the LHR-departure return.

Compensation Amounts: GBP vs EUR

At Brexit, the UK converted EU261's EUR amounts to GBP at the prevailing rate. The amounts are now fixed independently in each currency and will drift apart over time as the exchange rate moves. When the pound is weaker against the euro, EU261 claims are worth more in absolute USD terms.

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Short-haul (under 1,500 km): UK261 = £220. EU261 = €250. USD equivalent varies.
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Medium-haul (1,500 to 3,500 km): UK261 = £350. EU261 = €400.
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Long-haul (over 3,500 km): UK261 = £520. EU261 = €600.
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Currency at time of claim: If you have a choice between filing UK261 or EU261 (for example, on a UK-EU route operated by a UK carrier departing from an EU airport), check the current GBP/EUR rate and choose the higher-value claim.

Enforcement and Regulators

Under EU261, each EU country has its own National Enforcement Body (NEB). For a claim against a carrier from a Paris-departure flight, you escalate to the French DGAC. For an Amsterdam departure, you escalate to the Dutch ACM. The NEB in the departure country has jurisdiction.

Under UK261, the UK Civil Aviation Authority (CAA) is the primary regulator, but it does not directly resolve individual claims. Passengers must exhaust the airline's internal process and then use an approved ADR scheme (CEDR or Aviation ADR) before pursuing court action. For a detailed walkthrough of UK261 escalation, see the UK Civil Aviation Authority complaints guide.

Extraordinary Circumstances: Identical Standard

Both regulations use the same definition of extraordinary circumstances: events that could not have been avoided even if all reasonable measures had been taken. UK courts post-Brexit continue to follow the EU case law developed before 2021 (when UK courts ceased to be bound by the Court of Justice of the EU), and interpretations remain largely consistent.

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Qualifies: Genuine severe weather, ATC strikes, security threats, political instability at destination, bird strikes causing structural damage.
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Does not qualify: Routine technical faults, ordinary bad weather, crew shortages from poor scheduling.
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Airlines must prove: Both that the circumstances were extraordinary and that all reasonable measures were taken to avoid the delay.

UK-EU Flights After Brexit: Potential Dual Coverage

On UK-EU routes, both regulations can apply to the same journey on separate legs. This rarely creates a conflict: you simply file UK261 for the UK-departure leg and EU261 for the EU-departure leg if both legs are delayed. If both apply to the same leg (for example, a UK carrier on an EU-departure flight), you can claim under either but not both for the same delay.

For airline-specific guidance on UK-EU routes, see the Ryanair UK261 guide and easyJet UK261 guide. For the full UK261 rights overview, see the dedicated rights page. For international passenger rights, see the complete guide.

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