UK261, Israel, Canada and the US: which rules apply?

After Brexit, the UK copied Regulation 261/2004 into its own law, and airlines and lawyers call this version UK261. You keep the rights you knew: compensation, meals and drinks, hotels, refunds and rebooking. The Civil Aviation Authority still sets these rights out in its passenger guidance.

Article 7 of the UK's retained version sets the amounts on the same distance bands as the EU rules. A flight up to 1,500 km pays £220. A flight between 1,500 and 3,500 km pays £350. A longer flight pays £520, or £260 when it lands three to four hours late.

A London to New York flight lands five hours late because of a crew shortage. The route covers about 5,540 km, so the airline owes you £520.

The two systems are now separate laws, so keep them apart in your letter. Name UK261 for a flight from a UK airport, and EU261 for a flight from an EU airport. In England and Wales you generally have six years to go to court, and five in Scotland.

Write first to the airline that operated the flight. Keep your booking, boarding pass and any messages about the delay.

Put it in numbers: a London to Paris hop of about 347 km lands three and a half hours late after a maintenance problem. Under UK261, the airline owes you £220. Your Paris to London return lands just as late for the same reason. That flight falls under EU261, so the airline owes you €250.

The split follows one shared rule in Article 3 of Regulation 261/2004 and of the UK's retained version: the departure airport decides. UK261 covers every flight that leaves a UK airport. EU261 covers every flight that leaves an EU airport. For departures, the airline's nationality does not matter.

Flights into the UK add one twist. UK261 also reaches a flight from the EU into the UK when a UK or EU airline operates it. EU261 already covers that Paris departure, so the two rules overlap. The UK rule steps aside when you already received compensation and care under the EU rule.

So pick the regime that fits your departure airport, and claim under it once. Write to the airline that operated the flight and name the right regulation.

Check your booking for the words “operated by”. Under Article 3 of the UK's retained Regulation 261/2004, the operating airline decides whether a flight into the UK is covered. The airline that sold you the ticket does not.

UK261 treats flights into the UK differently from flights out of it. Any flight leaving a UK airport qualifies. A flight arriving from outside qualifies only when a UK or EU airline operates it.

A worked case: British Airways operates your New York to London flight. A technical problem with the aircraft makes it land four hours late. The route covers about 5,540 km, so under Article 7 British Airways owes you £520. Put the same delay on an American Airlines-operated flight, and UK261 gives you nothing. The return leg from London is a separate flight, covered on either airline.

Without UK261, the Montreal Convention may still help with costs you can prove. That treaty pays actual losses, not a fixed sum. US federal rules do not add cash compensation for a delay. Claim from the operating airline in writing, and keep receipts for meals or hotels.

A US trip can still fall under European rules. Article 3 of Regulation 261/2004 brings in every flight that leaves an EU airport, on any airline. Imagine flying Paris to New York on a US airline. A fault found during the pre-flight checks makes you land five hours late. The route covers about 5,830 km, so the airline owes you €600.

The other direction is narrower. A flight from the US into the EU qualifies only when an EU airline operates it.

At home, the US takes a different route. EU261 sets fixed cash amounts for long delays, cancellations and denied boarding. US federal rules focus on refunds, not compensation, for the delay itself. Extras for a late flight, such as meal vouchers, depend on the airline's own commitments.

On an international trip, Article 19 of the Montreal Convention can also cover losses you can prove, such as a hotel night you lost. It pays actual damage, not a fixed sum, and the airline can defend itself. Check where your flight departed and who operated it. Then write to the airline and name the rule that fits.

The departure airport decides EU261's reach, not the airline's home country. A US airline leaving Amsterdam owes you the same as KLM would. The delay counts at your final destination, measured when the doors open.

United flies you from Amsterdam to Chicago, about 6,610 km. Your aircraft arrives late, held up by an earlier fault, and you land five hours late. United owes you €600 under Article 7. Land between three and four hours late, and the airline may halve it to €300. Bad weather or air traffic control limits can excuse the airline. It must prove the cause and that it took all reasonable measures.

Write to the airline's claims team, cite Articles 3(1)(a) and 7 of Regulation 261/2004, and ask for cash. The airline can pay in vouchers only with your signed agreement.

Your deadline depends on the country where you claim: two years in the Netherlands and five in France, for example. The EU approved a reform on 7 July 2026 with a single nine-month deadline. It is expected to apply from the second half of 2027. Until then, the national limits stand.

Article 3 of Regulation 261/2004 never asks about nationality. The test is the flight. A flight that departs an EU airport qualifies on any airline. A flight into the EU qualifies when an EU airline operates it. You also need a confirmed booking and an on-time check-in, unless the airline cancelled.

An Israeli passenger flies El Al from Frankfurt to Tel Aviv, about 2,950 km. A technical problem with the aircraft makes the flight land four hours late. The flight left an EU airport, so El Al owes that passenger €400, the same as any German on board.

Israel's Aviation Services Law may also reach that flight, because it lands in Israel. That law has its own thresholds and amounts. Do not assume one law's answer carries over to the other.

Claim from the operating airline in writing and cite Articles 3 and 7 of Regulation 261/2004. Point out that your nationality plays no part in the scope test. Keep your boarding pass and booking confirmation.

Imagine Emirates flies you from London to Dubai, about 5,500 km. A maintenance problem makes you land five hours late, so Emirates owes you £520 under UK261. Your Dubai to London return, also five hours late, earns nothing under UK261. The return counts as a separate flight, even on one ticket.

The difference comes from Article 3 of Regulation 261/2004 and of the UK's retained version. Every departure from Europe qualifies. A flight into Europe qualifies only when a European airline operates it. For EU261 that means an EU airline, and for UK261 a UK or EU airline. Emirates is neither, so its flights from Dubai fall outside both.

A delayed flight from Dubai is not always a dead end. The Montreal Convention lets you claim losses you can prove, such as a hotel night you paid for and missed. It pays actual damage, not a fixed sum.

A trip that began in Europe and connected in Dubai follows another rule, measured at the final destination. Whatever the route, keep receipts and write to Emirates.

EU261 reaches beyond the 27 EU countries. Flights leaving Norway, Iceland and Switzerland follow the same rules, on any airline. The same distance bands set the amount, and the same three-hour test applies to delays.

For instance, a Zurich to London flight of about 790 km lands three and a half hours late after a crew shortage. The airline owes you €250 under EU261. A Reykjavík to London flight, about 1,900 km, would pay €400 for the same delay. Under UK261, a flight from London back to Zurich pays £220.

Swiss delay claims draw the most disputes. Passengers report Swiss airlines arguing that no delay compensation is due for flights to and from Switzerland. Cancellations and denied boarding cause less argument. On a Swiss delay, expect to push your claim further.

Start with the operating airline and cite Articles 6 and 7 of Regulation 261/2004. If it refuses, the national enforcement body in that country can review the complaint. Keep your booking and the arrival time.

Article 3 of Regulation 261/2004 covers every flight from an EU airport, but flights into the EU only on an EU airline. So Turkish Airlines owes EU261 compensation on the way out of Europe, not on the way back.

Put it in numbers: Turkish Airlines flies you from Frankfurt to Istanbul, about 1,840 km. A technical problem with the aircraft makes you land three and a half hours late, so the airline owes you €400. Your Istanbul to Frankfurt return on Turkish Airlines lands just as late, and EU261 gives you nothing. Had Lufthansa operated that return, EU261 would apply, because Lufthansa is an EU airline.

UK passengers follow the same logic. A London to Istanbul flight, about 2,490 km, pays £350 under UK261 for a three-hour late arrival within the airline's control.

On a flight from Istanbul, find out what Turkish rules offer and keep receipts for any costs. The Montreal Convention can cover losses you can prove on an international trip. Claim cash, not miles. Under EU261, the airline needs your signed agreement to pay in vouchers.

The Aviation Services Law covers flights that depart from or arrive in Israel, on Israeli and foreign airlines alike. It has its own rules, separate from EU261's. A delay earns fixed compensation only once the law treats it as a cancellation. The EU three-hour test does not carry over.

Distance sets the amount. Imagine the airline cancels your Tel Aviv to New York flight, about 9,120 km, at short notice. If the law does not exempt the reason, the airline owes you about ₪3,580. A Frankfurt to Tel Aviv flight, about 2,950 km, falls in the middle band at about ₪2,390. Indexing moves the numbers, so read the current official figure for your flight date.

The exemptions differ from EU case law, too. A reason that excuses an airline under EU261 does not automatically excuse it in Israel, and the reverse holds as well.

Write to the operating airline and cite the Aviation Services Law, 5772-2012. You have four years to claim under Israeli law. Keep your booking and any cancellation messages.

Israeli and European rules are easy to mix up. EU261 pays fixed compensation from a three-hour late arrival. Israel's law instead treats a long enough delay as a cancellation and pays on that basis. A shorter delay can still bring other duties under the law, but not the fixed sum.

The flight's direction can change your options. A worked case: El Al flies you from Frankfurt to Tel Aviv, about 2,950 km. A late aircraft, held up by an earlier fault, gets you in four hours late. The flight left an EU airport, so EU261 applies and El Al owes you €400. That holds even if the delay falls short of Israel's threshold. On El Al's Tel Aviv to Frankfurt flight, only Israeli law applies, because El Al is not an EU airline.

Israel's exemptions differ from EU case law as well. Do not copy an EU answer into an Israeli claim.

Before you write to El Al, check the current text of the Aviation Services Law, 5772-2012, and the Civil Aviation Authority's guidance. Give your flight, date and arrival time. Israeli law gives you four years to claim.

Two laws can reach the same route. Article 3 of Regulation 261/2004 looks at the departure airport and, for flights into Europe, at the operating airline. Israel's Aviation Services Law, 5772-2012, covers flights that depart from or arrive in Israel, whatever the airline.

For instance, El Al flies you from Paris to Tel Aviv, about 3,280 km. An engineering fault on the aircraft makes you land three and a half hours late, so El Al owes you €400 under EU261. On the Tel Aviv to Paris return, EU261 does not apply to El Al. Had Air France operated that return, it would, because Air France is an EU airline.

Israeli law applies to all three flights, but only once a delay passes its own, longer threshold. Your passport plays no part in the EU test. An Israeli on El Al from Paris has the same EU rights as a French passenger.

Pick the law that fits your flight, and cite it in your letter.

The Aviation Services Law, 5772-2012, applies to flights that depart from or arrive in Israel. It does not ask whether the airline is Israeli. A US or European airline on a Tel Aviv route answers to it just as El Al does.

United cancels your Newark to Tel Aviv flight, about 9,140 km, at short notice for a reason the law does not exempt. The flight falls in the top band, so United owes you about ₪3,580. Indexing changes the figure, so check it for your flight date. A long enough delay can count as a cancellation, but under the law's own thresholds, not the EU's three hours.

Make the claim in writing. Give your booking reference, flight number, date, route and what the airline told you. Ask to be paid in money, and keep copies of everything you send and receive.

You have four years under Israeli law to bring the claim. Leave EU arguments about extraordinary circumstances out of it, because Israel's exemption rules differ.

Air Canada flies you from Toronto to Vancouver, and a crew scheduling problem makes you land seven hours late. Crew scheduling sits within the airline's control. As a large carrier, Air Canada owes you CA$700. Land ten hours late, and the figure rises to CA$1,000.

That follows from how the Air Passenger Protection Regulations work. They cover flights to, from and within Canada, and they sort every disruption into three groups. A disruption is within the airline's control, within its control but required for safety, or outside its control. Only the first group earns compensation. The amount depends on how late you reach your final destination.

Denied boarding pays more. A large airline that bumps you owes CA$900 if you arrive less than six hours late. The figure is CA$1,800 for six to nine hours, and CA$2,400 for nine hours or more.

Send your request to the airline within one year. If it refuses, you can complain to the Canadian Transportation Agency. You will find these rules in sections 19 and 20 of the Air Passenger Protection Regulations.

The airline's label is the whole case. Canada's rules put each disruption in one of three groups. It sits within the airline's control, within its control but required for safety, or outside its control. Only the first earns compensation.

Your Air Canada flight reaches its final destination ten hours late. If the cause sat within the airline's control and safety did not require it, Air Canada owes you CA$1,000. If the airline shows that safety required the delay, it owes you no compensation. It still owes you rebooking, or a refund when the new flight no longer meets your needs.

Passengers have pushed back on these labels. News reports describe Air Canada classing staff shortages as safety issues, and passenger advocates disputing that. Tribunals have asked airlines for the evidence behind the label.

Reply to the refusal and request exactly what happened, and why safety required it. Cite sections 19 and 20 of the Air Passenger Protection Regulations. Keep your boarding pass and arrival time. The compensation request must go in within one year, and the Agency's complaint process runs separately.

Section 19 of the Air Passenger Protection Regulations sets the amounts and a one-year limit for asking the airline for compensation. Start with the airline, not the regulator. Use its claim form or write to it, and keep a copy.

Your request should name the flight, the date and your final destination, with your scheduled and real arrival times. A worked case: your WestJet flight from Calgary to Toronto reaches Toronto six and a half hours late. The cause lay within the airline's control. As a large carrier, WestJet owes you CA$700. Quote that figure and ask for payment in money.

If the airline refuses, have it explain the cause in writing. You can then file a complaint with the Canadian Transportation Agency. Some passengers also take APPR claims to a provincial small-claims body, such as British Columbia's Civil Resolution Tribunal.

Keep every email, boarding pass and receipt. Whichever route you take, you will need them to show what happened and when.

An Air Canada flight from Frankfurt to Toronto meets both tests. EU261 looks at the departure airport. APPR looks at whether the flight goes to, from or within Canada.

That route covers about 6,340 km. A routine technical fault makes you land five hours late. Under EU261, a routine technical problem generally counts as the airline's own issue, so Air Canada owes you €600. Under APPR, the same delay pays CA$400 if it sat within the airline's control and safety did not require it. APPR may class a mechanical fault as required for safety, which pays nothing.

The deadlines differ too. APPR gives you one year to ask the airline. Under EU261 the national limit applies, such as three years in Germany, ending on 31 December. The EU approved a reform on 7 July 2026 that sets a single nine-month deadline, expected from the second half of 2027. Until then, the national limits stand.

Pick the stronger claim and name the rule in your letter: Article 7 of Regulation 261/2004, or section 19 of the APPR. Do not expect the airline to pay you twice for one delay.

A non-EU airline flies you from Bangkok to Frankfurt, about 9,000 km, and you land ten hours late. EU261 does not apply, because the flight started outside the EU on a non-EU airline. You missed a prepaid hotel night and bought two meals. With receipts, you can claim those costs under the Montreal Convention. You cannot claim a fixed €600 on top.

The Montreal Convention is a treaty that covers most international flights. Article 19 makes the airline liable for damage caused by delay. Article 22 caps that liability in Special Drawing Rights, an IMF unit of account. You must show what you lost and that the delay caused it.

The airline has a defence. It avoids liability if it proves it took all reasonable measures to avoid the damage, or that it could not. You also have to keep your losses reasonable.

Collect receipts and send the airline a list of your costs. If it refuses, you must start a court action within two years, counted under Article 35. Your claim rests on Articles 19, 22 and 35 of the Montreal Convention 1999.

Article 3(1) of Regulation 261/2004 has two branches. One covers every departure from an EU airport. The other covers arrivals at an EU airport from abroad, when an EU carrier operates the flight. An EU airline's flight between two foreign airports meets neither, so the airline's nationality alone does not bring EU261 in.

Take a separate ticket from Bogotá to Lima, about 1,888 km, on an EU airline. It lands five hours late after a maintenance problem. EU261 gives no fixed sum, because the flight never touches the EU. Local passenger rules or the Montreal Convention may still help with costs you can prove.

A single booking from Europe changes the picture. Suppose you booked Madrid to Lima via Bogotá as one reservation, with the same EU airline on both legs. The delay and the distance are then assessed at the final destination. Madrid to Lima is about 9,526 km, so arriving in Lima four hours late gives €600 per passenger.

Check your booking confirmation first. If both flights share one booking reference and the trip began in the EU, claim from the operating airline under EU261. If you bought the foreign leg on its own, look to the passenger rules of the country you flew from.

The UK's retained version of Regulation 261/2004 covers passengers departing from any UK airport. Northern Ireland is part of the UK for this purpose. Belfast International and Belfast City count just like London or Manchester. The amounts are £220, £350 and £520 by distance.

Take Belfast International to Malaga, about 2,004 km. The flight lands four hours late after a fault found during the pre-flight checks. The airline owes £350 per passenger under UK261. Coming home, Malaga to Belfast departs an EU airport, so EU261 applies and the same delay is worth €400.

Plenty of people in Northern Ireland fly from Dublin instead. Dublin to Malaga is about 1,867 km and departs an EU airport. A three-hour late arrival in Malaga gives €400 under EU261, again on any airline.

Claim from the airline that operated the flight. If it refuses a claim under the UK rules, the UK Civil Aviation Authority's guidance explains what you can do next. Expect to be paid once for one flight, so do not file under both regimes for the same disruption.