EU261 vs UK261 vs APPR: which applies?
The same disruption can fall under different rules depending on where you flew and who operated the flight. Picking the right regime first gives the airline one clear question to answer.
“EU261 vs UK261 vs Canada APPR explained”
Use three filters:
- Departure and arrival geography.
- Operating carrier nationality/category.
- Disruption type (delay, cancellation, denied boarding).
Then verify amount table.
Scope basics in one screen
EU261
Covers every flight departing an EU/EEA/Swiss airport, and flights arriving there on an EU/EEA/Swiss airline unless you received benefits or compensation and assistance under the law of the departure country (EU261 Article 3(1) (opens in a new tab)).
UK261
Covers every flight departing a UK airport, and flights arriving in the UK on a UK or EU airline (UK261 Article 3 (opens in a new tab)).
APPR
Applies to flights to, from, or within Canada under the APPR framework (APPR (opens in a new tab)).
“Are they able to pay my companion under EU and me under APPR?”
Each passenger is paid under whichever regime covers their own flight, so on the same booking that is usually the same regime for everyone. An airline cannot refuse APPR compensation just because another regime could also apply (APPR s.3(3), APPR (opens in a new tab)), but no one can be paid twice: APPR compensation is not owed if you were already compensated for the same event under another law (Canada Transportation Act s.86.11(3) (opens in a new tab)).
If two passengers on one booking got different answers, send:
- same booking proof,
- same route/arrival evidence,
- side-by-side claim references,
- request for uniform legal basis explanation.
Amount tables you should know
EU261
- €250 / €400 / €600 (EU261 Article 7(1) (opens in a new tab)).
- Potential 50% reduction in specific scenarios under Article 7(2) (EU261 Article 7(2) (opens in a new tab)).
UK261
- £220 / £350 / £520 in retained UK framework usage (UK261 retained text (opens in a new tab)).
- Delay compensation is due from 3 hours or more late at the final destination (CJEU Sturgeon (opens in a new tab)). For EU261 only, this becomes more than 3 hours for flights from 23 October 2027 (Regulation (EU) 2026/2202).
APPR
Section 19 delay/cancellation compensation:
- Large carrier: C$400 / C$700 / C$1,000.
- Small carrier: C$125 / C$250 / C$500.
Section 20 denied boarding:
- C$900 if you arrive less than 6 hours late, C$1,800 for 6 to 9 hours, C$2,400 for 9 hours or more.
(APPR sections 19-20 (opens in a new tab))
US context if your trip touches US airports
US federal pieces in this toolkit:
- denied boarding compensation in Part 250,
- refund obligations after cancellation/significant change in Part 260.
(14 CFR Part 250 (opens in a new tab), 14 CFR Part 260 (opens in a new tab))
Part 250 sets 200% up to $1,075 and 400% up to $2,150 in specified denied-boarding conditions (14 CFR 250.5 (opens in a new tab)).
Overlap examples passengers ask about
Example A: Paris to London on Air France
Both apply: EU261 because the flight departs the EU, and UK261 because it arrives in the UK on an EU airline. There is no official guidance on choosing, and you cannot be paid twice, so claim under one, usually EU261 as the departure rule.
Example B: London to Toronto
UK261 applies because the flight departs the UK, and APPR applies because the flight is to Canada. You cannot be paid twice for the same event, so claim under one. Check both UK261 and APPR amounts for your delay.
Example C: New York to London on UK/EU carrier
UK261 applies because the flight arrives in the UK on a UK or EU airline. EU261 does not, because the UK is not an EU country, and US federal rules pay no cash for delays. Verify route and carrier details in the checker.
Which one should you file under first?
Recommendation strategy:
- Choose the regime with clearest direct fit to route + carrier.
- Choose the one with clearest amount bracket evidence for your facts.
- Keep overlap argument ready, but avoid multi-regime first email unless needed.
A focused first claim is easier for the airline to answer.
“What are my rights here?” quick mapping
- EU airport departure? Start EU261 check.
- UK airport departure or UK inbound with qualifying carrier? Start UK261 check.
- Any Canada-touching route? Run APPR check too.
- US denied boarding or refund dispute? Add Part 250/260 lens.
Then submit one coherent claim with source citations.
Where people go wrong
- Using marketing blog summaries instead of regulation text.
- Citing compensation when remedy sought is refund.
- Ignoring denied boarding as separate legal category.
- Missing final-arrival evidence.
Best workflow
- Run checker.
- Open relevant rule pages: EU261, UK261, APPR, US.
- Draft from letters.
- Track dates in deadlines.
This keeps your claim specific, source-backed, and escalation-ready.
Priority order when multiple regimes seem possible
Citing every regime at once makes the claim harder to answer. A better approach:
- Start with the most direct route/carrier fit.
- Include one fallback sentence noting overlap possibility.
- Keep second-regime argument for follow-up if denied.
This keeps first review simple while preserving your escalation position.
Carrier identity mistakes that change outcomes
A frequent error is naming the ticketing brand instead of the operating carrier. Scope analysis and some compensation logic can hinge on operating carrier identity, especially in inbound cases under EU/UK structures (EU261 Article 3 (opens in a new tab), UK261 retained text (opens in a new tab)).
Check your boarding pass or “operated by” line before filing.
Connection itineraries: one booking vs separate tickets
On one booking, compensation is based on your delay at the final destination (CJEU Folkerts (opens in a new tab)). On separate tickets, each flight is assessed on its own.
That is why your submission should always state whether all legs were on one booking reference.
Quick pre-submit jurisdiction check
Before sending, confirm these five fields in your draft:
- departure airport country,
- final destination country,
- operating carrier,
- disruption type,
- final arrival delay.
Those five fields usually determine whether your claim should be centered on EU261, UK261, APPR, or US Part 250/260 context (14 CFR Part 250 (opens in a new tab), 14 CFR Part 260 (opens in a new tab)).
Self-help information and templates only; this is self-help, not legal advice.
Not sure what you are owed? The free checker applies these rules to your flight in about two minutes and shows the amount and your deadline.
Related guides
This article is self-help information, not legal advice. It explains published rules so you can claim yourself; check the sources below and your own booking before relying on it.