Is UK261 basically the same as EU261?

Yes, in most respects. UK261 was enacted by copying EU261 into UK law at the point of Brexit. The rules for when it applies, what counts as extraordinary circumstances, and the delay thresholds are essentially identical. The main differences are the currency (GBP vs EUR), the enforcement body (UK CAA vs EU national bodies), and the specific flights covered.

Which applies on a London to Paris flight?

On a UK-departure London to Paris flight, UK261 applies. On a Paris to London return, EU261 applies on the EU-airport departure. If the carrier is a UK carrier (British Airways), UK261 also applies on the EU-departure Paris to London leg because UK261 covers UK carriers arriving in the UK from non-UK airports.

Is EU261 compensation worth more than UK261?

At current exchange rates, EU261 amounts in EUR are often worth slightly more than UK261 amounts in GBP (for example, 600 EUR vs 520 GBP). The difference fluctuates with the pound-euro exchange rate. Check the current rate when comparing a specific claim.

Can I claim under both UK261 and EU261 for the same flight?

You can file claims under both if both technically apply (for example, a Paris to London flight on British Airways). However, you can only recover compensation once. You cannot collect 600 EUR under EU261 and £520 under UK261 for the same delay: you choose one recovery.

Does UK261 apply to Ryanair flights?

Ryanair has separate legal entities. Ryanair DAC (the Irish entity) is the EU carrier for most routes and falls under EU261. Ryanair UK is a separate UK carrier registered in the UK for UK routes and falls under UK261. Which entity is operating your specific flight determines which regulation applies.

Does UK261 cover flights entirely within the UK?

UK261 covers flights that are international in nature: departing from UK airports to non-UK destinations, or UK carrier flights from non-UK airports to the UK. Domestic UK flights (such as London to Edinburgh) operated by UK carriers may fall under a different framework or domestic UK consumer law rather than UK261 specifically.

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Passenger RightsMay 2, 2026•8 min read

UK261 vs EU261: Post-Brexit Passenger Rights Differences Explained

Loren Castillo

Founder, TravelStacks

UK261 and EU261 are nearly identical in structure but differ in currency (GBP vs EUR), enforcement authority, and the scope of flights covered post-Brexit. This comparison explains when each applies, how much you can claim, and which regulation covers flights between the UK and EU.

Quick Comparison

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Full name: UK261 (UK Air Passenger Rights and Air Travel Organisers Licencing Amendment 2019) 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 jurisdiction: UK261 covers UK airport departures (all carriers) + UK carrier flights to UK. EU261 covers EU airport departures (all carriers) + EU carrier flights to EU.
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Enforcement authority: UK261 = UK Civil Aviation Authority (CAA) and approved ADR schemes. EU261 = national enforcement bodies in each EU member state.
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Extraordinary circumstances defense: Identical in both regulations.
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Best for: UK261 for delays on UK-departure flights or UK carrier flights. EU261 for delays on EU-departure flights or EU carrier flights.
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Verdict: Nearly identical rights; the main practical difference post-Brexit is which currency and which enforcement body handles your claim.

Which Regulation Covers Your Flight

The fundamental rule for both regulations is the same: coverage is anchored to the departure airport and the carrier's nationality. Here is how to determine which regulation applies to a UK-EU journey.

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London Heathrow (LHR) to Paris CDG on British Airways: UK261 applies (UK airport departure).
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Paris CDG to London Heathrow on British Airways: EU261 applies (EU airport departure). UK261 also applies because BA is a UK carrier on a non-UK to UK route.
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London Heathrow to Amsterdam on KLM: UK261 applies (UK airport departure).
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Amsterdam to London Heathrow on KLM: EU261 applies (EU airport departure).
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London Heathrow to New York on Virgin Atlantic: UK261 applies (UK airport departure, UK carrier to non-UK).
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New York to London Heathrow on British Airways: UK261 applies (UK carrier arriving in UK from non-UK).
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New York to Paris CDG on American Airlines: Neither regulation applies on this US-departure non-EU/non-UK carrier leg. Montreal Convention governs.

Compensation Amounts: GBP vs EUR

The compensation amounts in UK261 and EU261 were designed to be equivalent at the time of Brexit but are expressed in different currencies and will diverge over time with exchange rate movements. When the pound is weaker than the euro, EU261 claims in EUR may be worth more in absolute terms.

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Short-haul (under 1,500 km): UK261 £220 / EU261 €250. A delay on a London-Edinburgh route would be governed by domestic UK law, not UK261 (UK261 covers international routes).
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Medium-haul (1,500 to 3,500 km): UK261 £350 / EU261 €400. Covers UK-EU routes and similar distances.
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Long-haul (over 3,500 km): UK261 £520 / EU261 €600. Covers transatlantic and long-haul routes.
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50% reduction rule: Identical in both. If you were rerouted and arrived within 4 hours of your original arrival time (long-haul), compensation is halved.

Enforcement: UK CAA vs EU National Bodies

Under EU261, each EU member state designates its own National Enforcement Body (NEB) to handle complaints and issue compliance orders. For a claim against British Airways on a Paris departure, you would escalate to the French DGAC. For a KLM delay in Amsterdam, the Dutch ACM handles enforcement.

Under UK261, enforcement is handled by the UK Civil Aviation Authority (CAA). The CAA investigates systemic non-compliance but does not directly adjudicate individual passenger claims. Individual UK261 claims that airlines refuse are resolved through approved Alternative Dispute Resolution (ADR) schemes (CEDR or Aviation ADR) or the courts. For the full escalation process, see the guide to UK Civil Aviation Authority complaints.

Extraordinary Circumstances: Identical Defense

Both regulations use the same extraordinary circumstances defense. Airlines are not required to pay compensation if the delay or cancellation was caused by extraordinary circumstances that could not have been avoided even if all reasonable measures had been taken. The definition of extraordinary circumstances has been refined by court decisions in both the UK and EU.

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Qualifies: Severe weather, political instability, security threats, hidden manufacturing defects discovered mid-fleet, airport authority decisions.
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Does not qualify: Routine technical faults, typical bad weather that should have been anticipated, airline crew shortages from poor scheduling.
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Key case law: The UK Supreme Court and EU Court of Justice have issued consistent rulings on extraordinary circumstances, and UK courts continue to follow this precedent.

UK-EU Flights After Brexit: Which Regulation Applies

For flights between UK and EU airports, both regulations can potentially apply, and in some cases, both do. This redundancy is generally good for passengers: if one regulation's claim process is slower, the other may be more efficient.

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UK departure to EU destination (any carrier): UK261 applies.
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EU departure to UK destination (any carrier): EU261 applies.
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EU departure to UK on a UK carrier (BA, Virgin): EU261 applies (EU departure). UK261 also applies (UK carrier to UK). Claim under either.
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UK departure to EU on an EU carrier (Ryanair Irish entity, Wizz Air, easyJet Europe): UK261 applies (UK departure). Confirm which Ryanair or easyJet legal entity is operating.

For more detail on individual airline claims, see the Ryanair UK261 guide and easyJet UK261 guide. For all UK261 rights, see the complete UK261 passenger rights overview.

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