When the UK left the EU it copied Regulation 261/2004 into domestic law almost word for word. The result, UK261, pays the same money for the same disruptions on the same thresholds.
Three things genuinely differ, and one of them works strongly in your favour.
The short answer
Delayed three or more hours, cancelled with under 14 days’ notice, or denied boarding on a UK-linked flight, with the airline at fault:
| Flight distance | UK261 | EU261 |
|---|---|---|
| Up to 1,500 km | £220 | €250 |
| 1,500 to 3,500 km | £350 | €400 |
| Over 3,500 km | £520 | €600 |
The three hour threshold is identical. So is the list of what counts as extraordinary circumstances, and so is the airline’s duty to feed and house you while you wait.
What actually changed
You are paid in pounds, at fixed statutory amounts. Not a converted euro figure. Depending on the exchange rate that can be slightly more or slightly less than the EU equivalent, and it does not track the euro.
The regulator is the CAA. The Civil Aviation Authority enforces UK261. Complaints escalate to the CAA, or to whichever approved dispute resolution scheme the airline belongs to, rather than to an EU national enforcement body.
UK courts are no longer bound by the Court of Justice of the EU. Under section 6(1) of the European Union (Withdrawal) Act 2018, UK courts do not have to follow CJEU decisions made after the end of the implementation period.
In practice that third point has changed little so far. UK courts have continued to apply the rulings that matter most, including Wallentin-Hermann and van der Lans on technical faults, and Sturgeon on the three hour threshold. But the two systems can now diverge, and over time they probably will. If you are claiming in the UK for a flight several years old, that is worth remembering: the law that applied then still applies to your claim.
The big advantage: years, not months
This is the difference worth knowing about.
| Where you claim | Time limit |
|---|---|
| England, Wales, Northern Ireland | 6 years |
| Scotland | 5 years |
| EU, currently | 1 to 10 years depending on country |
| EU, from 2027 | 9 months |
The EU’s 2026 reform brings in a uniform nine month deadline from 2027. The UK has no plan to match it. A UK claim from several years ago may well still be live, which is worth checking if you have had a bad flight at any point since 2020 and never got round to claiming.
Which flights are covered
UK261 covers any flight departing a UK airport on any airline, and flights arriving in the UK on a UK or EU carrier.
EU261 separately covers flights departing the EU, and flights arriving in the EU on an EU carrier.
There is real overlap. London to Madrid departs the UK and arrives in the EU, so both regimes can apply. You cannot claim twice, but you can pick whichever suits you: usually the higher amount at the current exchange rate, or the longer deadline.
What is not covered catches people out constantly: New York to Manchester on a US carrier. It does not depart the UK, and the airline is neither UK nor EU.
The halving rule on long-haul
On flights over 3,500 km, if the airline re-routes you and you land less than four hours late, they can pay £260 instead of £520.
The compensation checker applies the sterling amounts automatically when you departed a UK airport, and names the Civil Aviation Authority as the body to escalate to.
Watch how that interacts with the threshold. At three hours you qualify. At three and a half you are probably getting half. At four hours and one minute you get the full amount. So the exact arrival time matters, and arrival means the moment the aircraft doors open, not when the wheels touch down.
If you are anywhere near that boundary, get evidence of the actual door-open time. Cabin crew announcements, a timestamped photo, or the airline’s own operational data through a subject access request will all do.
How to claim
Claim direct first, citing “UK Regulation 261/2004 as retained in UK law”, with the flight number, date, distance band and amount.
If they refuse or go quiet after eight weeks, escalate free to the airline’s dispute resolution scheme. Most UK carriers belong to AviationADR or CEDR. If they belong to neither, go to the CAA.
Money Claim Online is the last resort. It is built for people without lawyers, and the fee is recoverable if you win.
If the first answer is no, that is not the end of it. The dispute schemes and the small claims track exist because airlines and passengers disagree about what counts as extraordinary, and an independent look often goes the passenger’s way.
Frequently asked questions
Can I claim under both UK261 and EU261? Not for the same flight. Where both apply, pick one, usually whichever pays more or gives you longer.
Does the 2026 EU reform affect UK rules? No. The free cabin bag, the nine month deadline and the seating rules are EU changes. The UK has not matched them.
What about a connecting flight through the UK? On a single booking what counts is when you reached your final destination and whether the itinerary qualifies. Separate bookings are treated as separate journeys, which is one good reason to book connections on one ticket.
Is my old claim too late? In England and Wales you have six years, so probably not. Check the exact flight date against the limit before assuming.
Sources: UK Civil Aviation Authority, resolving travel problems, Regulation (EC) No 261/2004 as retained in UK law, the European Union (Withdrawal) Act 2018 section 6(1), and the Court of Justice rulings in Sturgeon v Condor (C-402/07), Wallentin-Hermann v Alitalia (C-549/07) and van der Lans v KLM (C-257/14).
Researched from primary sources and checked August 2026. General information, not legal advice.
