Air passenger rights compared: UK261, EU261, APPR, US DOT and Montreal
Checked 12 min read · 9 tables
Five sets of rules decide what an airline owes you when a flight goes wrong: UK261, EU261, Canada’s Air Passenger Protection Regulations (APPR), US Department of Transportation (DOT) rules and the Montreal Convention. Each states its amounts in its own unit. That means £ for UK261, € for EU261, C$ for APPR, $ for US DOT and Special Drawing Rights (SDR) for the Convention, and no amount converts into another as a legal figure.
Canada’s Air Passenger Protection Regulations (APPR), 
US Department of Transportation (DOT) rules and the Montreal Convention. Each states its amounts in its own unit. That means £ for UK261, € for EU261, C$ for APPR, $ for US DOT and Special Drawing Rights (SDR) for the Convention, and no amount converts into another as a legal figure.Which rules reach your flight depends on where it leaves from, where it lands and who operates it. That decision is worked through at which law covers my flight. This page compares what each regime gives you once it applies; how long a delay must last before any of it starts is at flight delay threshold rules.
Passenger rights compared: ten outcomes, five regimes
Outcome | UK261 £ | EU261 € | APPR C$ | US DOT $ | Montreal Convention (SDR) |
|---|---|---|---|---|---|
Flights covered | Any airline leaving a UK airport; into the UK on a UK or EU-licensed carrier; into an EU Member State on a UK carrier | Any airline leaving an airport in the EU, Iceland, Norway or Switzerland; into the EU or Switzerland from outside on a Community carrier (EU or Swiss licence) | Flights to, from and within Canada, connections included | Refunds: a "covered flight" under 14 CFR Part 260. Bumping pay: nonstop segments leaving the US on aircraft of 30 or more seats | Not compared on this page |
Delay compensation | £220 / £350 / £520 by distance, arrival 3 hours or more late; over 3,500 km, £260 for "between three and four hours" late on the CAA page | €250 / €400 / €600 by distance, arrival 3 hours or more late; over 3,500 km and not intra-EU, the carrier may cut this to €300 if under 4 hours late | Large carrier C$400 / C$700 / C$1,000; small carrier C$125 / C$250 / C$500; from 3 hours, within the carrier's control and not required for safety | Not comparable: none required on domestic itineraries | Proven damage up to 6,303 SDR |
Denied boarding | £220 / £350 / £520 | €250 / €400 / €600 | C$900 / C$1,800 / C$2,400, any carrier size, within the carrier's control | 200% of the one-way fare up to $1,075, or 400% up to $2,150 | Not comparable |
Cancellation notice that ends compensation | 2 weeks or more | 2 weeks or more | More than 14 days | Not comparable: no compensation to end | Not comparable |
Care while waiting | From 2, 3 or 4 hours by distance | From 2, 3 or 4 hours by distance | After 2 hours, within the carrier's control, if told under 12 hours before departure | Not comparable: no federal airport rule; airline dashboard commitments | Not comparable |
Refund deadline | 7 days | 7 days | 30 days | 7 business days for credit card purchases; 20 calendar days for other methods | Not comparable |
Tarmac deplaning | Not comparable: no tarmac rule in force | Not comparable: no tarmac rule in force | Opportunity at 3 hours; not required if take-off is likely less than 3 hours 45 minutes after doors closed or landing and service continues | Opportunity before the delay exceeds 3 hours (domestic) or 4 hours (international) | Not comparable |
Baggage | Not comparable: no baggage rule | Not comparable: no baggage rule | At least baggage fees plus the Carriage by Air Act amount, or the Montreal amount where that Act does not apply | Domestic: liability not limited below $4,700 per passenger on aircraft of more than 60 seats | 1,519 SDR per passenger |
Time limit | 6 years in England, Wales and Northern Ireland; Scotland not settled | Each Member State's limitation rules; not set by the Regulation | Ask the carrier before the first anniversary | Not comparable: no federal delay compensation to claim | 2 years to sue |
Enforcement | Civil Aviation Authority | National enforcement body | Canadian Transportation Agency | US Department of Transportation | Varies: complaint to the carrier, then court; in the UK, CAA PACT can consider baggage complaints; Ireland has no designated body |
UK airport; into the 
EU Member State on a 
Iceland, 
Norway or 
Switzerland; into the 
CAA page
England, 
Wales and 
Scotland not settled
Canadian Transportation Agency
Ireland has no designated bodySource: UK261 arts. 3, 4, 5, 6, 7, 8, 9, 16 - legislation.gov.uk; CAA, Delays and How the CAA can help - caa.co.uk; Regulation (EC) No 261/2004 arts. 3 to 9 and 16 - eur-lex.europa.eu; Sturgeon (C-402/07 and C-432/07) and Cuadrench Moré (C-139/11) - eur-lex.europa.eu, eur-lex.europa.eu; APPR ss.9, 12, 14, 18.2, 19, 20, 23 and Canada Transportation Act ss.85.04, 86.11 - laws-lois.justice.gc.ca; 14 CFR 250.2, 250.5, 254.4, 259.4, 260.2 - ecfr.gov; DOT Fly Rights - transportation.gov; Montreal Convention arts. 22, 35 - eur-lex.europa.eu; IAA, APR FAQs - iaa.ie, checked 2026-09-15.
IAA, APR FAQs - No row ranks one regime above another: each column pays in its own currency, and a “not comparable” cell means that regime has no equivalent rule.
EU261 figures apply the 2004 text; in Sturgeon (C-402/07 and C-432/07, 2009) the Court of Justice extended compensation to arrivals 3 hours or more late. A revision of EU261 has been adopted, but it is not yet published in the Official Journal and is not in force. Full rules for each column sit on the UK261, EU261, Canada APPR, US DOT and Montreal Convention pages, and a CSV version of the table is prepared for the data hub.
#How do compensation amounts compare across the four regimes?
£520 is the top UK261 amount for a long delay, a cancellation or denied boarding, against €600 under EU261. Canada’s APPR pays up to C$1,000 for a delay on a large carrier and C$2,400 for denied boarding. US federal rules require no delay compensation on domestic itineraries, and bumping from an oversold flight pays up to $2,150.
Source: UK261 art. 7(1) - legislation.gov.uk; Regulation (EC) No 261/2004 art. 7(1) - eur-lex.europa.eu; APPR ss.19(1), 20(1) - laws-lois.justice.gc.ca; 14 CFR 250.5 - ecfr.gov, checked 2026-09-15.
UK261 and EU261 set their bands by great-circle distance to your last destination. APPR sets them by hours of arrival delay and by carrier size. A large carrier is one that carried 2 million passengers or more worldwide in each of the two preceding calendar years, and this page labels no airline as large or small.
Compensation amounts by regime
Point | UK261 £ | EU261 € | APPR C$ | US DOT $ |
|---|---|---|---|---|
Delay trigger | Arrival 3 hours or more late, art. 6(3) | Arrival three hours or more late, Sturgeon (C-402/07 and C-432/07, 2009) | Arrival 3 hours or more late; within the carrier's control and not required for safety; you were told 14 days or less before departure, ss.12, 19 | Not comparable: DOT says airlines are not required to compensate for delays on domestic itineraries; all 9 airlines on the DOT dashboard list "No" for cash compensation (page last updated 11 September 2025) Show the full rule |
Amounts | £220 up to 1,500 km; £350 for 1,500 to 3,500 km; £520 beyond | €250 up to 1,500 km; €400 for 1,500 to 3,500 km and for every intra-EU flight over 1,500 km; €600 beyond | Large carrier: C$400 for 3 to under 6 hours, C$700 for 6 to under 9, C$1,000 for 9 or more. Small carrier: C$125, C$250, C$500 | Not comparable |
Over 3,500 km, arriving 3 to under 4 hours late | £260 for "between three and four hours" late on the CAA delays page; article 7(2) says the carrier "may" cut | €300 where the carrier uses its 50% option, Sturgeon para 63; intra-EU flights stay at €400 | Not comparable: bands run by hours | Not comparable |
Re-routed after cancellation or denied boarding | The carrier may halve the amount if the new flight arrives no more than 2, 3 or 4 hours late, by band, art. 7(2); the CAA table for 7 to 14 days' notice pays the full amount from exactly 2, 3 or 4 hours Show the full rule | Same rule, art. 7(2) | Not comparable | Not comparable |
Denied boarding | £220 / £350 / £520, compensated immediately, art. 4(3) | €250 / €400 / €600, compensated immediately, art. 4(3) | C$900 if you arrive under 6 hours late, C$1,800 for 6 to under 9, C$2,400 for 9 or more; any carrier size; paid within 48 hours; not owed outside the carrier's control, ss.10(3), 20 | Oversold flight, nonstop segment leaving the US: nothing if the alternate arrives no more than 1 hour late; 200% of the one-way fare up to $1,075 if more than 1 hour and under 2 hours late (domestic) or under 4 hours (international); 400% up to $2,150 at 2 hours or more (domestic) or 4 hours or more (international), or with no alternate, 14 CFR 250.5 Show the full rule |
Carrier's defence | Extraordinary circumstances, defined in art. 2(o) | Extraordinary circumstances that could not have been avoided with all reasonable measures, art. 5(3) | Disruption outside the carrier's control, s.10, or required for safety, s.11 | Denied boarding only: exceptions such as not meeting ticketing or check-in rules, a smaller aircraft substituted for operational or safety reasons, or a seat elsewhere on the flight at no extra charge, 14 CFR 250.6 Show the full rule |
Source: UK261 arts. 2(o), 4(3), 6(3), 7(1)-(2) - legislation.gov.uk; CAA, Delays and Cancellations - caa.co.uk; Regulation (EC) No 261/2004 arts. 4(3), 5(3), 7(1)-(2) - eur-lex.europa.eu; Sturgeon (C-402/07 and C-432/07) - eur-lex.europa.eu; APPR ss.1(2), 10-12, 19, 20 - laws-lois.justice.gc.ca; DOT Fly Rights - transportation.gov; 14 CFR 250.5, 250.6 - ecfr.gov, checked 2026-09-15.
Distance drives the UK and EU columns, hours and carrier size drive Canada’s, and the US column holds a figure only for denied boarding.
Notice of a cancellation moves the answer, and the 14-day line sits one day apart.
Cancellation notice and what is owed, by regime
Notice before departure | UK261 £ | APPR C$ |
|---|---|---|
More than 14 days | No compensation | No compensation |
Exactly 14 days | No compensation: told "at least two weeks" before | Compensation possible: told 14 days or less before |
7 days to under 14 days | None only if offered re-routing leaving no more than 2 hours early and arriving less than 4 hours late | Compensation by arrival-delay band, if within the carrier's control and not required for safety |
Under 7 days | None only if offered re-routing leaving no more than 1 hour early and arriving less than 2 hours late | Same as the row above |
Burden of proof | The carrier proves whether and when it told you, art. 5(4) | In a CTA complaint, the disruption is presumed within the carrier's control and not required for safety unless the carrier proves otherwise |
Source: UK261 art. 5(1)(c), 5(4) - legislation.gov.uk; Regulation (EC) No 261/2004 art. 5(1)(c), 5(4) - eur-lex.europa.eu; APPR s.12(2) - laws-lois.justice.gc.ca; Canada Transportation Act s.85.07(2) - laws-lois.justice.gc.ca, checked 2026-09-15.
With exactly 14 days' notice, UK261 and EU261 owe no compensation, while APPR compensation is still possible.
APPR pays no compensation once you have received compensation for the same event under another regime. On an inbound flight, UK261 and EU261 drop out if you already received benefits or compensation and assistance in the country you left. Keep the cancellation message with its date, then check your band in the compensation calculator.
#What must airlines provide while you wait under each regime?
2 hours is the earliest care threshold: on UK261 and EU261 flights up to 1,500 km, and under Canada’s APPR after a 2-hour wait when the disruption is within the carrier’s control and you were told less than 12 hours before departure. US federal rules set no airport care duty.
Source: UK261 arts. 6(1), 9 - legislation.gov.uk; Regulation (EC) No 261/2004 arts. 6(1), 9 - eur-lex.europa.eu; APPR ss.11, 12, 14 - laws-lois.justice.gc.ca; DOT Fly Rights - transportation.gov, checked 2026-09-15.
In the DOT’s words, each airline “has its own policies” for delayed passengers at the airport, and “there are no federal requirements”. The US substitute is the DOT dashboard. It lists airline commitments for disruptions within the airline’s control, and DOT says airlines must keep the promises in their customer service plans.
Care while you wait, by regime
Point | UK261 £ | EU261 € | APPR C$ | US DOT $ |
|---|---|---|---|---|
When care starts | Departure delay expected to reach 2 hours up to 1,500 km, 3 hours for 1,500 to 3,500 km, 4 hours beyond, art. 6(1) | Same, but intra-EU flights over 1,500 km at 3 hours, art. 6(1) | After a 2-hour wait past the original departure time, within the carrier's control, if you were told less than 12 hours before departure, s.14 | Not comparable: no federal airport rule |
Food and drink | Meals and refreshments in reasonable relation to the waiting time, art. 9(1)(a) | Same, art. 9(1)(a) | Food and drink in reasonable quantities, s.14(1) | Not comparable: no federal airport rule; the dashboard has a meal row for waits of 3 hours or more (check your airline's column) |
Hotel | Hotel and transport where a stay of one or more nights is needed, art. 9(1)(b)-(c) | Same, art. 9(1)(b)-(c) | Hotel and transport if an overnight wait is expected, s.14(2) | Dashboard row: hotel for an overnight stay; Frontier lists "No" |
Communication | Two calls or e-mails, art. 9(2) | Same, art. 9(2) | Access to a means of communication, s.14(1); status updates every 30 minutes, s.13(2) | Flight status notice within 30 minutes of the airline learning of a cancellation, diversion or delay of 30 minutes or more, for flights in the next 7 days, 14 CFR 259.8 |
If the carrier was not at fault | Care still owed: arts. 5(3) and 6(4) remove only compensation | Care still owed: art. 5(3) removes only compensation | Not owed outside the carrier's control, s.10(3) | Dashboard covers only disruptions within the airline's control |
Frontier lists "No"Source: UK261 arts. 5(3), 6, 9 - legislation.gov.uk; Regulation (EC) No 261/2004 arts. 5(3), 6, 9 - eur-lex.europa.eu; APPR ss.10, 13, 14 - laws-lois.justice.gc.ca; DOT Airline Cancellation and Delay Dashboard, page last updated 11 September 2025 - transportation.gov; 14 CFR 259.5, 259.8 - ecfr.gov, checked 2026-09-15.
Under UK261 and EU261, care does not depend on who caused the disruption; under APPR it does.
Tarmac rules exist only in Canada and the US.
Tarmac delay rules by regime
Point | UK261 £ | APPR C$ | US DOT $ |
|---|---|---|---|
Deplaning | Not comparable: no tarmac rule in force | Chance to disembark 3 hours after the doors close for take-off or after landing, s.9(1) | Chance to deplane before the tarmac delay exceeds 3 hours (domestic) or 4 hours (international), 14 CFR 259.4(c) |
Exceptions | Not comparable | Not required if take-off is likely less than 3 hours 45 minutes after doors closed or landing and on-board service continues; safety, security, air traffic control and customs, s.9(2), (4) | Safety, security and air traffic control |
On board | Not comparable | Free lavatories, ventilation, cooling or heating, communication, food and drink, s.8 | Food and potable water no later than 2 hours after the delay starts; a status notice once it passes 30 minutes, 259.4(c)(4), (6) |
Aircraft covered | Not comparable | Flights to, from and within Canada | US carriers, and foreign carriers on flights to or from the US, on aircraft of 30 or more seats, 259.2-259.3 |
Source: APPR ss.8, 9 - laws-lois.justice.gc.ca; 14 CFR 259.2-259.4 - ecfr.gov, checked 2026-09-15.
Canada lets a carrier keep you aboard up to 45 more minutes when take-off is close and on-board service continues; the US rule has no such extension.
Ask at the desk for a meal voucher once your threshold passes. Keep every receipt if you end up paying for food or a hotel yourself.
#When is a refund due under each regime?
7 days is the refund deadline under UK261 and EU261 once you choose reimbursement after a cancellation, denied boarding or a departure delay of at least 5 hours. Canada’s APPR allows 30 days. US DOT rules allow 7 business days for credit card purchases and 20 calendar days for other payment methods.
Source: UK261 arts. 6(1), 8(1) - legislation.gov.uk; Regulation (EC) No 261/2004 arts. 6(1), 8(1) - eur-lex.europa.eu; APPR s.18.2 - laws-lois.justice.gc.ca; 14 CFR 260.2 - ecfr.gov, checked 2026-09-15.
Refund rules by regime
Point | UK261 £ | EU261 € | APPR C$ | US DOT $ |
|---|---|---|---|---|
When a refund is due | Cancellation, denied boarding, or a departure delay of at least 5 hours, if you choose reimbursement, art. 8(1)(a) | Same, art. 8(1)(a) | Within the carrier's control: if the alternate arrangements do not suit you, s.17(2). Outside its control: a refund of the unused portion is your choice if no re-routing leaving within 48 hours is possible, s.18(1) Show the full rule | Cancellation, or a significant delay or change: departure 3 hours or more earlier or arrival 3 hours or more later (domestic), 6 hours (international); another airport; more connections; a lower class; certain disability-related changes. Due if you reject the alternative, get none, or do not respond and do not fly, 14 CFR 260.2, 260.6(a) Show the full rule |
What comes back | Full cost of the ticket, plus a return flight to your first point of departure where relevant | Same | A refund, of the unused portion when outside the carrier's control, s.18(1); plus a free return flight to your origin if the trip no longer serves its purpose and you are not at your origin, s.17(2) Show the full rule | Fare including taxes and ancillary fees, 260.6(a) |
Deadline and method | Within 7 days, art. 8(1)(a) | Within 7 days, art. 8(1)(a) | Within 30 days, to the original payment method unless you consent in writing to a non-expiring alternative, s.18.2 | 7 business days for credit card purchases; 20 calendar days for cash, check, debit card or other methods, 260.2 |
Instead of a refund | Re-routing at the earliest opportunity, or later at your convenience, art. 8(1)(b)-(c) | Same | Within the carrier's control: large carrier, own or partner flight leaving within 9 hours, then any carrier within 48 hours; small carrier, own or partner flight, s.17(1). Outside its control: own or partner flight leaving within 48 hours, s.18(1) Show the full rule | Voucher or credit only if you affirmatively accept it, valid at least 5 years, 260.6(c), 260.7 |
Source: UK261 art. 8(1) - legislation.gov.uk; Regulation (EC) No 261/2004 art. 8(1) - eur-lex.europa.eu; APPR ss.17, 18, 18.2 - laws-lois.justice.gc.ca; 14 CFR 260.2, 260.6, 260.7 - ecfr.gov, checked 2026-09-15.
A UK261 or EU261 refund is your choice; a US refund is due unless you accept the alternative, and an APPR refund depends on the disruption category.
Two details change the money. If an APPR flight qualifies for compensation and you take the refund because the alternate arrangements do not suit you, the amount becomes C$400 on a large carrier or C$125 on a small one. In the US, DOT does not enforce its cancellation-refund requirements where a flight is merely renumbered, you are rebooked on it and there is no “significant change or delay” (91 FR 41556). That discretion is extended to 7 July 2027; full detail is on airline refund rules.
Ask for the refund in writing and say that you do not accept a voucher or credit.
#How do baggage limits and deadlines compare?
1,519 SDR per passenger is the Montreal Convention limit for destroyed, lost, damaged or delayed baggage since 28 December 2024, unless you made a special declaration of interest. A complaint about damage must be in writing within 7 days of receiving the bag, and a complaint about delay within 21 days.
Source: Montreal Convention arts. 22(2), 31 - eur-lex.europa.eu; ICAO, 2024 revised limits of liability - icao.int, checked 2026-09-15.
The 1,519 SDR figure is a ceiling on proven loss, not a flat payment. It replaced the 1,288 SDR limit that applied from 28 December 2019. The limit does not apply where the damage came from an intentional or reckless act, done knowing damage would probably result. UK261 and EU261 contain no baggage article, so a lost bag on a UK or EU flight is never a UK261 or EU261 claim.
Baggage limits and deadlines by regime
Point | Montreal Convention (SDR) | APPR C$ | US DOT $ |
|---|---|---|---|
Liability | Up to 1,519 SDR per passenger for destruction, loss, damage or delay, unless you made a special declaration of interest, art. 22(2) | At least the baggage fees plus the amount under the Carriage by Air Act, or the Montreal Convention amount where that Act does not apply, s.23(1) | Domestic: the carrier may not limit liability below $4,700 per passenger on aircraft of more than 60 seats, 14 CFR 254.4 |
Bag counts as lost | The carrier admits the loss, or the bag has not arrived 21 days after it was due, art. 17(3) | The carrier admits the loss, or more than 21 days pass, s.23(1) | Not covered on this page |
Delayed bag | Inside the same 1,519 SDR limit | Baggage fees plus delay compensation on the same basis, s.23(2) | Bag fee refunded if not delivered within 12 hours (domestic), 15 hours (international with a nonstop of 12 hours or less) or 30 hours (longer nonstops), 14 CFR 260.5 |
Written complaint | Damage: within 7 days of receipt. Delay: within 21 days of the bag being placed at your disposal, art. 31 | CTA guidance: damaged baggage within 7 days, delayed baggage within 21 days | A Mishandled Baggage Report is needed for the fee refund, 260.5(b) |
Source: Montreal Convention arts. 17(3), 22(2), 22(5), 31 - eur-lex.europa.eu; APPR s.23 - laws-lois.justice.gc.ca; CTA, Air travel complaints - otc-cta.gc.ca; 14 CFR 254.4, 260.5 - ecfr.gov, checked 2026-09-15.
Canada adds your baggage fees to the Carriage by Air Act or Convention amount; US domestic flights on aircraft over 60 seats carry a $4,700 floor.
Report damage in writing within 7 days and delay within 21 days, and keep a copy: after those dates the Convention says no action lies, except for fraud. Step-by-step help is on lost and delayed baggage compensation.
#How long do you have to claim under each regime?
1 year is the APPR deadline: you must ask the carrier for compensation before the first anniversary of the delay or cancellation. A UK261 court claim in England and Wales has 6 years and a Montreal Convention action 2 years. EU261 leaves the period to national law, which gives 6 years in Ireland.
Source: APPR s.19(3) - laws-lois.justice.gc.ca; UK261 art. 3(9) and Limitation Act 1980 s.9 - legislation.gov.uk; Montreal Convention art. 35(1) - eur-lex.europa.eu; Statute of Limitations 1957 - revisedacts.lawreform.ie, checked 2026-09-15.
These deadlines measure different acts. APPR’s year limits your request to the carrier. The UK, Irish and Montreal periods limit the court action itself.
Time limits to claim, by regime and place
Regime and place | Deadline | What must happen in time | Legal basis |
|---|---|---|---|
UK261, England and Wales | 6 years | Court claim | UK261 art. 3(9); Limitation Act 1980 s.9 |
UK261, Northern Ireland | 6 years | Court claim | Art. 3(9) or the Limitation (Northern Ireland) Order 1989: both routes give 6 years |
UK261, Scotland | 5 years, not settled | A relevant claim or acknowledgement before the obligation is extinguished | Prescription and Limitation (Scotland) Act 1973 s.6 |
EU261, any Member State | National limitation period | Court claim | Each Member State's limitation rules, Cuadrench Moré (C-139/11, 2012) |
EU261, Ireland | 6 years | Court claim | Statute of Limitations 1957 |
Canada APPR | Before the first anniversary of the delay or cancellation | Compensation request to the carrier | APPR s.19(3) |
US DOT | Not comparable | No federal delay compensation to claim | DOT Fly Rights |
Montreal Convention | 2 years from arrival, from the date the aircraft ought to have arrived, or from when carriage stopped | Court action | Art. 35(1) |
Source: UK261 art. 3(9) - legislation.gov.uk; Limitation (Northern Ireland) Order 1989 art. 4 - legislation.gov.uk; Prescription and Limitation (Scotland) Act 1973 s.6 - legislation.gov.uk; Cuadrench Moré (C-139/11, 2012) - eur-lex.europa.eu, checked 2026-09-15.
Scotland is the one open point: a UK261 claim there faces 5 years under the Prescription and Limitation (Scotland) Act 1973, and no Scottish court has yet decided whether that Act or UK261’s article 3(9) governs.
File inside the shortest period that could apply to you, 5 years if you might sue in Scotland. The full list by country is on flight compensation time limits.
#Who enforces each regime?
30 days is Canada’s waiting period: the Canadian Transportation Agency takes an APPR complaint only after your written request to the carrier has gone unresolved for 30 days. The Civil Aviation Authority enforces UK261, a national enforcement body in each state enforces EU261, and the US Department of Transportation enforces its own rules.
Source: Canada Transportation Act s.85.04(1)(d) - laws-lois.justice.gc.ca; UK261 art. 16(1) - legislation.gov.uk; Regulation (EC) No 261/2004 art. 16(1) - eur-lex.europa.eu; DOT, File a consumer complaint - transportation.gov, checked 2026-09-15.
Article 16(1) decides which EU body handles your flight. Each state’s body covers flights from its airports and flights from outside the EU into its airports. The Irish Aviation Authority tells passengers to complain to the body of the state the flight was due to depart from. The European Commission’s list, updated 27 August 2026, names bodies for the 27 Member States plus Iceland, Norway and Switzerland.
European Commission’s list, updated 27 August 2026, names bodies for the 27 Member States plus Who enforces each regime
Regime | Body | Your first step | Escalation and outcome |
|---|---|---|---|
UK261 | Civil Aviation Authority, art. 16(1) | Complain to the airline in writing | After 8 weeks without a reply: AviationADR or CEDR if the airline is a member, free and binding on the airline if you accept the decision, filed within 12 months of the airline's final response. Otherwise the CAA's Passenger Advice and Complaints Team (PACT), which cannot impose a solution Show the full rule |
EU261 | National enforcement body of the departure state, or of the arrival state for a flight from outside the EU, art. 16(1). Ireland: Irish Aviation Authority | Claim from the operating carrier, which owes the compensation, art. 3(5) | Complaint to the national body. In Ireland the IAA also lists Small Claims and the European Small Claims Procedure |
Canada APPR | Canadian Transportation Agency | Written request to the carrier, which must pay or explain within 30 days | Mediation starts no later than day 30 after filing; without agreement, an order follows no later than day 60 after mediation started, enforceable as an Agency order, Canada Transportation Act ss.85.05-85.07 Show the full rule |
US DOT | Office of Aviation Consumer Protection, US Department of Transportation | Contact the airline | Online OACP form or mail. DOT directs the airline to respond to you with a copy to DOT; airlines must acknowledge within 30 days and answer in writing within 60 days, 14 CFR 259.7 |
Montreal Convention | Varies by country: the IAA says Ireland has no designated body for the Convention; the CAA's PACT can consider Montreal baggage complaints | Baggage: written complaint to the carrier within 7 days (damage) or 21 days (delay) | Court within 2 years, art. 35(1) |
AviationADR or 
CEDR if the airline is a member, free and binding on the airline if you accept the decision, filed within 12 months of the airline's final response. Otherwise the Source: CAA, Alternative dispute resolution - caa.co.uk; CAA, How the CAA can help - caa.co.uk; European Commission, National Enforcement Bodies list - transport.ec.europa.eu; IAA, Air passenger rights - iaa.ie; Canada Transportation Act ss.85.04-85.07 - laws-lois.justice.gc.ca; 14 CFR 259.7 - ecfr.gov, checked 2026-09-15.
An accepted UK ADR decision and a CTA order both bind the airline, while PACT cannot impose a solution and the DOT asks the airline to respond to you. The glossary has entries for ADR, PACT and a CTA complaint.
Send your first complaint to the airline in writing and date it: that letter starts the UK 8-week clock and the Canadian 30-day clock.
This comparison is general information, not legal advice. For your specific case, contact the CAA (UK), your national enforcement body or the European Consumer Centre network (EU), the Canadian Transportation Agency (Canada), the US Department of Transportation (US) or a solicitor.
#Sources
- Regulation (EC) No 261/2004 as it forms part of UK law, arts. 2 to 9 and 16, as amended by SI 2019/278 and SI 2023/1370 - legislation.gov.uk, checked 2026-09-15.
- Limitation Act 1980 s.9; Limitation (Northern Ireland) Order 1989 art. 4; Prescription and Limitation (Scotland) Act 1973 s.6 - legislation.gov.uk, checked 2026-09-15.
- Civil Aviation Authority, Delays; Cancellations; Alternative dispute resolution; How the CAA can help - caa.co.uk, checked 2026-09-15.
- Regulation (EC) No 261/2004, arts. 3 to 9 and 16 - eur-lex.europa.eu, checked 2026-09-15.
- Court of Justice of the EU, Sturgeon (C-402/07 and C-432/07, 2009) and Cuadrench Moré (C-139/11, 2012) - eur-lex.europa.eu, eur-lex.europa.eu, checked 2026-09-15.
- Commission Interpretative Guidelines C/2024/5687 (Iceland, Norway, Switzerland) - eur-lex.europa.eu, checked 2026-09-15.
- European Parliament Legislative Observatory, procedure 2013/0072(COD) (revision status) - oeil.europarl.europa.eu, checked 2026-09-15.
- European Commission, National Enforcement Bodies, updated 27 August 2026 - transport.ec.europa.eu, checked 2026-09-15.
- Irish Aviation Authority, Air passenger rights and APR FAQs; Statute of Limitations 1957 - iaa.ie, revisedacts.lawreform.ie, checked 2026-09-15.
- Air Passenger Protection Regulations (SOR/2019-150) - laws-lois.justice.gc.ca, checked 2026-09-15.
- Canada Transportation Act ss.85.04-85.07, 86.11 - laws-lois.justice.gc.ca, checked 2026-09-15.
- 14 CFR Parts 250, 254, 259 and 260 - ecfr.gov; Federal Register, Airline Refunds and Other Consumer Protections, 91 FR 41556 (7 July 2026) - federalregister.gov, checked 2026-09-15.
- US Department of Transportation, Fly Rights; Airline Cancellation and Delay Dashboard; File a consumer complaint - transportation.gov, checked 2026-09-15.
- Convention for the Unification of Certain Rules for International Carriage by Air (Montreal, 1999) - eur-lex.europa.eu; ICAO 2024 revised limits - icao.int, checked 2026-09-15.