UK261 vs EU261: Key Differences for Passengers After Brexit
UK261 is the post-Brexit equivalent of EU261 — nearly identical in structure but with pounds instead of euros, CEDR as the ADR body, and the UK's generous 6-year limitation period. Here is exactly how the two regulations compare and which one applies to your flight.
Quick answer
UK airport departure → UK261 (£220/£350/£520), CEDR escalation, 6-year deadline. EU airport departure → EU261 (€250/€400/€600), national ADR, country-specific deadline. The rules are nearly identical — only currency, enforcement and deadline differ.
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Side-by-Side Comparison
| Feature | EU261 | UK261 |
|---|---|---|
| Regulation name | EU Regulation 261/2004 | UK Air Passenger Rights Regulations 2019 |
| Territory covered | All EU airports (27 countries) | All UK airports (England, Scotland, Wales, Northern Ireland) |
| Short-haul compensation | €250 (≤1,500 km) | £220 (≤1,500 km) |
| Medium-haul compensation | €400 (1,500–3,500 km) | £350 (1,500–3,500 km) |
| Long-haul compensation | €600 (>3,500 km) | £520 (>3,500 km) |
| Limitation period | Varies by country (1–5 years) | 6 years (UK Limitation Act 1980) |
| Enforcement body | National aviation bodies (DGAC, LBA, ILT...) | UK Civil Aviation Authority (CAA) |
| ADR scheme | Per country (SÖP, Médiateur, etc.) | CEDR Aviation (UK-wide) |
| EU carriers on return | Covered both directions | UK carriers covered both directions |
| Non-EU/UK carrier on return | NOT covered on non-EU departure | NOT covered on non-UK departure |
Frequently Asked Questions
Does UK261 still apply to EU airlines after Brexit?
Yes. UK261 applies to all airlines departing from UK airports, including EU carriers like Ryanair, easyJet, Wizz Air, Vueling, and all others. If your Ryanair flight departed from London Stansted, UK261 applies regardless of where Ryanair is registered. The regulation also applies to UK-registered carriers arriving at UK airports from anywhere in the world.
I flew London–Paris–Rome connecting. Which regulation applies?
Each flight segment is assessed independently for the departing airport. London–Paris: UK261 applies (UK departure). Paris–Rome: EU261 applies (EU departure). If your disruption was on the Paris–Rome segment, you'd claim under EU261 from the French/Italian enforcement body. If it was London–Paris, UK261 applies and CEDR is your escalation route. If the disruption caused you to miss the Paris–Rome connection, the single-booking rule may allow a UK261 claim against the operating carrier for the entire journey.
Is the UK261 ADR scheme CEDR the same as the EU ADR schemes?
CEDR Aviation (Centre for Effective Dispute Resolution) is the UK CAA-approved ADR scheme for aviation passenger rights. It is separate from EU national ADR bodies like Germany's SÖP, France's Médiateur du Tourisme, or Netherlands' Geschillencommissie. CEDR handles UK261 claims from UK airport departures. EU ADR bodies handle EU261 claims. Both are free for passengers and their decisions are binding on participating airlines.
My EU261 claim was already rejected — can I also claim UK261 for the same flight?
No — a flight is covered by either EU261 or UK261, not both. If your flight departed from an EU airport, EU261 applies. If it departed from a UK airport, UK261 applies. A UK airport departure cannot be subject to EU261, and vice versa. If your claim was rejected, escalate within the same regulatory framework: EU261 rejection → national ADR/enforcement body; UK261 rejection → CEDR Aviation.
Which gives more compensation — EU261 or UK261?
The compensation tiers are functionally similar, but expressed in different currencies. EU261 at €600 long-haul is broadly equivalent to UK261 at £520 long-haul at typical exchange rates, though the exact comparison shifts with currency movements. The UK261 6-year limitation period is more generous than most EU countries (Belgium 1 year, Netherlands 2 years, Italy 2 years, Germany 3 years). France and Spain match at 5 years. UK passengers generally have the most time to file.
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