# EU261 on transatlantic flights: when €600 applies Source: https://airtravelrights.com/transatlantic-flight-compensation/ > UK261 pays up to £520 on UK-US flights; US airlines owe EU261 on flights leaving the EU, not into it. A DOT refund, when owed, takes 7 business days by card. # Transatlantic flight compensation: EU261, UK261 and flights to the US €600 under EU261 or £520 under UK261 is the top payment on a long transatlantic flight. For EU261 on US flights, direction decides. From an EU or UK airport, any airline is covered, American, United and Delta included. Flying in from the US, the licence decides: an EU or UK airline brings its law along, a US airline does not. Find your row in the matrix below. ## Does EU261 cover flights from the US to Europe? Only 1 kind of airline brings EU261 onto a flight from the US: a Community carrier, licensed by an EU Member State. The Irish Aviation Authority gives its own example: a delayed New York to Dublin flight is covered on Aer Lingus and not covered on American Airlines. Source: Regulation (EC) No 261/2004 art. 3(1)(b), art. 2(c) - eur-lex.europa.eu; Irish Aviation Authority, Air passenger rights - iaa.ie, checked 2026-09-15. | Direction | Operating carrier | Compensation law | |:--|:--|:--| | US to an EU airport | Community carrier, such as Aer Lingus Limited or Deutsche Lufthansa AG | EU261, unless you received benefits or compensation and assistance in the US | | US to an EU airport | US carrier: American Airlines, United Airlines, Delta Air Lines, JetBlue | Neither EU261 nor UK261; US DOT rules apply | | US to an EU Member State | UK air carrier, such as British Airways plc or Virgin Atlantic Airways Limited | UK261, not EU261, unless you received benefits or compensation and assistance in the US | | US to a UK airport | UK air carrier or Community carrier | UK261, unless you received benefits or compensation and assistance in the US | | US to a UK airport | US carrier | Neither UK261 nor EU261; US DOT rules apply | | EU airport to the US | Any carrier, US carriers included | EU261 | | UK airport to the US | Any carrier, US carriers included | UK261 | | One booking from an EU or UK airport with a US connection | Any carrier | EU261 or UK261 on the whole journey, measured at the final destination | | US domestic flight on a separate booking | Any carrier | US DOT rules only, with no federal delay compensation | Read every row by the airline that operated the flight, not the one that sold the ticket: article 3(5) puts the claim on the operating air carrier. Source: Regulation (EC) No 261/2004 art. 3 - eur-lex.europa.eu; UK261 art. 3 - legislation.gov.uk; EU-Switzerland Air Transport Agreement, Annex - eur-lex.europa.eu; Commission, CAA and EASA carrier licence lists, checked 2026-09-15. The line comes from article 3(1)(b): only an EU carrier into the EU brings the law along, meaning an airline licensed by an EU Member State. The EU-Switzerland air transport agreement counts Swiss-licensed airlines too. American Airlines, United Airlines, Delta Air Lines and JetBlue sit on EASA's list of authorised third-country operators. Their flights into the EU fall outside EU261, which is why the [JFK airport page](https://airtravelrights.com/airports/jfk/) tests every New York departure by the operating carrier. On the European Commission's licence list, Aer Lingus Limited holds an Irish licence and Deutsche Lufthansa AG a German one. The one-way rule catches people out. One BA booking began with a Las Vegas to Chicago leg flown by American Airlines. Its holder wrote in a November 2025 passenger report on Reddit's r/Flights: "Odd why they would have this loophole when you do have those rights on non-EU carriers in the other direction." DOT's Fly Rights page points international trips elsewhere: passengers may be able to recover delay expenses under Article 19 of the Montreal Convention by claiming with the airline. Check the "operated by" line on your booking first. If a US airline flew you in, start at [US DOT rules](https://airtravelrights.com/us-dot/); the [American Airlines](https://airtravelrights.com/airlines/american-airlines/) and [Aer Lingus](https://airtravelrights.com/airlines/aer-lingus/) cards hold per-airline detail. ## Does EU261 cover flights from Europe to the US? €600 per passenger is the top EU261 amount on a flight from Europe to the US. Article 3(1)(a) applies EU261 to every airline departing an EU airport, American, United and Delta included. The European Commission treats departures from Iceland, Norway and Switzerland the same way. Source: Regulation (EC) No 261/2004 arts. 3(1)(a), 3(5), 7(1) - eur-lex.europa.eu; Commission Interpretative Guidelines C/2024/5687, footnote 20 - eur-lex.europa.eu, checked 2026-09-15. The departure test ignores the licence: flights departing the EU are covered, whoever flies them. Article 3(5) makes the operating carrier the one you claim from. The delay right itself is case law: in Sturgeon (C-402/07 and C-432/07, 2009), the CJEU held that passengers reaching their final destination three hours or more late may claim article 7 compensation, subject to extraordinary circumstances. Connections count as one journey. Wegener (C-537/17, 2018) treats connecting flights on one reservation as a single unit of transport, and Folkerts (C-11/11, 2013) measures the delay at the final destination. A passenger report on Reddit's r/delta from August 2026 shows the effect on a US onward leg: "Delta paid me €300 in cash x 4 people (€1200) because our fight from CDG-SEA-PDX was delayed and we got to our final destination 3 hrs and 15 min later than scheduled." The protection ends where the booking ends. A Chicago to Denver flight bought on a separate ticket is a US domestic trip. Fly Rights says that for domestic itineraries "airlines are not required to compensate passengers whose flights are delayed or canceled". Keep the flight home on one booking and note the actual arrival time at your last airport. The [EU261 guide](https://airtravelrights.com/eu261/) and the [Delta Air Lines](https://airtravelrights.com/airlines/delta-air-lines/) and [United Airlines](https://airtravelrights.com/airlines/united-airlines/) cards add the detail. ## Does UK261 cover flights between London and the US? £520 per passenger is the top UK261 amount between London and the US, and the direction test mirrors EU261 with one extra limb. Any airline leaving a UK airport is covered. Flying into the UK from the US, UK261 applies only when a UK air carrier or an EU-licensed Community carrier operates the flight. Source: UK261 arts. 3(1), 7(1) (as substituted by SI 2019/278) - legislation.gov.uk, checked 2026-09-15. UK261 flights to New York from Heathrow include any operated by American Airlines, United or Delta, because article 3(1)(a) tests only the departure airport. The return leg on the same US carrier is not covered. British Airways plc and Virgin Atlantic Airways Limited hold Type A licences from the Civil Aviation Authority. Their flights into the UK are covered. The extra limb reaches into the EU. Article 3(1)(b)(ii) covers a UK air carrier's flight from outside the UK into an EU Member State. A US to Amsterdam flight operated by British Airways plc would fall under UK261, not EU261. The limb does not reach Iceland, Norway or Switzerland. UK261 also writes the connection rule into statute. Article 3(1A), inserted by SI 2023/1370, treats a multi-leg flight booked as a single unit as a whole, departing from the first leg's point of departure. In Gahan v Emirates [2017] EWCA Civ 1530, the Court of Appeal measured a single Manchester booking via Dubai by the delay at the final destination. The ruling binds lower courts in England and Wales. A FlyerTalk passenger report from June 2026 shows it on a US domestic leg: "Booked AA LHR-ORD-MSN. Upon arriving ORD, the ORD-MSN leg was cancelled. App showed crew scheduling issue. Emailed and first reply was cancellation due to weather / ATC. Sent the app screenshot and was provided GBP520." Check the licence of the airline that flew your inbound leg before you pick a currency. The [UK261 guide](https://airtravelrights.com/uk261/) and the [British Airways](https://airtravelrights.com/airlines/british-airways/) and [Virgin Atlantic](https://airtravelrights.com/airlines/virgin-atlantic/) cards carry the detail. ## How much can a transatlantic delay pay: €600 or £520? €600 under EU261 and £520 under UK261 are owed per passenger when a flight over 3,500 km, such as London to New York, reaches the final destination 4 hours or more late, unless extraordinary circumstances apply. From 3 hours up to that line, the carrier may pay half: €300, while the Civil Aviation Authority's delay page gives £260. Source: Regulation (EC) No 261/2004 art. 7(1)-(2) - eur-lex.europa.eu; Sturgeon (C-402/07, 2009), para 63; UK261 art. 7(1)-(2) - legislation.gov.uk; Civil Aviation Authority, Delays - caa.co.uk, checked 2026-09-15. | Distance and outcome | EU261 | UK261 | |:--|:--|:--| | 1,500 km or less, 3 hours or more late | €250 | £220 | | 1,500 to 3,500 km, or intra-EU over 1,500 km (EU261), 3 hours or more late | €400 | £350 | | Over 3,500 km, 3 hours or more but less than 4 hours late | €600, or €300 at the carrier's option | £260 for "between three and four hours" late (CAA) | | Over 3,500 km, 4 hours or more late | €600 | £520 for "more than four hours" late (CAA) | | Over 3,500 km, compensation owed for cancellation or denied boarding, re-routed arrival no more than 4 hours late | €600, or €300 at the carrier's option | £520, or £260 at the carrier's option; the CAA table pays £260 only below 4 hours | | Delayed flight, any distance, less than 3 hours late | Nothing | Nothing | | Worked case, flight over 3,500 km | Per passenger | 4 passengers | |:--|:--|:--| | UK261, London to New York, 3 hours 30 minutes late | £260 (CAA) | £1,040 | | UK261, London to New York, 4 hours 30 minutes late | £520 | £2,080 | | EU261 departure, 3 hours 15 minutes late | €600, or €300 if the carrier cuts it | €2,400 or €1,200 | | EU261 cancellation notified 3 days ahead, replacement 3 hours 50 minutes late | €600, or €300 if the carrier cuts it | €2,400 or €1,200 | | EU261 departure, 2 hours 59 minutes late | Nothing | Nothing | | US domestic flight on a separate booking, 5 hours late | No federal compensation | No federal compensation | On one booking with a [connection](https://airtravelrights.com/missed-connection-compensation/), the band runs by great-circle distance from the first departure airport to the final destination. That holds even if only the last flight ran late (Flightright v Eurowings, C-939/19, CJEU order of 30 April 2020, no official English text). Source: Regulation (EC) No 261/2004 art. 7 - eur-lex.europa.eu; Flightright v Eurowings (C-939/19), order of 30 April 2020 - eur-lex.europa.eu; UK261 art. 7 - legislation.gov.uk; Civil Aviation Authority, Delays and Cancellations - caa.co.uk; DOT Fly Rights - transportation.gov, checked 2026-09-15. Two 50% cuts sit behind those rows, with opposite boundary words. After a cancellation or denied boarding, article 7(2) lets the carrier halve the payment if the replacement arrives no later than 4 hours after the original schedule. The cut is still allowed at exactly 4 hours 0 minutes. The CAA's cancellation table pays £260 only below 4 hours. For a plain delay, Sturgeon allows the cut where the delay is "less than four hours". An EU261 delay of exactly 4 hours 0 minutes earns the €600 long-haul amount in full. The CAA delay page leaves that exact minute unstated. Article 7(2) says "may", so the cut is the carrier's choice. Routes of 3,500 km or less, and EU261 flights within the EU, have no delay cut at all. Enter the distance and the arrival delay in minutes into the [compensation calculator](https://airtravelrights.com/compensation-calculator/). Where UK261 law and the CAA's table disagree on a boundary minute, it shows both readings. ## How do you claim from United, Lufthansa or British Airways? 1 claim goes to 1 airline: the operating air carrier, under article 3(5) of EU261, even when another airline sold the ticket or put its code on the flight. Write to that carrier with the flight number, date, scheduled and actual arrival times and the amount per passenger. Source: Regulation (EC) No 261/2004 arts. 3(5), 7(3) - eur-lex.europa.eu; UK261 art. 7(3) - legislation.gov.uk, checked 2026-09-15. Codeshares follow the operating carrier, not the ticket. One FlyerTalk poster held a partner's ticket for an American Airlines flight from an EU city to Seattle. The July 2026 passenger report reads: "when I reached out to AA, I was told since AS was the ticket issuer, I should file claims with AS." Article 3(5) sends that claim to American Airlines. As of 15 September 2026, a United EU261 claim starts from [United's disruption help page](https://www.united.com/en/us/fly/travel/missed-delayed-or-canceled-flights.html), and an American Airlines EU261 claim from its [Passenger Rights European Union page](https://www.aa.com/i18n/customer-service/support/passenger-rights-european-union.jsp?locale=en_ES). Lufthansa uses its [passenger rights page](https://www.lufthansa.com/us/en/passenger-rights) and British Airways its [claims portal](https://www.britishairways.com/travel/feedbackclaims); the Delta EU261 claim form is the [Exit European Union compensation request](https://www.delta.com/us/en/change-cancel/exit-eu-compensation). Article 7(3) sets the payment form: cash, bank transfer, bank orders or cheques, and travel vouchers only with your signed agreement. A Reddit r/unitedairlines passenger report from July 2026, on a Paris to Newark flight, reads: "On United's customer care compensation form, it defaults to offering 5000 miles or $100 travel cert. I should be able to do better right?" A miles or voucher offer replaces cash only if you sign for it. The [airline payout-times dataset](https://airtravelrights.com/data/airline-compensation-payout-times/) holds passenger reports for two: American Airlines: "Reported by passengers on public forums: compensation received a median of 8.5 days after submitting the claim (n = 4 posts, Jun 2025–Sep 2026)." British Airways: "Reported by passengers on public forums: compensation received a median of 112.5 days after submitting the claim (n = 4 posts, Jan 2025–Sep 2026)." Send the claim in writing, ask for payment in money, and keep the booking page that shows "operated by". > Rather not write to the airline yourself? [AirHelp (third-party claim service)](https://airtravelrights.com/partner/airhelp?ref=atr-cx-transatlantic-m) takes EU261 and UK261 claims on covered transatlantic flights, no win no fee, and keeps a fee from any payout; the [British Airways claims portal](https://www.britishairways.com/travel/feedbackclaims) and the other carrier forms above stay free. ## What if American Airlines or Delta refuses your claim? 8 weeks without an answer, or a final refusal, opens the next step on a UK departure. Delta is an AviationADR member, a free scheme approved by the Civil Aviation Authority. American Airlines and United appear on no approved ADR list, so the CAA's Passenger Advice and Complaints Team (PACT) can consider those complaints. Source: Civil Aviation Authority, Alternative Dispute Resolution and How the CAA can help - caa.co.uk; AviationADR airline members - aviationadr.org.uk, checked 2026-09-15. AviationADR takes complaints about any member airline when the flight involves a UK airport. File within 12 months of the airline's final response. A decision comes in most cases within three months and binds the airline if you accept it; court stays open to you. ADR covers incidents from the last six years, five if you live in Scotland. PACT works differently. It advises whether your complaint is valid and takes it up with the airline. The CAA adds: "we do not have the legal powers to impose a solution on an airline". PACT also will not handle a complaint with less than a year left to take legal action. On an EU departure, complain to the national enforcement body of the country the flight left: the Irish Aviation Authority for Dublin, the DGAC for France or the Luftfahrt-Bundesamt for Germany. For a flight into the EU from the US on a Community carrier, the body of the arrival country is competent. EU261 sets no court deadline of its own; each Member State's limitation rules apply, and in Ireland that is 6 years under the [Statute of Limitations](https://airtravelrights.com/flight-compensation-time-limits/) 1957. Reply to the refusal once, citing article 3(1)(a) and your departure airport. Once you hold a final response, or 8 weeks pass without one, file with AviationADR or PACT, or with the enforcement body of the departure country; the [refused-claim guide](https://airtravelrights.com/airline-refused-compensation/) maps each route. > Still refused on a flight that left an EU or UK airport? [AirHelp (third-party claim service)](https://airtravelrights.com/partner/airhelp?ref=atr-cx-transatlantic-b) handles claims no win no fee and keeps a fee from any payout; [Delta's EU compensation request](https://www.delta.com/us/en/change-cancel/exit-eu-compensation), AviationADR and PACT stay open. ## Can you have EU261 compensation and US refund rights on the same trip? 2 separate rights can sit on one transatlantic ticket. EU261 pays compensation of up to €600 for the disruption. A US refund under 14 CFR 260.6 comes when a flight is not operated or is significantly delayed and you do not accept an alternative. Source: Regulation (EC) No 261/2004 arts. 5(1), 8(1), 12(1) - eur-lex.europa.eu; 14 CFR 260.2 and 260.6 - ecfr.gov, checked 2026-09-15. The two rules ask different questions. Under EU261, a passenger on a cancelled flight chooses between reimbursement within seven days and re-routing, and is still owed article 7 compensation unless an exception applies. The US rule gives a full refund, taxes and ancillary fees included, when the airline offers no alternative, when you reject it, or when you do not respond and the flight departs. On an international itinerary, DOT counts an arrival 6 hours or more later as a significant delay. A prompt refund means 7 business days for a credit card purchase and 20 calendar days for cash, check, debit card or other payment. Cancelling a new booking yourself is a separate matter, covered by the [24-hour cancellation rule](https://airtravelrights.com/us-dot/24-hour-cancellation-rule/). For Delta Air Lines, the [payout-times dataset](https://airtravelrights.com/data/airline-compensation-payout-times/) records: "Reported by passengers on public forums: refund or expense reimbursement received a median of 42 days after requesting it (n = 3 posts, Sep 2024–Aug 2026)." One overlap rule removes a right. EU261 and UK261 do not reach a flight into the EU or the UK if you received benefits or compensation and assistance in the country you left. Article 12(1) also lets an EU261 payment be deducted from any further compensation. Claim the refund and the compensation in separate messages, citing 14 CFR 260.6 in one and article 7 in the other. Flying between Canada and Europe? Check the [Air Passenger Protection Regulations](https://airtravelrights.com/canada-appr/) and [which law covers your flight](https://airtravelrights.com/which-law-covers-my-flight/). General information, not legal advice. For your specific case: ECC-Net / Civil Aviation Authority / US Department of Transportation / a lawyer. ## Sources - Regulation (EC) No 261/2004, arts. 2, 3, 5, 7, 8, 12, 16 - [eur-lex.europa.eu](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32004R0261), checked 2026-09-15. - Regulation (EC) No 261/2004 as it forms part of UK law, arts. 3 and 7 - [legislation.gov.uk](https://www.legislation.gov.uk/eur/2004/261/article/3). - The Aviation (Consumers) (Amendment) Regulations 2023 (SI 2023/1370) - [legislation.gov.uk](https://www.legislation.gov.uk/uksi/2023/1370/made). - Commission Interpretative Guidelines on Regulation (EC) No 261/2004, C/2024/5687 - [eur-lex.europa.eu](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:C_202405687). - Sturgeon, joined cases C-402/07 and C-432/07 (2009), CJEU - [eur-lex.europa.eu](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62007CJ0402). - Folkerts, C-11/11 (2013), CJEU - [eur-lex.europa.eu](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62011CJ0011). - Wegener, C-537/17 (2018), CJEU - [eur-lex.europa.eu](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62017CJ0537). - Flightright v Eurowings, C-939/19, CJEU order of 30 April 2020 - [eur-lex.europa.eu](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62019CO0939). - Gahan v Emirates [2017] EWCA Civ 1530, Court of Appeal - [caselaw.nationalarchives.gov.uk](https://caselaw.nationalarchives.gov.uk/ewca/civ/2017/1530). - EU-Switzerland Air Transport Agreement, Annex - [eur-lex.europa.eu](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02002A0430(02)-20230715). - Irish Aviation Authority, Air passenger rights - [iaa.ie](https://www.iaa.ie/consumer-protection/air-passenger-rights). - European Commission, National Enforcement Bodies, updated 27 August 2026 - [transport.ec.europa.eu](https://transport.ec.europa.eu/document/download/d7b5dd33-4083-4faa-8132-b6dc8b3a1c07_en). - European Commission, EU air carriers holding an active operating licence - [transport.ec.europa.eu](https://transport.ec.europa.eu/document/download/7d7c51df-f11d-4a0c-815c-28a5ae4264b5_en?filename=eu_air_carriers_by_country_holding_an_active_operating_licence.pdf). - EASA, Authorised Third Country Operators - [easa.europa.eu](https://www.easa.europa.eu/download/tco-lists/TCO%20Status%20Report.pdf). - Civil Aviation Authority, Airline licence holders - [caa.co.uk](https://www.caa.co.uk/commercial-industry/airlines/licensing/licence-types/airline-licence-holders/). - Civil Aviation Authority, Delays - [caa.co.uk](https://www.caa.co.uk/air-passengers/travel-problems-and-rights/flight-delays-and-cancellations/delays/). - Civil Aviation Authority, Cancellations - [caa.co.uk](https://www.caa.co.uk/air-passengers/travel-problems-and-rights/flight-delays-and-cancellations/cancellations/). - Civil Aviation Authority, Alternative Dispute Resolution - [caa.co.uk](https://www.caa.co.uk/air-passengers/travel-problems-and-rights/travel-complaints/alternative-dispute-resolution/). - Civil Aviation Authority, How the CAA can help - [caa.co.uk](https://www.caa.co.uk/air-passengers/travel-problems-and-rights/travel-complaints/how-the-caa-can-help/). - AviationADR, Airline and airport members - [aviationadr.org.uk](https://www.aviationadr.org.uk/complaints-process/airline-and-airport-members-aviationadr/). - Statute of Limitations 1957, s.11 (revised) - [revisedacts.lawreform.ie](https://revisedacts.lawreform.ie/eli/1957/act/6/revised/en/html). - US Department of Transportation, Fly Rights - [transportation.gov](https://www.transportation.gov/airconsumer/fly-rights). - 14 CFR 260.2 and 260.6, refunds - [ecfr.gov](https://www.ecfr.gov/current/title-14/part-260).