EU261 is the EU/EEA passenger-rights regulation; UK261 is the UK’s retained parallel regime after Brexit. Both can require care and fixed compensation on qualifying flights, but territory, airline and currency bands differ — check which frame fits your ticket.
What is the difference between UK261 and EU261?
EU261 (Regulation 261/2004) covers qualifying flights in the EU/EEA framework. UK261 is the UK’s retained parallel passenger-rights regime after Brexit. Both can require care during disruption and fixed compensation for certain delays, cancellations and denied boarding — but eligibility turns on route, operating airline and which legal territory applies.
For the fuller EU-side rules, read EU261 compensation complete rules. For a global overview, see flight delay compensation rights. Screen a case in the compensation checker, then follow how to claim flight compensation DIY or a specialist such as AirHelp. operating carrier on each segment.
Brexit did not delete passenger rights in the UK; it created a sibling rulebook. Do not assume an EU airline into a non-EU airport automatically answers to both.
Which flights typically fall under each regime?
As a planning rule of thumb, flights departing EU/EEA airports often engage EU261, while flights departing the UK often engage the UK regime. Arrivals can qualify when the operating carrier is based in that regulatory area — confirm the details for your ticket.
Codeshares use the operating carrier, not only the logo on the booking email. A UK departure on a non-UK airline still needs careful reading. Multi-city tickets can touch both regimes across different segments.
| Planning scenario | Often start with | Confirm |
|---|---|---|
| Departing an EU/EEA airport | EU261 | Operating carrier + delay at final arrival |
| Departing a UK airport | UK261 | Airline and ticket conditions |
| Arriving in EU on EU carrier | EU261 lens | Marketing vs operating carrier |
| Arriving in UK on UK carrier | UK261 lens | Full itinerary timestamps |
| Non-UK/non-EU to non-UK/non-EU | Usually neither | Contract of carriage + insurance |
How do compensation bands and care duties compare?
Both frameworks use distance and delay-at-arrival logic for cash bands and both expect airlines to provide care (meals, communication, hotels when overnight) during long waits. UK amounts are expressed in sterling; EU amounts in euros.
At the time of writing, common planning figures sit around €250/€400/€600 under EU261 and roughly £220/£350/£520 under the UK regime for qualifying distance bands — treat these as orientation, not a guarantee. current official amounts and whether extraordinary circumstances are argued.
Care duties can remain even when cash compensation is refused. Keep receipts for food and hotels. Denied boarding has its own notice rules in both systems.
- Note scheduled vs actual arrival times
- Keep boarding passes and delay notices
- Save meal and hotel receipts
- Record the operating carrier
- Claim with the airline before paying large success fees
How should you choose a claim path?
Identify which regime fits, gather evidence, claim with the airline first, then escalate to the relevant enforcement or ADR route — or use a specialist if you prefer to trade a fee for convenience.
DIY is slower but keeps the full amount when you win. Specialists such as AirHelp take a cut on success. Either path needs the same timeline: booking reference, flight numbers, arrival delay and reason codes if the airline shares them. claim deadlines for your case.
If your itinerary straddles UK and EU segments, analyse each disrupted arrival separately. One successful claim frame does not automatically cover every leg of a multi-city trip.
Write the claim letter with the regulation name you believe applies, the flight numbers, the arrival delay in hours and the distance band you used for the amount. Attach PDFs, not only screenshots. Polite, complete files move faster than angry one-liners.
If the airline cites extraordinary circumstances, ask for a short explanation of the event chain. Knock-on crew or technical issues are argued differently from severe weather. You do not need to win a legal seminar in the first email — you need a clear timeline. national enforcement body contacts if the airline stonewalls past a reasonable window.
Package holidays can add organiser duties alongside airline duties. Keep both contracts. Statutory passenger rights and package remedies are not always mutually exclusive, yet the claim address may differ.