Passenger-rights comparison guide • Updated August 2026

EU261 vs UK261 vs Turkish Passenger Rights: 2026 Comparison

EU261, UK261 and Türkiye's SHY-YOLCU passenger-rights rules protect passengers in similar situations, but they are not interchangeable. The rules that may apply to a disrupted flight can depend on the departure airport, destination, operating airline, disruption type and final arrival time. This guide compares the three frameworks side by side and explains why Europe–Türkiye journeys often need a route-by-route check.

EU261EU/EEA-related air passenger rights, including many flights departing the EU.

UK261UK passenger-rights rules for many flights departing from or arriving in the UK.

SHY-YOLCUTürkiye's passenger-rights framework for covered domestic and international flights.

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EU261 vs UK261 vs Turkish passenger rights: quick comparison

The three systems share several ideas: fixed compensation can be available in qualifying cases, passengers may have care or rerouting rights during disruption, and the operating airline can matter. Their geographical scope and compensation currencies are different, and Turkish rules have their own coverage test for Turkish and foreign carriers.

Question	EU261	UK261	Türkiye / SHY-YOLCU
Core geography	Many flights departing an EU airport; certain flights arriving in the EU when operated by an EU carrier.	Flights departing the UK on any airline; certain flights arriving in the UK on UK/EU airlines; some UK-carrier flights arriving in the EU.	Turkish carriers on flights to/from Turkish airports; foreign carriers on flights departing Turkish airports, subject to the regulation's conditions.
Delay compensation threshold	Generally 3+ hours late at final destination for eligible claims.	Generally more than 3 hours late at destination for eligible claims.	Since the December 2024 amendment, certain technical or operational delays reaching the planned final destination 3+ hours late can trigger compensation duties.
Fixed compensation	Common bands: €250 / €400 / €600.	Common bands: £220 / £350 / up to £520.	Domestic: €100 equivalent; international: €250 / €400 / €600, with Turkish-lira conversion under the regulation.
Cancellation notice	Compensation may be relevant when notice is under 14 days, subject to rerouting and exceptions.	Compensation may be relevant when notice is under 14 days, subject to alternative-flight timing and exceptions.	Uses a similar 14-day structure with specific rerouting timing tests.
Denied boarding	Involuntary denied boarding can trigger compensation, reimbursement/rerouting and assistance.	Similar protection for involuntary denied boarding on covered flights.	Involuntary denied boarding can trigger compensation plus reimbursement/rerouting and care duties.
Airline-control exception	Extraordinary circumstances can remove fixed compensation while some care rights remain.	Compensation may not be due when disruption was outside the airline's control.	Extraordinary-circumstance / force-majeure concepts can affect compensation depending on the disruption type.

Important: A comparison table cannot decide a real claim by itself. On a Türkiye–Europe journey, two frameworks can sometimes appear relevant from the route alone, while the operating carrier, booking structure and direction of travel determine which rules can actually be relied on.

2026 EU rules update: EU institutions completed the legislative adoption process for updated air passenger-rights rules in August 2026. The updated framework preserves the three-hour compensation principle and the €250 / €400 / €600 bands, while adding procedural and other changes. A publication and preparation period applies before implementation. This comparison therefore focuses on the rules currently used for passenger claim checks and should be updated as the new EU rules become applicable.

What is EU261?

EU261 is the European air passenger-rights framework built around Regulation (EC) No 261/2004. It covers denied boarding, cancellation and long delays, with additional rights such as reimbursement, rerouting and care depending on the situation.

EU261 route logic

EU261 can apply to flights departing from an EU airport regardless of where the airline is based, and to certain flights arriving in the EU from outside the EU when operated by an EU airline. Iceland, Norway and Switzerland are also included in the wider European passenger-rights area reflected in official guidance.

Eligible arrival delays can qualify when the passenger reaches the final destination 3 hours or more late.
Cancellation compensation can depend on whether notice was given less than 14 days before departure and on the timing of any rerouting offered.
Involuntary denied boarding can create compensation and assistance rights when the passenger met the booking, check-in and travel-document conditions.
Extraordinary circumstances can remove the right to fixed compensation when the relevant legal test is met.

Read the dedicated guide: EU261 Compensation.

What is UK261?

UK261 is the UK passenger-rights framework derived from Regulation 261/2004 as retained and amended in UK law. The structure is familiar to EU261 users, but the territorial scope and compensation amounts are expressed under UK rules.

UK261 route logic

UK Civil Aviation Authority guidance states that UK rules cover flights departing a UK airport on any airline, flights arriving in the UK on a UK or EU airline, and flights arriving in the EU on a UK airline.

Delay compensation may apply when the passenger arrives at the destination more than 3 hours late and the airline was responsible.
Care rights can begin earlier than the compensation threshold, depending on flight distance and waiting time.
Cancellation compensation may be relevant when the airline gave less than 14 days' notice, depending on alternative-flight timing and the cause.
Common fixed compensation levels are £220, £350 and up to £520 depending on distance and timing.

Read the dedicated guide: UK261 Compensation. For the UK–Türkiye route specifically, see UK–Türkiye Flights and UK261 Rights.

What are Turkish passenger rights under SHY-YOLCU?

Türkiye's passenger-rights framework is set out in SHY-YOLCU, the Regulation on the Rights of Passengers Travelling by Air. It was prepared in parallel with Regulation 261/2004 but has its own legal scope and rules. A December 2024 amendment added an express compensation rule for certain technical and operational delays that result in arrival at the planned final destination 3 hours or more late.

SHY-YOLCU route logic

The regulation covers Turkish air carriers on scheduled and non-scheduled flights to and from airports in Türkiye, and foreign air carriers on flights departing from airports in Türkiye, provided the passenger meets the regulation's booking and check-in conditions.

Domestic compensation under Article 8 is €100 equivalent when the compensation provision applies.
International compensation bands are €250 for flights up to 1,500 km, €400 for flights between 1,500 and 3,500 km, and €600 for flights over 3,500 km.
For Turkish-lira payments, the regulation uses the Central Bank of the Republic of Türkiye foreign-exchange selling rate on the payment date.
Cancellation, involuntary denied boarding, rerouting, reimbursement, care and downgrade rights are addressed separately.

Read the dedicated guide: Turkey Flight Compensation.

Which rules may apply on common Europe–Türkiye routes?

Route direction matters. The examples below are a starting point, not a final eligibility decision.

EU → Türkiye

EU261 can apply because the flight departs the EU, including when the operating airline is Turkish. For example, an AJet flight from an EU airport to Türkiye can fall within EU261 even though AJet is not an EU airline. Turkish passenger-rights rules can also be relevant for a Turkish carrier flying to Türkiye. The exact interaction should be checked for the specific claim.

Türkiye → EU on an EU airline

EU261 can apply because the flight arrives in the EU on an EU carrier. SHY-YOLCU can also be relevant because the flight departs from a Turkish airport.

Türkiye → EU on a Turkish airline

A direct flight is generally outside EU261's inbound route rule because the operating airline is not an EU carrier. This is especially relevant to AJet passengers: an AJet-operated flight from Türkiye to the EU is generally outside that EU261 inbound rule, while SHY-YOLCU can be the main passenger-rights framework to check.

UK → Türkiye

UK261 can apply because the flight departs the UK, regardless of airline nationality. If a Turkish carrier operates the flight, Turkish passenger-rights rules may also need consideration.

Türkiye → UK on a UK or EU airline

UK261 can apply to certain arrivals into the UK on UK or EU airlines. SHY-YOLCU can also be relevant because the journey departs Türkiye.

Türkiye → UK on a Turkish airline

UK261's inbound rule generally does not cover a direct Türkiye-to-UK flight operated by a Turkish airline. SHY-YOLCU is the main framework to check for the Turkish departure.

Operating airline matters: A ticket may show the marketing airline while another carrier actually operates the flight. EU261, UK261 and SHY-YOLCU all use operating-carrier concepts in important parts of their rules, so codeshares should be checked carefully.

For flights specifically between the UK and Türkiye, see UK–Türkiye Flights and UK261 Rights. If your disrupted flight was operated by AJet, see the dedicated AJet Compensation Claim guide for an airline-specific explanation of how EU261, UK261 and Turkish passenger-rights rules may apply.

How do compensation amounts compare?

Fixed compensation is not based simply on what the passenger paid for the ticket. Distance, disruption type, final arrival timing, rerouting and the applicable framework can all affect the amount.

Distance / category	EU261	UK261	SHY-YOLCU
Short distance	€250 for qualifying flights up to 1,500 km.	£220 for qualifying short-haul cases up to 1,500 km.	International: €250 up to 1,500 km. Domestic: €100 equivalent.
Medium distance	€400 for qualifying intra-EU flights over 1,500 km and other flights between 1,500 and 3,500 km.	£350 for qualifying cases between 1,500 and 3,500 km.	International: €400 between 1,500 and 3,500 km.
Long distance	Up to €600 for qualifying longer journeys, with some rerouting/delay reductions possible.	Up to £520 for qualifying longer journeys, with reductions possible in some cases.	International: €600 over 3,500 km, with a possible 50% reduction in specified rerouting situations.

For a focused amount guide, see: Flight Compensation Amounts.

How do the three systems treat delays and cancellations?

Flight delays

EU261 and UK261 focus heavily on delay at the final destination for fixed compensation. Türkiye's December 2024 SHY-YOLCU amendment expressly links certain technical or operational delays to a 3-hour-or-more final-arrival threshold.

Flight cancellations

All three frameworks can provide reimbursement or rerouting rights. Compensation can depend on notice timing, replacement-flight timing, the cause of cancellation and whether an exclusion applies.

Care while waiting

Meals, refreshments, communication, hotel accommodation and transport can be separate from fixed compensation. A passenger may have care rights even when fixed compensation is unavailable.

What about denied boarding and missed connections?

Involuntary denied boarding is protected under all three systems when the relevant conditions are met. Voluntarily giving up a seat in exchange for benefits is different from being denied boarding against your will.

EU261: covered passengers denied boarding against their will can have compensation, reimbursement/rerouting and assistance rights.
UK261: similar protections apply on covered UK-law flights when boarding is refused for reasons such as overbooking rather than valid passenger-related grounds.
SHY-YOLCU: the operating carrier must first seek volunteers; if passengers are then involuntarily denied boarding, compensation, reimbursement/rerouting and care duties apply.
Missed connections: the answer can depend heavily on whether flights were on one booking, the final destination, which segment caused the disruption and which legal framework covers the journey.

See: Denied Boarding Compensation and Missed Connection Compensation.

Can extraordinary circumstances stop compensation?

Yes, but the wording and legal test are not identical across every system. Severe weather, air traffic control restrictions, security events, natural disasters and other events outside normal airline control can affect fixed compensation. The airline may still have separate care, rerouting or reimbursement duties.

Do not treat every airline explanation as conclusive: The fact that an airline uses words such as “weather”, “operational reasons” or “technical issue” does not by itself decide the legal result. The cause, evidence, reasonable measures and applicable framework still matter.

Learn more: Extraordinary Circumstances.

What documents help when more than one framework may apply?

Keep records that allow the route, operating carrier, timing and disruption reason to be reconstructed.

Booking confirmation and e-ticket
PNR / booking reference
Flight number and travel date
Departure, connection and final-destination airports
Boarding pass, if available
Airline emails, SMS messages and app notifications
Cancellation notice and any replacement-flight details
Evidence of the actual final arrival time
Any written explanation of the disruption reason
Receipts for meals, hotel, ground transport or other disruption-related costs

Full checklist: Documents Needed for a Flight Compensation Claim.

How to identify which passenger-rights framework to check first

Start with four facts: departure airport, destination, operating airline and disruption type. Then look at the final arrival delay and booking structure.

Start with EU261 when…

the journey departs the EU/EEA passenger-rights area, or it arrives there from outside on an EU carrier.

Start with UK261 when…

the flight departs the UK, arrives in the UK on a UK/EU carrier, or falls within the UK-carrier route rules.

Start with SHY-YOLCU when…

a flight departs a Turkish airport, or a Turkish carrier operates a flight to or from Türkiye within the regulation's scope.

When two systems appear relevant, do not assume you can automatically receive duplicate compensation for the same disruption. The interaction between claims and amounts needs to be assessed under the applicable rules.

Official passenger-rights sources

This guide is based on official sources available in August 2026. Passenger-rights rules can change, so material legal points should be checked against the current regulator or legislation.

EU261 vs UK261 vs Turkish passenger rights FAQ

Are EU261, UK261 and Turkish passenger rights the same?

No. They protect passengers in many similar disruption scenarios, but their territorial scope, legal wording and compensation rules are not identical. The route and operating airline can determine which framework applies.

Which rules apply to a flight from the EU to Türkiye?

EU261 can apply because the flight departs from the EU, regardless of whether the operating airline is EU-based or Turkish. Turkish passenger-rights rules may also need to be considered when a Turkish carrier operates the flight to Türkiye.

Which rules apply to a flight from Türkiye to the EU?

SHY-YOLCU can be relevant because the flight departs from Türkiye. EU261 can also apply when the flight to the EU is operated by an EU airline. A direct Türkiye-to-EU flight on a Turkish airline is generally outside EU261's inbound-carrier rule.

Which rules apply to a flight between the UK and Türkiye?

UK261 can apply to flights departing the UK on any airline. For flights from Türkiye to the UK, UK261 can apply in certain cases when the operating airline is a UK or EU carrier. SHY-YOLCU can also be relevant to flights departing Türkiye and to Turkish carriers within its scope.

Do all three systems use a 3-hour delay threshold?

For fixed delay compensation, EU261 generally uses a 3-hour-or-more delay at final destination, UK guidance uses more than 3 hours, and Türkiye's December 2024 SHY-YOLCU amendment added compensation duties for certain technical or operational delays reaching the planned final destination 3 hours or more late.

How much compensation can each system pay?

EU261 commonly uses €250, €400 and €600 distance bands. UK261 commonly uses £220, £350 and up to £520. SHY-YOLCU provides €100 equivalent for domestic flights and €250, €400 and €600 bands for international flights when its compensation provision applies. Reductions and exceptions can apply.

Can I receive compensation under two systems for the same flight?

Do not assume duplicate recovery is available. A flight can have facts connecting it to more than one passenger-rights framework, but the interaction between legal rights, prior benefits and compensation needs to be assessed for the specific claim.

Did EU261 change in 2026?

EU institutions completed the legislative adoption process for updated air passenger-rights rules in August 2026. The new framework preserves core three-hour delay compensation and the €250, €400 and €600 bands while adding procedural and other changes, but a preparation period applies before implementation. Current claims should be checked against the rules applicable to the flight date and disruption.

Not sure whether EU261, UK261 or Turkish passenger rights apply?

Share your route, operating airline, flight date and disruption details. Airdelay can help check which passenger-rights framework may be relevant and whether your flight may qualify for compensation.

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