When the UK left the EU it kept Regulation 261 in domestic law. The result is UK261, which works the same way as EU261: same three hour threshold, same distance bands, same list of extraordinary circumstances, same burden of proof on the airline.
The practical differences are the currency and who enforces it.
| Flight distance | EU261 | UK261 |
|---|---|---|
| 1,500 km or less | €250 | £220 |
| Over 1,500 km inside the EU | €400 | £350 |
| 1,500 km to 3,500 km | €400 | £350 |
| Over 3,500 km | €600 | £520 |
The sterling figures are fixed, not converted. Depending on the exchange rate on the day, a UK claim can be worth slightly more or slightly less than the euro equivalent. You do not get to pick whichever is higher.
The departure airport decides. Not the airline, not where you live, not where you booked.
This catches people out constantly on return trips. The outbound and the inbound leg of the same holiday can fall under different schemes and pay in different currencies.
Same logic. If you departed a UK airport, escalation goes to the Civil Aviation Authority or an approved ADR scheme. If you departed an EU airport, it goes to that country's regulator, even when the airline is British.
A British Airways flight out of Madrid is a Spanish AESA case, not a CAA one. Sending it to the wrong body wastes weeks.
Nothing that matters to a passenger. The three hour threshold, the extraordinary circumstances defence, the duty to provide meals and hotels, the burden of proof sitting with the airline: all identical on both sides.
If you flew before the UK left, the old rules applied and the claim is still live if you are inside the time limit. UK claims run to six years.
Check which one covers you