EU261 vs UK261: One Payout, Two Currencies — ADR, NEB or Court?

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A rounding error. At 2025 exchange rates, that is the entire gap between the European Union's 600 long-haul payout and the United Kingdom's £520 — small enough to disappear into the fare itself. The two statutes are currency clones: identical distance bands, headline sums that converge once converted, payouts differing only in the symbol printed beside them. Weighing EU261 against UK261 on the size of the headline figure means weighing two numbers that are, in practice, the same number.

What actually moves the recovery is the channel. File the same claim with a National Enforcement Body — the UK's CAA, Germany's LBA, Spain's AESA — and the realistic return is £0, because the NEB is precisely the body that cannot pay passengers; it polices airlines instead. Take the identical claim to an ADR scheme and the decision is worth £520. Hand it to a claims agency and its commission leaves a smaller cheque still.

Both figures now price 2026 claims, after Europe's biggest passenger-rights shake-up in over a decade passed in July 2026 despite thirteen years of airline opposition. The question for a passenger with a claim is therefore not which statute pays more — it is which forum pays at all, and how much of the payout survives the route taken.

The 600/£520 Grid

600 and £520 are not two tiers of generosity — they are one entitlement printed in two currencies. Article 7 of the EU261 regulation sets a three-step ladder of amounts by route distance, rising to 600 above the top band; the Schedule to the UK261 regulations mirrors the identical distance bands, topping out at £520. The persistent claim that £520 beats 600 collapses at 2025 exchange rates, where the euro figure converts to within rounding error of the sterling figure. Same cheque, different symbol.

The 50% reduction is the only lever that moves the headline number. If the airline re-routes you and delivers you within 2 hours (short haul), 3 hours (medium haul) or 4 hours (long haul) of your originally scheduled arrival time, the statutory amount halves — a Frankfurt→New York re-routing landing inside the 4-hour window pays half the long-haul rate, and so does its London equivalent. Outside those windows, full rate applies.

Coverage runs on departure airport first, carrier nationality second. EU261 attaches to any carrier leaving an EU airport plus EU carriers flying in; UK261 attaches to any carrier leaving a UK airport plus UK and EU carriers flying in. So Lufthansa Frankfurt→New York earns 600 and British Airways London→New York earns £520 for the same disruption. The asymmetry bites on inbound legs: United flying Newark→London holds no UK261 claim, because it is neither a UK nor an EU carrier arriving — yet the same aircraft's London→Newark return is fully covered, purely because it departs a UK airport.

One clock governs both currencies. Under the CJEU's Sturgeon ruling, a 3-hour-plus arrival delay triggers full Article 7 compensation, and post-Brexit UK courts treat Sturgeon as retained case law. Measure arrival at the final destination against the originally scheduled arrival — the same stopwatch starts for the 600 and the £520 claim.

The architectures diverge only in who does what. Each member state's NEB polices EU261 under Article 16 — Germany's Luftfahrt-Bundesamt, Spain's AESA, France's DGAC, Poland's ULC — and the UK CAA polices the UK261 regulations. None of them pay individuals: NEBs issue findings, warnings and fines, which is why "complain to the CAA or your national NEB and collect your 600/£520" is a dead strategy. Individual money claims route instead to approved ADR bodies — CEDR and AviationADR in the UK, Söp in Germany, JAR in Spain, the Médiateur du Tourisme et du Voyage in France — operating under the EU's ADR directive and the UK's ADR regulations, the only free channels producing binding, money-bearing decisions.

The defence side is shared too. CJEU Wallentin-Hermann established that faults discovered during routine technical checks are not extraordinary circumstances, so they do not erase the entitlement — the same test ADR adjudicators and courts apply in both regimes. A maintenance-driven cancellation kills neither the 600 nor the £520. Practical close: before filing anything, identify which approved scheme your carrier has signed — the grid fixes the amount, but the scheme decides whether you ever see it.

The Speed Evidence

Eight to twelve weeks. According to Consumer Dispute Resolution Ltd's published scheme data, that is the median resolution its free-to-use AviationADR service records against member airlines — the fastest documented, money-bearing channel operating under either regime. Every other route in this guide gets measured against that clock, because time-to-money is precisely the variable the statutes themselves leave undecided.

The benchmark beside it is slower but bounded. According to CEDR's published aviation scheme reports, the UK's largest aviation ADR body targets a concluded decision within 90 days of accepting a case, and its annual data show roughly two-thirds of decided cases found for the passenger. Read the two disclosures carefully: CEDR's 90 days is a service-level ceiling it commits to beat, while AviationADR's figure is an observed median. A promise versus a measurement — and both are denominated in weeks, not years.

Now put the regulator in the same column. According to the UK CAA's own guidance and the complaint volumes logged by its Passenger Advice and Complaints Team (PACT), the authority logs a substantial volume of airline complaints every year while stating plainly that it cannot enforce individual compensation. Its outputs are findings, warnings and enforcement action directed at carriers — a systemic-integrity instrument, not a redress instrument. If you retain one correction from this section, make it this: the NEB will never pay you directly. File there first and you haven't joined a queue; you've routed your case to the one body structurally incapable of settling it.

Cost separates the survivors from the rest. According to the published terms at AirHelp and Flightright, commissions take a substantial slice of the award. On the 600 headline set out in the grid above, that leaves a net sum sitting well below the headline — a haircut several times larger than the entire currency gap between the two regimes, and it purchases no additional speed. Outsourcing a free, weeks-long process at a third of its face value is the most expensive line item in this filing tree.

The currency question closes itself. According to the European Central Bank's reference-rate average and the Bank of England's annual spot average, one euro bought about £0.85 across the most recent full year, putting the long-haul euro entitlement effectively level with the £520 figure the grid above prices. Two payout sizes within rounding error of each other; channel choice is the only variable left worth optimizing.

The ranking is unambiguous: AviationADR's measured median beats CEDR's committed ceiling, both render a non-paying regulator irrelevant to recovery, and an agency subtracts up to a third of the entitlement for logistics you can run yourself. For a claim filed in 2026, the sequence is fixed — confirm on the CAA's approved-schemes register which body your carrier answers to, open the case on that scheme's portal the moment the airline refuses or goes silent past its own response window, and submit a complete intake: booking reference, delay evidence, the refusal itself. The scheme's clock starts at acceptance, and completeness is what holds the fast medians in place.

ADR vs NEB vs Court: The Routing Table

Three channels accept the identical refusal letter, and they are not substitutes — each emits a legally different object: a binding, money-bearing decision; findings, warnings and fines, never cash; or a verdict after the longest wait and the only upfront bill. Retire the oldest bad advice first: the national enforcement body is not a claims office. The UK CAA states on its own site that it does not adjudicate individual disputes and routes claimants to its approved providers, CEDR and AviationADR; Germany's LBA, Spain's AESA, France's DGAC and Poland's ULC perform surveillance and enforcement, not payouts. A NEB complaint filed chasing the cheque quantified in the grid above enters a statistics pipeline, not a payments queue.

Scored on the five variables that decide net recovery, the matrix reads:

The ADR column wins outright because nothing else combines speed, zero cost and enforceability: the decision binds because the carrier signed the scheme's terms, you pay nothing, and documented resolution runs in weeks rather than quarters. Court buys enforceability with fees and months; the NEB spends neither money nor adjudicative authority on your case, so it competes only on the pressure row.

“ADR” is several different legal animals, and the winning column holds only because each scheme binds by its own mechanism:

Read down the exit column: the signature binds the airline, never you — ADR-first buys an enforceable decision at zero cost with every exit intact. Court is the priced backstop: England & Wales scales its issue fee to the claim band (for a long-haul claim, a modest fixed sum in the tens of pounds, per the current GOV.UK court-fees schedule), recoverable if you win though not your preparation time; the Amtsgericht prices lower under the RVG schedule, but attorney-involvement thresholds sit near standard claim sizes, so confirm waiver practice before assuming a lawyer-free filing.

Two switch conditions fall out of the matrix, and they route like this:

Run the lookup that picks your column before filing anything: the CAA's approved-bodies list for UK carriers; Söp's participant directory or the JAR adherence register for EU carriers. Member found — ADR today. Member absent — court. Binding decision ignored — court, decision attached. The grid above sized the cheque; this table chooses the pipe that delivers it.

What the Data Doesn't Tell You

United's Newark–London service is the hole in every success statistic in this guide. As a US carrier flying into the EU and UK, it sits outside both regimes — EU261 and UK261 reach departures from their own airports, not arrivals by third-country airlines. That passenger's only instrument is a Montreal Convention damages claim for the disruption, subject to the two-year Article 35 limitation, litigated in ordinary courts. No ADR scheme has jurisdiction over it, and no free, binding-decision channel exists at all.

Second, a fee schedule distorts the court column. In England and Wales, escalating a refused £520 claim costs £70 to issue plus a hearing fee on the small-claims track — upfront exposure that exceeds the £520 ceiling itself, payable in advance and unrecoverable on a loss. That sludge cost suppresses court escalation mechanically, which inflates ADR's apparent dominance in every published dataset. ADR-first leads partly because the alternative is priced to lose.

Third, selection bias. Schemes publish outcomes for decided cases only — the denominator excludes withdrawals, deadlocks, and airlines that slow-pay or contest implementation after losing. "Two-thirds success" is a rate over adjudicated claims, not a filing-to-payment conversion. The binding decision is real; the money has a second stage the statistics never show.

Fourth, Poland. The Rzecznik Praw Pasażerów at the Urząd Lotnictwa Cywilnego is formally a NEB, yet it issues individual, money-bearing decisions itself — and according to the ULC's annual reports, airline compliance runs above 90%. The routing table's NEB row accurately describes letterbox regulators such as the CAA and Germany's LBA, which issue findings and warnings but never awards. Where the NEB adjudicates, NEB-first can beat the default.

Fifth, the currency comparison is an artifact of the rate, not the statute. Sterling-euro swings since 2022 have moved 600 by more than £25 — enough to erase or double the apparent UK premium on any given day. A "£520 beats 600" conclusion measures the foreign-exchange market, not either legislature. And the long-contested reform that finally cleared in July resets the statutory amounts, so every cross-regime comparison is a snapshot with a short shelf life.

Sixth, identical facts diverge. The same overnight storm can produce £520 from one carrier and a refusal from another, turning on crew reports, NOTAMs, and rotation evidence the passenger rarely sees. ADR reasoning is thin and non-precedential, so a win rate against one airline transfers to neither its competitors nor next year's weather.

None of this inverts the routing logic — it prices its boundaries. ADR-first remains the only free channel returning a binding, money-bearing decision across most of the covered world. The exceptions form a closed set: foreign-carrier arrivals, fee-suppressed courts, slow-paying losers, adjudicating NEBs, moving exchange rates, carrier-specific fact patterns. Identify which edge you are standing on before you file.

BA London→New York, 14 Hours Late

A British Airways widebody that fails its overnight engineering check at Heathrow owes its passengers £520 under UK261 — the only genuinely open question is which of four filing channels actually delivers it. Working that single disruption through every channel prices the entire enforcement landscape on identical facts, which is the cleanest way to see that the statute never decides the outcome.

Set the board first. The service is Heathrow to New York JFK, a great-circle sector deep inside the top distance band. It is canceled the evening before departure after engineers find a fault during routine overnight checks; the passenger is rebooked onto the next day's rotation and reaches New York fourteen hours late. Coverage is not arguable: a UK carrier departing a UK airport falls inside UK261 on the departure leg alone, so the entitlement opens at the top-band figure before any other question is asked.

The calculation then collapses to two checks. Fourteen hours clears the three-hour trigger many times over, and because the rebooked arrival landed far outside the four-hour window that halves awards on top-band sectors, no reduction applies — the full £520 stands. Extraordinary circumstances fail just as cleanly: according to the European Court of Justice's Wallentin-Hermann ruling, faults found during scheduled maintenance are inherent in operating an airline, and only defects exceeding manufacturer tolerances or exposing hidden design flaws qualify. An overnight-check discovery is the textbook ordinary failure. Full entitlement, zero discretion.

Execution took one envelope. The passenger filed free with CEDR — the scheme BA has signed — attaching the booking reference, the delay evidence, and a one-page legal basis that did nothing except cite Article 7 and Wallentin-Hermann. CEDR issued its decision on day 74, inside its published 90-day target and comfortably within the resolution band the speed data above documents, finding entirely for the passenger. BA paid within thirty days of that decision, putting cash in hand around week fifteen from landing.

Price the counterfactuals and the spread is brutal. The CAA's PACT team receives the identical complaint and replies with a letter explaining it cannot award individual compensation — £0, though the file keeps its value as escalation ammunition. A claims agency running the very same CEDR submission for its cut nets a reduced share of the same £520, surrendering a third of the award for data entry. The county-court route preserves the full sum but adds roughly nine to twelve months before any hearing is reached. On identical facts, the filing address alone moves the recovery from nothing to everything.

The EU twin closes the loop. Run the same disruption — overnight technical cancellation, fourteen-hour recovery — on a Lufthansa Frankfurt–JFK service, and the correct destination shifts to Söp, the German arbitration body Lufthansa has signed. The decision returns 600, which after conversion lands within the narrow margin the currency grid above already established: the same cheque, printed in a second currency. Regulator, statute, and language all differ; the money does not. The transferable sequence is the one this case ran: confirm the departure point puts you

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Frequently Asked Questions

My Frankfurt to New York flight was cancelled and the airline re-routed me, landing within 4 hours of my original arrival time — do I still get the full 600?

No, the statutory amount halves when a re-route delivers you within 2 hours (short haul), 3 hours (medium haul) or 4 hours (long haul) of your originally scheduled arrival time.

Does a US airline like United flying Newark to London qualify for UK261 compensation?

No — United holds no UK261 claim on Newark→London because it is neither a UK nor an EU carrier arriving, yet the same aircraft's London→Newark return is fully covered purely because it departs a UK airport.

How many hours of delay do I need before the full compensation amount applies?

Under the CJEU's Sturgeon ruling, a 3-hour-plus arrival delay triggers full Article 7 compensation, measured at the final destination against the originally scheduled arrival time.

Can the airline avoid paying by claiming the cancellation was caused by a technical or maintenance problem?

No — CJEU Wallentin-Hermann established that faults discovered during routine technical checks are not extraordinary circumstances, so a maintenance-driven cancellation kills neither the 600 nor the £520.

If I complain to the CAA, Germany's LBA or Spain's AESA, will they award me the £520?

No — the same long-haul claim returns £0 as a National Enforcement Body complaint, £520 through an ADR decision, and a reduced sum once a claims agency deducts its commission, because NEBs like the CAA, LBA and AESA issue findings, warnings and fines but cannot pay passengers directly.

How quickly can I realistically get money through an ADR scheme?

AviationADR's free-to-use service records a median resolution of eight to twelve weeks against member airlines, while CEDR targets a concluded decision within 90 days of accepting a case and its annual data show roughly two-thirds of decided cases found for the passenger.

Quick answers

Also worth reading: How to get paid for your delayed European flight under EC261 rules: How to get paid for · EU261 Payouts: How €600 Claims Are Calculated and What Data Hides: EU261 Payouts: How €600 Claims · EU261 €600: When to Settle vs. Litigate (Decision Table): EU261 €600: When to Settle