UK261 Flight Compensation After Brexit: What Changed?
After Brexit, the UK retained EU261 as "UK261" — almost unchanged. The thresholds are identical, the extraordinary circumstances defence is the same, and care rights are equivalent. The main differences are the amounts (in GBP rather than EUR) and the scope for inbound non-UK flights.
Quick answer
UK261 is essentially EU261 in GBP: £220 (up to 1,500 km), £350 (1,500–3,500 km), £520 (over 3,500 km). Same 3-hour delay threshold. Same 14-day cancellation rule. For UK passengers flying from EU airports — EU261 still applies on that direction.
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EU261 vs UK261: Side-by-Side Comparison
| Aspect | EU261 | UK261 |
|---|---|---|
| Delay threshold for compensation | 3+ hours arrival delay | 3+ hours arrival delay (same) |
| Cancellation notice threshold | Less than 14 days before departure | Less than 14 days before departure (same) |
| Short-haul compensation (≤1,500 km) | €250 | £220 |
| Medium-haul compensation (1,500–3,500 km) | €400 | £350 |
| Long-haul compensation (>3,500 km) | €600 | £520 |
| Care rights (meals, hotel) | Article 9 — same obligations | Equivalent provisions — same obligations |
| Extraordinary circumstances defence | Applies | Applies (same rules) |
| Applicable to inbound non-UK flights | EU carriers only | UK carriers only (BA, Virgin, easyJet UK, etc.) |
| Enforcement body | National bodies (CAA, DGAC, LBA, etc.) | CAA (Civil Aviation Authority) |
| ADR scheme (UK) | Various national schemes | CEDR Aviation, AviationADR |
Which Regulation Applies to Your Flight?
The key question is where the flight departs from:
- Departing from a UK airport → UK261 applies (regardless of airline or destination)
- Departing from an EU airport → EU261 applies (regardless of whether you are a UK or EU citizen)
- Departing from a non-EU, non-UK airport → depends on the airline: EU carrier = EU261, UK carrier = UK261, non-EU/UK carrier = neither
How to Enforce UK261
The UK Civil Aviation Authority (CAA) oversees UK261 enforcement. Process:
- Submit claim directly to the airline
- If rejected or ignored after 8 weeks: escalate to CEDR Aviation or AviationADR (both CAA-approved ADR schemes)
- If ADR fails or airline is not a member: file in small claims court (MCOL for claims up to £10,000 in England & Wales)
Frequently Asked Questions
Can I still claim EU261 for flights from the UK after Brexit?
For flights departing from UK airports, EU261 no longer applies — UK261 does. For UK passengers flying from EU airports (e.g., returning from Paris CDG), EU261 still applies to that flight. So a British passenger flying Paris → London would claim under EU261 (departure from EU), while London → Paris would be covered by UK261.
The amounts are lower in UK261 than EU261 — why?
UK261 amounts were set at an approximate GBP equivalent of the EU261 EUR amounts when the legislation was retained in UK law after Brexit. They are not dynamically linked to exchange rates and have not been updated since. At current rates, the GBP amounts are somewhat lower in USD/EUR terms than the EU261 equivalents, but the legal framework is the same.
Which airlines does UK261 cover?
For flights departing from UK airports: all airlines (same as EU261's Rule 1). For flights arriving in the UK from outside: only UK-licensed carriers — primarily British Airways, Virgin Atlantic, easyJet (UK entity), Jet2, TUI Airways, Loganair, etc. Non-UK airlines (Ryanair — Irish entity, Wizz Air, Air France, etc.) operating inbound non-UK flights are not covered under UK261 for that direction.
I flew from London to Ibiza on Ryanair — does UK261 or EU261 apply?
UK261 applies — the flight departed from a UK airport (London). Ryanair's Irish registration doesn't matter for this rule; the departure airport determines which regulation applies. So you claim under UK261 with its GBP amounts (£220 for this short-haul route).
The CAA rejected my UK261 claim — what can I do?
The CAA handles enforcement complaints when airlines reject claims. If the CAA declines to take enforcement action, you can still escalate via CEDR Aviation (approved ADR for most UK airlines) or file in small claims court (England & Wales: MCOL; Scotland: Simple Procedure). The CAA's enforcement decision doesn't prevent you from pursuing the claim privately.
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