UK261 vs EU261: What Changed After Brexit?
When the UK left the EU, it retained EU261 as UK261 with identical protections. But the rules about which flights are covered and where to escalate changed. Here is a practical breakdown of what UK261 and EU261 each cover after Brexit.
What Changed (and What Didn't)
The core passenger protections are identical. UK261 mirrors EU261 in compensation amounts, delay thresholds, extraordinary circumstances definitions, and duty of care requirements. The main changes are geographic coverage and enforcement.
The protections are the same. The coverage map is different. If you are trying to determine which regulation covers your flight, the key questions are: where did the flight depart, and is the operating airline a UK or EU carrier?
Which Regulation Covers Your Flight
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EU261 covers: Flights departing EU airports (any airline), flights arriving at EU airports on EU carriers.
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UK261 covers: Flights departing UK airports (any airline), flights arriving at UK airports on UK carriers.
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Both may apply: A flight from Paris to London on British Airways could involve both EU261 (EU departure) and UK261 (UK carrier arriving at UK airport).
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Neither applies: A Delta flight from New York to London (non-UK carrier, non-EU departure, arriving in the UK).
For detailed coverage rules, see our EU261 rights guide and UK261 rights guide. For our comprehensive EU261 overview, read the complete EU261 guide.
Compensation Amounts: GBP vs EUR
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Short-haul: €250 (EU261) or £220 (UK261).
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Medium-haul: €400 (EU261) or £350 (UK261).
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Long-haul: €600 (EU261) or £520 (UK261).
The UK amounts are fixed in GBP and do not fluctuate with the EUR/GBP exchange rate. At current exchange rates, the GBP amounts may be slightly higher or lower than the EUR equivalents. For practical purposes, the amounts are nearly identical.
Enforcement After Brexit
For UK261 claims, the enforcement body is the UK Civil Aviation Authority. For EU261 claims, you escalate to the National Enforcement Body in the departure country. The UK CAA no longer handles EU261 complaints for flights departing EU airports.
UK courts remain passenger-friendly. The 6-year limitation period and well-established case law make the UK one of the best jurisdictions for flight compensation claims, even after Brexit.
Practical Tips
If your flight departed from a UK airport, file under UK261 with the UK CAA. If it departed from an EU airport, file under EU261 with the relevant NEB. If both could apply, choose the jurisdiction that is more favorable (usually the one with the longer limitation period). Check your flight and we will determine which regulation applies automatically.