UK261 or EU261: Which One Applies to Your Specific Flight?

Which regulation covers your flight depends on where it departs from and which carrier operates it, not which country you’re flying to or which passport you hold. As of September 2026, both EU261 (Regulation (EC) 261/2004, still in force across the EU) and UK261 (the UK’s retained, near-identical version since Brexit) exist side by side, and a flight that touches both the UK and the EU can trigger one, the other, or in some interpretations both — verify current scope directly on europa.eu’s air passenger rights page and the UK Civil Aviation Authority’s site (caa.co.uk) before assuming either applies.

The core question: where does the flight depart from

EU261 applies to flights departing from an airport in an EU member state, regardless of which airline operates it. UK261 applies, in the same way, to flights departing from a UK airport, regardless of carrier. If your flight departs Paris, EU261 is the starting point; if it departs London, UK261 is. This departure-airport rule is the first branch of the decision tree, before carrier nationality matters at all.

The second question: does the carrier matter for arrivals

For a flight arriving into the EU or UK from outside (say, from the US), the departure-airport rule above doesn’t help, since the flight didn’t depart from either zone. In that case, both regimes have historically extended coverage to flights operated by an EU carrier (for EU261) or a UK carrier (for UK261) landing in their respective zone. Whether your specific carrier counts, and whether that rule is still framed the same way in 2026, is exactly the kind of detail that gets amended — check the current wording on the official source before relying on it for a claim.

A UK carrier departing an EU airport

This is the case that is easy to get wrong. A UK-based airline departing from, say, Madrid, is departing from an EU airport — so EU261’s departure rule applies to that flight regardless of the airline’s nationality. UK261 may separately apply if the destination or ticketing conditions bring it in, but the EU departure rule already brings that leg within EU261’s scope.

An EU carrier departing a UK airport

The mirror case: an EU-based airline departing Heathrow is departing a UK airport, so UK261 applies by the departure rule regardless of the airline being EU-based. Don’t assume that “EU airline” alone points you to EU261 — the departure airport decides first.

Table: departure airport decides first

Departure airport	Carrier	Regime that applies first
EU airport	Any carrier	EU261
UK airport	Any carrier	UK261
Non-EU/UK airport	EU carrier arriving in EU	EU261 may extend, check current wording
Non-EU/UK airport	UK carrier arriving in UK	UK261 may extend, check current wording

What compensation actually covers, without a number attached

Both regimes tie compensation to the length of the delay and the flight distance, with amounts published directly in the regulation text and adjusted only through formal amendment, not informally over time. Rather than quoting a figure here that may be out of date by the time you read this, check the current amount on europa.eu (EU261) or caa.co.uk (UK261) for the distance band your flight falls into, as of the date of your flight.

Why this matters before you even board

Knowing which regime covers your itinerary changes where a claim goes if the airline rejects it — under EU261 the escalation is to the national enforcement body of the country where the incident happened, under UK261 to the Civil Aviation Authority or the approved dispute scheme the airline belongs to, as listed on caa.co.uk (last checked: September 2026). This is worth working out at the booking stage, alongside checking what “separate tickets” means for your connection, not after a delay has already happened.

When neither regime clearly applies

A flight departing a non-EU, non-UK airport, operated by a carrier based outside both zones, and arriving somewhere outside both zones too, falls under neither regime — in that case your rights come from the country of departure’s own consumer law, the airline’s contract of carriage, or a separate regional framework if one exists for that route. Don’t assume EU261 or UK261 stretches to cover every flight just because you booked it through a European travel agency.

Extraordinary circumstances: the main exception

Both regimes carve out an exception for delays caused by “extraordinary circumstances” — weather, air traffic control strikes, security threats — where the airline isn’t required to pay compensation even though the delay rule would otherwise apply. An airline’s reference to it is a claim you can check, not a final answer; if a claim is rejected on these grounds, the official guidance on europa.eu or caa.co.uk explains what does and doesn’t qualify, and it’s worth checking rather than accepting the airline’s letter at face value.

Package holidays and connecting itineraries

If your flight is part of a package holiday, a separate framework (the Package Travel Directive in the EU, or its UK equivalent) may run alongside EU261/UK261 rather than instead of it — the two aren’t mutually exclusive. On a connecting itinerary booked as one ticket, EU case law (Case C-537/17) treats the whole itinerary as decided by its first departure airport, not by each individual leg, though this is another detail worth confirming against the current official text for your specific booking.

What to check before you fly

Identify your departure airport first, then check whether the operating carrier’s nationality extends either regime to your specific itinerary, using the official sources above rather than a forum thread. On the day of travel, filing a claim or answering the airline abroad needs data, which is why FlightSIM is installed at home over Wi-Fi before departure, so nothing has to be done on arrival — no QR to hunt, no shop, no passport registration; see the iPhone installation guide or the Android installation guide, with current plans on the pricing page.