Which law covers my flight? UK261, EU261, APPR or US DOT rules

Checked 15 Sep 2026·17 min read

Four laws can reach one disrupted flight: UK261, EU261, Canada’s Air Passenger Protection Regulations (APPR) and US Department of Transportation (DOT) rules. Two can apply at once: a London to Paris flight operated by an EU-licensed airline meets UK261’s departure test and EU261’s arrival test on the same leg. Run the route triage below before you trust any amount, then check the figure in the compensation calculator.

#What decides which passenger-rights law applies to a flight?

3 facts decide which regulation applies: the departure airport, the arrival airport and the operating carrier’s licence. Leaving the UK or the EU triggers UK261 or EU261 on any airline; flying to or from Canada or the US triggers APPR or US DOT rules. An arrival in the UK or the EU adds either law only on a qualifying licence.

Source: UK261 art. 3(1) — legislation.gov.uk; Regulation (EC) No 261/2004 art. 3(1) — eur-lex.europa.eu; Canada Transportation Act s.86.11(1) — laws-lois.justice.gc.ca; 14 CFR 260.2 — ecfr.gov, checked 2026-09-15.

The departure test ignores the airline. UK261 covers every passenger leaving a UK airport, and EU261 every passenger leaving an airport in an EU Member State. EU261 also applies in Iceland and Norway under the EEA Agreement and in Switzerland under its air transport agreement with the EU; the table calls those 30 countries the EU261 area. APPR covers flights to, from and within Canada, connections included. US DOT refund rules cover scheduled flights to, from or within the US, while denied-boarding pay reaches only nonstop segments leaving the US on aircraft of 30 or more seats.

The arrival test runs on every flight landing in the UK or the EU261 area from outside and can add a second law. EU261 needs a Community carrier, licensed by an EU Member State. UK261 needs a UK or Community carrier for a flight into the UK, and a UK air carrier for a flight into an EU Member State. That second limb names Member States only, not Iceland, Norway or Switzerland.

Which law covers a route, by carrier type

Source: UK261 arts. 2, 3(1) — legislation.gov.uk; Regulation (EC) No 261/2004 arts. 2(c), 3(1), EEA Joint Committee Decision No 171/2004, EU-Switzerland Air Transport Agreement Annex — eur-lex.europa.eu; Canada Transportation Act s.86.11(1) — laws-lois.justice.gc.ca; 14 CFR 250.2, 260.2 — ecfr.gov, checked 2026-09-15.

Every law named in the matching cell applies. “US DOT refund rules” marks flights into the US, which the DOT’s denied-boarding pay does not reach; “US DOT rules” adds that pay on nonstop segments leaving the US.

Match the “operated by” line on your booking to a column before quoting any amount.

#Is your flight covered by UK261 or EU261?

2 tests decide UK261 or EU261 coverage. UK261 covers any airline leaving a UK airport, flights into the UK on a UK or Community carrier, and flights into an EU Member State on a UK carrier. EU261 covers any airline leaving the EU261 area, and flights into that area from outside on a Community carrier.

Source: UK261 art. 3(1)(a)-(b) — legislation.gov.uk; Regulation (EC) No 261/2004 art. 3(1)(a)-(b) — eur-lex.europa.eu, checked 2026-09-15.

UK261 is the Regulation as it forms part of UK law, amended by SI 2019/278 from 31 December 2020. After Brexit the UK sits outside EU261’s territory, and the EU outside UK261’s. Overlaps follow, so UK261 vs EU261 is rarely either-or. A Paris to London flight on a UK or Community carrier meets EU261 on departure and UK261 on arrival, and so does a UK carrier flying Paris to Rome.

Coverage follows the legal entity, not the brand. British Airways plc, BA Cityflyer Limited and BA Euroflyer Limited are UK air carriers: UK261 covers their flights into the UK and into the EU from outside the UK, and EU261 covers their EU departures but not their flights into the EU. EasyJet UK Limited is on the same terms, while easyJet Europe Airline GmbH holds an Austrian licence, so EU261 covers its flights into the EU and UK261 its flights into the UK. The CAA’s Type A list, EASA’s third-country operator list and the Commission’s list of EU licence holders show each status.

Three licence types sit in between. A Swiss-licensed carrier counts as a Community air carrier for EU261 under the EU-Switzerland agreement, so its flights into the EU are covered. UK261 defines a Community carrier by a licence granted by a Member State, and no CAA statement or UK court decision settles whether a Swiss-, Norwegian- or Icelandic-licensed carrier qualifies. For Norwegian- and Icelandic-licensed carriers flying into the EU, no text confirms EU261 either, though departures from Norway and Iceland are covered.

Check the operating carrier’s legal name on those lists before assuming either law inbound; the UK261 and EU261 guides cover each law in full.

#What changes when another airline operates your flight?

1 rule settles a codeshare under EU261’s article 3(5): the operating air carrier owes compensation, not the marketing carrier that sold the ticket under its flight number. For a wet lease, the Court of Justice held in Wirth (C-532/17, 2018) that a carrier leasing out aircraft and crew without operational responsibility for the flight is not the operating carrier.

Source: Regulation (EC) No 261/2004 art. 3(5) — eur-lex.europa.eu; Wirth (C-532/17, 2018) — eur-lex.europa.eu, checked 2026-09-15.

Codeshare partners sell seats on each other’s flights under their own flight numbers. Your booking names the marketing carrier, and the “operated by” line names the airline that flew. Article 3(5) of EU261 places the obligation on the operating air carrier, and the arrival tests in both Regulations look at “the operating air carrier of the flight concerned”. The Irish Aviation Authority’s own example shows what rides on it: a New York to Dublin delay is covered by EU261 on Aer Lingus and not on American Airlines. A codeshare ticket sold by one of them and flown by the other takes the operating airline’s answer.

Wet leasing separates the aircraft from the operation. The Court of Justice held that a carrier which leases aircraft and crew under a wet lease, but does not bear operational responsibility for the flight, is not the “operating air carrier”. That holds even where the booking confirmation says the flight is operated by the lessor. The carrier with operational responsibility owes the compensation.

Screenshot the “operated by” line from your booking before you file. If it names a wet-lease supplier, ask the airline you booked with, in writing, which carrier held operational responsibility for the flight, and address the claim to that carrier.

#How are connecting flights on one booking treated?

1 single booking with a connection counts as one journey in both Regulations: UK261 says so in article 3(1A), in force from 14 December 2023, and EU261 reaches the same point through case law. The delay that matters is the delay at your final destination, not at the airport where you changed planes.

Source: UK261 art. 3(1A) (inserted by SI 2023/1370) — legislation.gov.uk; Folkerts (C-11/11, 2013), Wegener (C-537/17, 2018) — eur-lex.europa.eu, checked 2026-09-15.

Under EU261, Wegener (C-537/17, 2018) treats connecting flights on one reservation as a single unit of transport. Folkerts (C-11/11, 2013) holds that the delay counted is the one at the final destination. A first leg that leaves 40 minutes late, makes you miss your onward flight and gets you to your final airport 3 hours 10 minutes late is a 3-hour case, not a 40-minute one. A return leg flying home from an EU airport meets EU261’s departure test under article 3(1)(a), on any carrier.

#How does UK261 treat a single booking?

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. A Manchester to Dubai to Bangkok connecting itinerary on one booking therefore departs Manchester for UK261 purposes. In Gahan v Emirates [2017] EWCA Civ 1530, the Court of Appeal held that for a single booking from an EU airport on a non-EU carrier, Manchester to Dubai to Bangkok or Sydney, compensation is assessed on the delay at the final destination, including a missed connection outside the EU. The decision binds lower courts in England and Wales.

Keep the booking confirmation that lists every leg, and measure your delay against the scheduled arrival at the last airport on it.

#APPR C$Does APPR apply to flights to or from Canada?

C$125 to C$1,000 is what Canada’s Air Passenger Protection Regulations pay for a delay or cancellation within the carrier’s control and not required for safety: C$400 to C$1,000 on a large carrier, C$125 to C$500 on a small one. APPR covers flights to, from and within Canada, whichever carrier operates them.

Source: Canada Transportation Act s.86.11(1) — laws-lois.justice.gc.ca; Air Passenger Protection Regulations (SOR/2019-150) ss. 1(2), 12, 19(1) — laws-lois.justice.gc.ca, checked 2026-09-15.

APPR tests the itinerary, not the licence. A Toronto to London flight sits under APPR on Air Canada, British Airways or a Community carrier alike; UK261 joins only on the UK or Community carrier, because Air Canada is a third-country carrier for UK261.

The cause decides whether money is owed. A disruption outside the carrier’s control brings alternative arrangements or a refund, and no compensation. A disruption required for safety, which excludes scheduled maintenance, pays no compensation either, but the carrier owes care after a 2-hour wait if you were informed less than 12 hours before departure, plus re-booking or a refund for a delay of 3 hours or more or a cancellation. Compensation needs a disruption within the carrier’s control and not required for safety, and notice of 14 days or less before departure (Missed connection compensation).

Size sets the amount. A large carrier, one that carried 2 million passengers or more worldwide in each of the two preceding calendar years, pays C$400 for an arrival 3 to under 6 hours late, C$700 for 6 to under 9 hours and C$1,000 from 9 hours. A small carrier pays C$125, C$250 or C$500 on those bands. Denied boarding within the carrier’s control and not required for safety pays C$900 for an arrival under 6 hours late, C$1,800 for 6 to under 9 hours and C$2,400 from 9 hours, whatever the carrier’s size.

Send your written request to the carrier before the first anniversary of the delay or cancellation; it must pay or explain within 30 days. If the request is still unresolved after 30 days, complain to the Canadian Transportation Agency. The APPR guide carries the full rules.

#When do US DOT rules apply, and can EU261 apply too?

$2,150 is the most US DOT rules pay a passenger bumped from an oversold flight, and only on a nonstop segment originating in the US on an aircraft with 30 or more seats. No federal rule requires airlines to compensate a delayed or cancelled flight; the DOT’s refund rules cover flights to, from or within the US.

Source: 14 CFR 250.2, 250.5 and 260.2 — ecfr.gov; US DOT, Fly Rights — transportation.gov, checked 2026-09-15.

A cancellation or a significant change triggers the refund rule. On an international flight, that includes a departure 6 hours or more earlier or an arrival 6 hours or more later; on a domestic flight the line is 3 hours. The refund is owed when you do not accept the alternative offered, and a passenger who does not respond and does not fly is still owed it. For delay costs on an international itinerary, the DOT points to article 19 of the Montreal Convention.

EU261 and UK261 can apply on top. A nonstop flight from the US into the EU on a Community carrier meets the DOT’s denied-boarding rule and EU261’s arrival test; into the UK on a UK or Community carrier, it meets UK261’s. A US carrier is covered by EU261 or UK261 when it leaves an EU or UK airport, but not on its flights into the EU or the UK. The glossary defines a Community carrier and a third-country operator.

Article 3(1)(b) of each Regulation switches the arrival law off if you received benefits or compensation and were given assistance in the departure country. A passenger bumped in New York who was paid denied-boarding compensation and given assistance there meets that exclusion. A passenger merely delayed gets no DOT compensation, so the operating carrier’s licence decides.

Complain to the airline first: it must acknowledge within 30 days and answer in writing within 60, and the DOT’s Office of Aviation Consumer Protection takes complaints once you have contacted the airline. The transatlantic flight compensation page covers both directions, and the US DOT guide covers the federal rules.

#Can two regimes cover one flight, and can you be paid twice?

2 Regulations, UK261 and EU261, carry the same bar in article 3(1)(b): the arrival law does not apply if you received benefits or compensation and were given assistance in the departure country. APPR pays nothing once another regime has compensated the same event, and EU261 lets its fixed amount be deducted from further compensation.

Source: Regulation (EC) No 261/2004 arts. 3(1), 12(1) — eur-lex.europa.eu; UK261 art. 3(1) — legislation.gov.uk; Air Passenger Protection Regulations s.3(3), Canada Transportation Act s.86.11(3) — laws-lois.justice.gc.ca, checked 2026-09-15.

The departure law carries no such exclusion. On a Paris to London flight operated by a Community carrier, EU261 applies because the flight left an EU airport, and UK261 applies unless you received benefits or compensation and were given assistance in France. On London to Paris the roles swap: UK261 applies on departure, and EU261 drops out if you received benefits or compensation and were given assistance in the UK.

Canada uses a different design. Section 3(3) of the Regulations says a carrier must not refuse APPR compensation because you are also eligible under another regime. Section 86.11(3) of the Canada Transportation Act stops APPR compensation once you have received compensation for the same event under a different regime. On a Toronto to London flight operated by a UK carrier, both APPR and UK261 reach the leg. Once UK261 compensation is received, APPR pays nothing; UK261’s own article 3(1)(b) test asks whether you received benefits or compensation and were given assistance in Canada.

EU261’s article 12(1) addresses a third overlap: a larger damages claim under other rules. The Regulation applies without prejudice to that further compensation, and the article 7 amount may be deducted from it.

List every payment, voucher, meal and hotel night you received for the disruption, and where you received it, before you choose which law to claim under. Each exclusion turns on exactly those facts.

#How do UK261 and EU261 differ after Brexit?

£220, £350 or £520 is what UK261 pays by distance band, against €250, €400 or €600 under EU261, and neither amount converts into the other. Since SI 2019/278 took effect on 31 December 2020, the two Regulations have also split on scope, enforcement body and time limits.

Source: UK261 art. 7(1) (as substituted by SI 2019/278) — legislation.gov.uk; Regulation (EC) No 261/2004 art. 7(1) — eur-lex.europa.eu, checked 2026-09-15.

UK261 and EU261 after Brexit, point by point

Source: UK261 arts. 3(1), 3(1A), 3(9), 6(3), 7(1)-(2), 16(1) — legislation.gov.uk; CAA, Delays — caa.co.uk; Regulation (EC) No 261/2004 arts. 3(1), 7(1)-(2), 16(1); Sturgeon (C-402/07, 2009), para 63 — eur-lex.europa.eu, checked 2026-09-15.

The UK261 vs EU261 gap is widest in the carve-outs. Both Regulations keep article 7(2): the airline may halve the amount when a re-routed flight’s arrival does not exceed the scheduled arrival by 2, 3 or 4 hours, by band. An intra-Community flight over 3,500 km keeps its €400, with no 3 to 4 hour cut.

A Dublin departure goes to the Irish Aviation Authority, and so does a New York to Dublin arrival. The Commission’s list of national enforcement bodies, updated 27 August 2026, covers the 27 Member States plus Iceland, Norway and Switzerland, and several States name more than one body. Under UK261, article 3(9) points to section 9 of the Limitation Act 1980. Scotland has 5 years under the Prescription and Limitation (Scotland) Act 1973, and no Scottish court has decided which rule governs a UK261 claim. Ireland gives 6 years under the Statute of Limitations 1957.

Use the amount table of the law your route triage produced, in its own currency, and check the deadline for the courts where you would sue on the flight compensation time limits page. The passenger rights comparison table lines up all four regimes.

All guides in this topic

• Bumped from a flight: £220–£520 UK, up to C$2,400 in Canada — EU261 pays €250–€600, US rules 200% or 400% of your fare up to $2,150, and a Canadian carrier must pay within 48 hours.
• EU261 on transatlantic flights: when €600 applies — UK261 pays up to £520 on UK-US flights; US airlines owe EU261 on flights leaving the EU, not into it.
• Flight cancelled due to weather: what 4 regimes still owe — A weather excuse leaves UK261 and EU261 care and a 7-day refund intact; APPR owes rebooking within 48 hours or a refund.
• Flight compensation calculator: UK261, EU261, APPR and DOT — Enter your route and delay to see UK261, EU261, APPR or US DOT compensation — US denied-boarding caps run $1,075-$2,150 since 22 Jan 2025.
• Flight delay claim time limits: 6 years E&W, 1 year Canada — Scotland’s 1973 Act sets 5 years, untested for UK261 claims.
• Lost luggage compensation: up to 1,519 SDR, 21-day deadline — Damaged bag: written complaint within 7 days of receipt; sue within 2 years.
• Missed connection compensation: one booking, 3 hours late — On one booking, UK261 pays £220-£520 and EU261 €250-€600 by great-circle distance from your first airport; APPR C$125-C$1,000.
• Passenger rights compared: UK261, EU261, APPR, DOT — Denied boarding pays up to C$2,400 under APPR and $2,150 under US rules; the Montreal baggage limit has been 1,519 SDR since 28 December 2024.
• The 3-hour delay rule in 4 regimes: when a delay counts — 2 hours triggers care, not cash, on short UK261/EU261 routes — compensation starts at 3 hours.

General information, not legal advice. For your specific case: the CAA if UK261 applies, a national enforcement body or the European Consumer Centre network if EU261 applies, the Canadian Transportation Agency if APPR applies, the US Department of Transportation for US rules, or a solicitor.

#Sources

• Regulation (EC) No 261/2004 (EU text), arts. 2, 3, 7, 12, 16 - eur-lex.europa.eu, checked 2026-09-15.
• Regulation (EC) No 261/2004 as it forms part of UK law, arts. 2, 3, 6, 7, 16 - legislation.gov.uk, checked 2026-09-15.
• Aviation (Consumers) (Amendment) Regulations 2023 (SI 2023/1370) - legislation.gov.uk, checked 2026-09-15.
• Limitation Act 1980, s.9 - legislation.gov.uk, checked 2026-09-15.
• Limitation (Northern Ireland) Order 1989, art. 4 - legislation.gov.uk, checked 2026-09-15.
• Prescription and Limitation (Scotland) Act 1973, s.6 - legislation.gov.uk, checked 2026-09-15.
• Civil Aviation Authority, Delays - caa.co.uk, checked 2026-09-15.
• EEA Joint Committee Decision No 171/2004 - eur-lex.europa.eu, checked 2026-09-15.
• EU-Switzerland Air Transport Agreement, consolidated text - eur-lex.europa.eu, checked 2026-09-15.
• Commission Interpretative Guidelines C/2024/5687 - eur-lex.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 - iaa.ie, checked 2026-09-15.
• Statute of Limitations 1957, s.11 - revisedacts.lawreform.ie, checked 2026-09-15.
• Canada Transportation Act, ss. 85.04, 86.11 - laws-lois.justice.gc.ca, checked 2026-09-15.
• Air Passenger Protection Regulations (SOR/2019-150), ss. 1, 3, 10-12, 14, 19, 20 - laws-lois.justice.gc.ca, checked 2026-09-15.
• US DOT, Fly Rights - transportation.gov, checked 2026-09-15.
• US DOT, File a consumer complaint - transportation.gov, checked 2026-09-15.
• 14 CFR Part 250 (denied boarding) - ecfr.gov, checked 2026-09-15.
• 14 CFR Part 260 (refunds) - ecfr.gov, checked 2026-09-15.
• 14 CFR 259.7 (complaint responses) - ecfr.gov, checked 2026-09-15.
• Civil Aviation Authority, Airline licence holders - caa.co.uk, checked 2026-09-15.
• EASA, Authorised Third Country Operators list - easa.europa.eu, checked 2026-09-15.
• European Commission, EU air carriers holding an active operating licence - transport.ec.europa.eu, checked 2026-09-15.
• Sturgeon (C-402/07 and C-432/07, 2009), CJEU - eur-lex.europa.eu.
• Wirth (C-532/17, 2018), CJEU - eur-lex.europa.eu.
• Wegener (C-537/17, 2018), CJEU - eur-lex.europa.eu.
• Folkerts (C-11/11, 2013), CJEU - eur-lex.europa.eu.
• Gahan v Emirates [2017] EWCA Civ 1530, Court of Appeal - caselaw.nationalarchives.gov.uk.

#FAQ

Is the UK version of EU261 the same as EU261?

£220, £350 or £520 under UK261 against €250, €400 or €600 under EU261: the two are no longer the same. Since 31 December 2020 UK261 covers UK departures and licence-gated arrivals into the UK or the EU, while EU261 covers departures from the EU, Iceland, Norway and Switzerland and arrivals on a Community carrier.

Does EU261 only apply to EU citizens?

Article 3(1) of EU261 sets scope by flight, not by nationality. Any passenger departing an airport in the EU, Iceland, Norway or Switzerland is covered on any airline, and a passenger flying in from outside is covered on a Community carrier. A UK, US or Canadian citizen on a covered flight holds the same rights.

Does UK261 apply to non-UK airlines?

Article 3(1)(a) of UK261 covers any airline leaving a UK airport. On flights into the UK, a Community carrier is covered too. A carrier licensed outside both the UK and the EU is not covered on that inbound leg, and for Swiss-, Norwegian- and Icelandic-licensed carriers the answer is not settled.

Can I claim under APPR and EU261 for the same flight?

2 laws can cover a Toronto to Paris flight on a Community carrier: APPR on the itinerary and EU261 on arrival. The carrier must not refuse APPR compensation just because EU261 also applies, but APPR pays nothing once EU261 compensation for the same event is received. EU261 does not apply if you received benefits or compensation and assistance in Canada.