In short: UK261 and EU261 cover flights departing the UK or EU on any airline, and flights arriving there only on a UK or EU airline. For flights into Europe on other airlines, the rules of the departure country may help: Canada and Turkey pay fixed compensation for some delays, Israel pays when a delay reaches 8 hours, the United States requires refunds but not compensation, and Brazil and the UAE focus on meals, hotels and rebooking. The Montreal Convention covers proven losses almost everywhere.
Step 1: is UK261 or EU261 enough?
Before looking at foreign law, check whether your flight is covered by UK261 or EU261. They usually pay more, and you can claim from the UK or EU.
| Flight | UK airline | EU airline | Other airline |
|---|---|---|---|
| Departs the UK | UK261 | UK261 | UK261 |
| Departs the EU (or Iceland, Norway, Switzerland) | EU261 | EU261 | EU261 |
| Arrives in the UK from outside Europe | UK261 | UK261 | Not covered |
| Arrives in the EU from outside Europe | UK261 | EU261 | Not covered |
| Outside Europe, as a later leg of one booking that started in the UK or EU | Covered as part of the whole journey (UK261 Art. 3(1A); Gahan v Emirates; Wegener, C-537/17) | ||
So London–Toronto, London–New York, London–Istanbul and London–Dubai are covered by UK261 on any airline, while the return flights are covered only on a UK or EU airline. Check your flight in our compensation checker.
Six regimes compared
| Regime | Covers | Fixed compensation for delay? | Care | Claim deadline |
|---|---|---|---|---|
| UK261 / EU261 | Departures from UK/EU; arrivals on UK/EU airlines | Yes, 3 h+ at arrival: £220–£520 / €250–€600 | From 2/3/4 h by distance | National law (e.g. 6 years in England and Wales) |
| Canada – APPR | To, from and within Canada | Yes, if within the airline's control and not for safety: CA$400–1,000 (large airlines) | From 2 h (within control) | 1 year to claim from the airline |
| United States | To, from and within the US | No – refunds only | Airline policy; tarmac rules | – |
| Turkey – SHY-YOLCU | Turkish airlines to/from Turkey; all departures from Turkey | Yes, 3 h+ for technical/operational reasons: €100–€600 (in lira) | From 2/3/4 h by distance | Not set in the regulation |
| Israel – Aviation Services Law | To and from Israel | Only from 8 h (treated as cancellation), in shekels | From 2 h | 4 years |
| Brazil – ANAC Res. 400 | Flights in, to and from Brazil | No (bumping: 250/500 SDR) | Food from 2 h; hotel from 4 h | – |
| UAE – GCAA CAR-PWP | Flights to and from UAE airports | No | Meals from 3 h; hotel over 8 h | Dubai: complain to airline within 60 days |
Summary only. Each country guide gives the exact conditions, exemptions and article numbers, and lists what we could not verify from an official source.
Country guides
- Canada – Air Passenger Protection Regulations (APPR). Flights to, from and within Canada. CA$400–1,000 (large airlines) for delays within the airline's control; CA$900–2,400 for bumping; claim within 1 year.
- United States – DOT refund rule, 14 CFR part 260. No federal delay compensation. Automatic refunds for cancellations and significant changes (3 h domestic / 6 h international) within 7 business days.
- Turkey – SHY-YOLCU regulation. Turkish airlines to/from Turkey and all departures from Turkey. €100–€600 in lira for cancellations, bumping and, since Dec 2024, 3 h+ technical/operational delays.
- Israel – Aviation Services Law 2012. Flights to and from Israel. Care from 2 h, refund from 5 h, 8 h+ delay counts as a cancellation with compensation in shekels.
- Brazil – ANAC Resolution 400 (amended 2026). Food after 2 h, accommodation after 4 h if overnight, options after 4 h, refunds in 7 days; 250/500 SDR for bumping; no fixed delay compensation.
- United Arab Emirates – GCAA CAR-PWP; Dubai 2026 directive. Care only: information 1–3 h, meals 3–8 h, hotel over 8 h; Dubai adds complaint mediation. No fixed compensation.
When two regimes apply to the same flight
Many flights are covered twice. London–Toronto on Air Canada is covered by UK261 (it departs the UK) and by the APPR (it flies to Canada); London–Istanbul on Turkish Airlines by UK261 and SHY-YOLCU; Tel Aviv–London on British Airways by UK261 and Israeli law. In those cases:
- You are normally compensated once. UK261 and EU261 exclude passengers on inbound flights who received benefits or compensation and assistance in the non-European country (Article 3(1)). Canada's law bars APPR compensation for an event already compensated under another passenger rights regime (Canada Transportation Act s.86.11(3)), and Israel's law has a similar rule (s.20).
- The tests differ. A technical fault normally earns compensation under UK261 and EU261 and under Turkey's 2024 rule, but a "required for safety" problem pays nothing under the APPR, and Dubai's 2026 directive treats technical defects as force majeure.
- The amounts differ. European and Turkish amounts depend on distance; Canadian amounts on the length of the delay; Israeli amounts on distance but with different bands, in shekels.
- Deadlines differ. Canada gives you one year to claim from the airline; a UK261 court claim in England and Wales can be brought within six years (time limits).
State clearly in your claim which rules you rely on. For a European claim, the steps are in how to claim.
The Montreal Convention applies almost everywhere
Separately from these schemes, the Montreal Convention makes airlines liable for proven losses caused by delay (up to 6,303 SDR per passenger) and for lost, delayed or damaged baggage (up to 1,519 SDR) on international journeys between countries that have joined it. Canada, the United States, Turkey, Israel, Brazil and the UAE are all parties, as is the UK. It is not a fixed payment: you have to show what the delay cost you, and court action must start within 2 years.
Other countries
We have not yet covered other national schemes in this series. If you were delayed on a flight to the UK or EU from elsewhere on a non-European airline, ask the airline which local rules it applies, keep receipts, and consider a Montreal Convention claim for proven losses. On flights where one leg started in the UK or EU on the same booking, check UK261 or EU261 first – see missed connections.
Frequently asked questions
Does UK261 apply to flights from outside Europe?
Only if a UK or EU airline operates the flight into the UK (or a UK airline into the EU), or if the flight is part of a single booking that started in the UK. A flight from New York, Istanbul, Toronto or Dubai to London on a non-European airline is not covered by UK261 – but the departure country's own rules may apply.
Which countries outside Europe pay fixed compensation for delays?
Of the six regimes we cover, Canada (APPR: up to CA$1,000 for delays within the airline's control), Turkey (SHY-YOLCU: €100–€600 for technical or operational delays of 3 hours or more since December 2024) and Israel (fixed compensation in shekels when a delay reaches 8 hours) do. The United States, Brazil and the UAE focus on refunds and care, with fixed amounts only for denied boarding in Brazil.
Can I be paid under two schemes for the same delay?
Generally not. UK261 and EU261 exclude passengers on inbound flights who already received compensation and assistance in the non-European country, Canada's law bars APPR compensation if you were compensated under another regime for the same event, and Israel's law has a similar rule. Compare the options and claim under the one that suits your case.
General information, not legal advice; we are not lawyers. Foreign amounts are in their own currencies; translations of foreign legal texts are our own. We are an independent guide and an affiliate partner of AirHelp – see our affiliate disclosure.
Sources
- Regulation (EC) No 261/2004 – UK version, Article 3 (scope) – legislation.gov.uk
- Regulation (EC) No 261/2004 – Article 3 (scope) – EUR-Lex
- Gahan v Emirates [2017] EWCA Civ 1530 – The National Archives
- Air Passenger Protection Regulations (SOR/2019-150) – Justice Laws Website, Government of Canada
- Refunds and Other Consumer Protections, final rule (Federal Register, 26 April 2024) – US Department of Transportation
- SHY-YOLCU amending regulation, Resmî Gazete No 32748, 10 December 2024 – Resmî Gazete (Türkiye)
- Aviation Services Law 5772-2012 – English translation – El Al Israel Airlines (translation of the law)
- Resolução nº 400/2016 (texto compilado) – ANAC, Brazil
- CAR-PWP – Passenger Welfare Program, Issue 02 – GCAA, United Arab Emirates
- Montreal Convention 1999 – list of parties – ICAO
We check every rule against the sources above. Spotted an error? Tell us – see our editorial policy.