Passengers still ask whether they lost their compensation rights when the UK left the EU. They didn't. The UK copied Regulation 261/2004 into its own law on exit day, and it applies today as "UK261".
RIGHTS
UK261 vs EC261: what changed after Brexit, and what didn't
The UK kept the EU's air passenger rights almost word for word. The real differences after Brexit: the currency, the courts, and who you complain to.
We deal with the airline for you
- Flights from the last 6 years
- Every UK and EU airline
- No win, no fee
Same rules
The eligibility tests are identical: three hours' delay at arrival, cancellation within 14 days, denied boarding, extraordinary circumstances as the only defence. The court decisions that interpret the EU rules (Sturgeon, Wallentin-Hermann, Huzar) still bind UK courts on these points.
What's different
| UK261 | EC261 | |
|---|---|---|
| Applies to | flights departing the UK on any airline; arriving in the UK on a UK or EU airline | flights departing the EU on any airline; arriving in the EU on an EU airline |
| Amounts | £220 / £350 / £520 | €250 / €400 / €600 |
| Complaints | CAA, or the airline's ADR scheme (CEDR or AviationADR) | the national enforcement body of the departure country, or a national ADR scheme |
| Court | county court, six-year limit | the departure country's courts, that country's limit |
Which one applies to my flight?
- London to Madrid on Ryanair: departed the UK, so UK261, £220.
- Madrid to London on Ryanair: departed the EU on an EU airline, so EC261, €250.
- London to New York on British Airways: departed the UK, UK261, £520.
- New York to London on British Airways: arrived in the UK on a UK airline, UK261, £520.
- New York to London on American Airlines: a non-UK, non-EU airline arriving in the UK. Neither: no compensation under these rules.
That last case catches people out. For flights into the UK or EU, the airline has to be a UK or EU carrier.
Unsure which applies? Check my flight: we work it out from the route and the airline.
