Your flight from London to Paris leaves three hours late, or your return from Nice to Manchester is cancelled the evening before departure, and the airline offers a voucher while your hotel night in an airport terminal stretches ahead of you. Since Brexit, that familiar scene sits across two legal systems instead of one: the European Union flight compensation rules still protect you when you fly out of France, while a separate British version of the same rules applies when you fly out of the United Kingdom. Many British travellers living in France, or shuttling between a French home and family in Britain, lose money simply because they claim under the wrong scheme, accept the first refusal letter, or throw away the boarding pass that proves their case. This guide explains, for a British reader, which set of rules covers each France to United Kingdom journey, how much money a delay or a cancellation is worth in euros and in pounds, what care the airline owes you at the airport, how to answer the standard excuse of extraordinary circumstances, and where to complain and where to sue in France when the airline will not pay. Every French legal term is explained as it appears, and every decisive legal statement is tied to the exact official text or published court decision it comes from. Readers dealing with the wider practicalities of arrival in France will also find the arrival formalities guide for British newcomers a useful companion to this page.

I. Was my France to United Kingdom flight covered by the European rules or the British rules, and how much does the airline owe me?

A. Which compensation scheme applies to your flight: EU261 or UK261?

Before Brexit, one single European text governed almost every flight touching France or Britain: Regulation (EC) No 261/2004 of the European Parliament and of the Council of 11 February 2004, usually shortened to EU261. Since the end of the transition period, the United Kingdom has kept that regulation as domestic law, amended by the Air Passenger Rights and Air Travel Organisers’ Licensing (Amendment) (EU Exit) Regulations 2019, recorded on the official statute book at legislation.gov.uk, and the UK Civil Aviation Authority explains on its official site that delay rights are set out in the British version of the rules, commonly called UK261. In practice, therefore, a British traveller faces two sibling regimes with the same architecture and different currencies, and the first question is always which sibling governs your flight.

The European regulation defines its own scope, and its wording still decides every flight connected with France. It covers all passengers departing from an airport in a Member State, and it also covers passengers flying from a third country into a Member State where the airline is a Community carrier and no compensation or assistance was already provided in that third country. The French civil aviation authority confirms this scope on its official passenger-rights page. Three consequences follow for a British reader. First, every flight departing from France, whatever your nationality, whatever the airline, and whatever the destination, falls under the European rules, because France is a Member State. Your Paris to London, Lyon to Bristol or Toulouse to Edinburgh service is an EU261 flight. Second, a flight departing from the United Kingdom, which is now a third country in European Union law, falls under the British UK261 rules instead, and any claim about it is measured in pounds and directed in the first instance through the British enforcement system. Third, the return leg matters independently: a London to Paris flight operated by a European Union carrier can still attract the European rules under paragraph (b), unless compensation and assistance were already given in the third country, which is why you must analyse each leg of a return ticket separately rather than assuming one regime covers the whole journey. The UK Civil Aviation Authority publishes its own parallel guidance for delayed flights under UK261.

Two practical points decide many cases before compensation is even discussed. The regulation applies only to passengers with a confirmed reservation who present themselves for check-in on time, or at the latest forty-five minutes before the published departure time where no time was indicated, and it does not apply to passengers travelling free of charge or at a reduced fare unavailable to the public, although tickets issued under a frequent flyer programme are covered. Keep your booking confirmation therefore, and arrive on time, because a missed check-in deadline hands the airline a complete defence. Then, identify the operating carrier, known in French as the transporteur aérien effectif, meaning the airline that actually operates the aircraft, as opposed to the airline whose code appears on your ticket under a codeshare or the travel agency that sold it. The regulation states that where an operating carrier with no contract with the passenger performs obligations under the regulation, it is legally treated as acting on behalf of the company that sold you the ticket, so your claim is directed at the airline that flew or should have flown the aircraft, even if you booked through a different brand or intermediary.

French domestic law reinforces the evidential value of your ticket. Article L6421-1 of the Code des transports, the French transport code, provides that “Le contrat de transport des passagers est constaté par la délivrance d’un billet, individuel ou collectif”, which means the passenger transport contract is evidenced by the issue of a ticket, individual or collective. The official text is published on Légifrance. Your ticket is therefore not a mere receipt: it is the legal proof of the contract of carriage, and it fixes the destination against which delay is measured, a point the French courts apply strictly, as shown below. Alongside it, article 1103 of the Code civil, the French civil code, states that “Les contrats légalement formés tiennent lieu de loi à ceux qui les ont faits”, meaning agreements lawfully formed stand as law between those who made them, published on Légifrance. The airline cannot rewrite the timetable after the event: the scheduled times on your booking bind it, and departure boards, delay certificates and the actual arrival time are measured against that contractual promise.

The sums at stake differ between the two regimes, which is why identifying the right one changes the value of your claim. Under the European rules, article 7 of the regulation fixes lump-sum compensation by distance: 250 euros for flights of 1,500 kilometres or less, 400 euros for intra-Community flights over 1,500 kilometres and other flights between 1,500 and 3,500 kilometres, and 600 euros beyond that. In practice, a Paris to London flight falls in the lowest band at 250 euros, while longer routes such as Nice to Manchester or Marseille to Edinburgh can reach the middle band at 400 euros, with distances measured by the great circle route method. Under the British rules, the Civil Aviation Authority confirms the sterling equivalents on its official site: 220 pounds per person for flights under 1,500 kilometres, 350 pounds per person for flights between 1,500 and 3,500 kilometres, and for flights over 3,500 kilometres 260 pounds where you arrive between three and four hours late and 520 pounds where you arrive more than four hours late. These are fixed sums per passenger, payable in cash, by bank transfer or by cheque, and only in travel vouchers if you sign an agreement accepting vouchers, so you are never obliged to accept miles or credit notes instead of money. Children pay the same per-person sums, which means a family of four delayed overnight on a Paris to London service carries a European claim worth 1,000 euros in fixed compensation alone, before any additional damages.

B. How much money for a delay or a cancellation, and what care is owed to you at the airport?

A delay gives a right to the fixed compensation once it reaches a legal threshold measured at arrival, not at departure. The decisive question is therefore not how late the aircraft left the gate but how late you reached your final destination, known in French as the destination finale, compared with the scheduled arrival time. The French Court of Cassation, the Cour de cassation, which is the supreme court for civil matters in France, confirmed the rule in a published decision of its First Civil Chamber: “les passagers de vols retardés bénéficient du droit à indemnisation prévu à l’article 7 de ce règlement lorsqu’ils atteignent leur destination finale trois heures ou plus après l’heure d’arrivée initialement prévue par le transporteur aérien (CJCE, 19 novembre 2009, Sturgeon e.a., C-402/07 et C-432/07).” In plain terms, passengers on delayed flights benefit from the compensation right provided for in article 7 of the regulation when they reach their final destination three hours or more after the arrival time initially scheduled by the air carrier. That holding comes from the decision Cass. 1re civ., 23 September 2026, No 25-14.563, a rejection of an appeal by a passenger against Air France, and it expressly adopts the European Court of Justice Sturgeon case law that equates a delay of three hours or more on arrival with a cancellation for compensation purposes. For your London to Paris or Paris to London flight, the arithmetic is therefore simple: scheduled arrival 18:00, actual arrival at the destination airport 21:00 or later, and the fixed sum is due unless the airline proves a valid defence.

The same decision defines precisely what counts as the destination, and the answer protects passengers diverted to another airport. In an earlier published ruling the Court of Cassation held that “peut bénéficier de l’indemnisation prévue à l’article 7 le passager d’un vol qui a atteint sa destination finale avec un retard de trois heures ou plus par rapport à l’heure prévue initialement et cette destination finale est définie comme étant celle figurant sur le billet présenté au comptoir d’enregistrement ou, dans le cas des vols avec correspondance, la destination du dernier vol.” That means a passenger may benefit from the article 7 compensation where he reaches his final destination three hours or more late against the initially scheduled time, and the final destination is defined as the one shown on the ticket presented at the check-in desk or, for connecting flights, the destination of the last flight. The ruling is Cass. 1re civ., 17 February 2021, No 19-21.362, given on an appeal by a passenger against the airline Vueling, whose Milan to Paris flight had been diverted from Orly airport to Roissy Charles de Gaulle airport because of the night curfew at Orly. The practical lesson for a British traveller is direct: if your booked Paris airport is Orly and the airline lands you at Charles de Gaulle, or your booked London airport is Heathrow and you are bussed in from Gatwick, the delay is measured against arrival at the airport named on your ticket, and the regulation adds that where the airline offers a flight to an alternative airport, it must bear the cost of transferring you to the airport for which the booking was made or to another nearby destination agreed with you. For connecting journeys, which many British travellers use when flying from regional France via Paris or Amsterdam to the United Kingdom, the three hours are assessed at the final airport of the whole journey, so a short first leg that causes a missed connection and a late evening arrival at the final destination opens the full compensation even though the first flight itself was only slightly late.

Cancellation follows its own scale, and the airline escapes compensation only if it warned you early enough or rerouted you tightly. The regulation provides that passengers have the right to compensation for a cancelled flight unless they were informed of the cancellation at least two weeks before the scheduled departure, or were informed between two weeks and seven days before departure and offered rerouting allowing them to depart no more than two hours before schedule and reach their final destination less than four hours after schedule, or were informed less than seven days before departure and offered rerouting allowing them to depart no more than one hour before schedule and reach their final destination less than two hours after schedule. A cancellation announced the night before, with rerouting the next day, therefore keeps your compensation intact in the ordinary case. Where the airline does reroute you and you arrive with only a short delay, the fixed sum may be cut by half: the regulation allows the carrier to reduce compensation by fifty per cent where the delay on arrival stays below two hours for short flights, below three hours for medium flights, or below four hours for long flights. Check the arrival time on the rerouting before accepting that the airline owes nothing: a reduction is not an extinction, and many refusal letters blur the two.

Alongside money, the airline owes you care while you wait, known in French under the umbrella of assistance, and these duties apply regardless of the reason for the disruption, including extraordinary circumstances. Article 9 of the regulation provides that passengers must be offered free of charge meals and refreshments in a reasonable relation to the waiting time, hotel accommodation where a stay of one or more nights becomes necessary or an additional stay becomes necessary, transport between the airport and the place of accommodation, and in addition two telephone calls, telex or fax messages, or emails free of charge. Article 8 adds the choice between reimbursement within seven days of the full cost of the ticket for the parts of the journey not made, together with a return flight to the first point of departure where relevant, or rerouting to the final destination at the earliest opportunity, or rerouting at a later date at your convenience subject to seat availability. If the airline fails to provide meals or a hotel and you pay yourself, keep every receipt: reasonable costs you advanced because the carrier defaulted on its duty of care are recoverable on top of the fixed compensation, and judges routinely award them where the receipts are coherent with the waiting time. Photograph the departure board showing the delay, keep boarding passes, baggage labels, booking confirmations, card statements and hotel invoices together in one file from the evening itself, because eighteen months later, when the claim reaches a court, that file is your case.

II. How do I make the airline pay, and how do I challenge a refusal?

A. How to claim, and how to answer the airline that pleads extraordinary circumstances?

Compensation is never automatic, on either side of the Channel. The UK Civil Aviation Authority states the procedure bluntly: you must claim compensation from the airline yourself; it is never paid automatically. The French system works the same way, and the order of steps matters because each later remedy asks what you did before. Write first to the operating carrier, meaning the airline that actually operated the flight, within days of the disruption while the details are fresh. Your letter states the flight number and date, the booking reference, the scheduled and actual arrival times, the number of passengers, the fixed sum claimed with its legal basis, and the reimbursement of any care costs with receipts attached. Send it by a traceable channel, email with acknowledgement or registered letter, and keep a copy, because proof of the complaint and of its date starts every clock that follows. Give the airline a clear deadline of about six weeks, and diary it: silence or a standard refusal at that point opens the administrative and judicial routes without weakening your position.

When the airline answers, its letter will very often invoke extraordinary circumstances, known in French as circonstances extraordinaires, and this is where most passengers abandon valid claims. The regulation provides that an operating carrier is not obliged to pay compensation if it can prove that the cancellation or long delay was caused by extraordinary circumstances which could not have been avoided even if all reasonable measures had been taken. The decisive words are “if it can prove”: the burden of proof lies on the airline, not on you. The Court of Cassation recalled the principle in the Vueling decision cited above, holding that “il incombe au transporteur aérien de démontrer qu’il s’est acquitté de ses obligations”, meaning it is for the air carrier to demonstrate that it discharged its obligations, applying article 1353 of the Civil Code alongside the regulation. That article of the Civil Code states the general rule of evidence in French law: “Celui qui réclame l’exécution d’une obligation doit la prouver. Réciproquement, celui qui se prétend libéré doit justifier le paiement ou le fait qui a produit l’extinction de son obligation.” Whoever claims performance of an obligation must prove it, and whoever claims to be discharged must prove payment or the fact that extinguished the obligation. The official texts are published on Légifrance for article 1353 and on the Cour de cassation website for the full Vueling ruling. A refusal letter that merely asserts bad weather, a technical problem or an air traffic decision, without dated documents proving both the event and the unavoidable character despite all reasonable measures, does not satisfy that burden, and a French judge will say so.

The content of the defence is then examined strictly, because the courts define extraordinary circumstances narrowly and cumulatively. The 2026 Air France decision sets out the current test in these terms: a long delay gives no right to compensation only where the carrier proves it results from extraordinary circumstances, and those circumstances are defined as events which by their nature or origin are not inherent in the normal exercise of the activity of the carrier concerned and which escape its effective control, “ces deux conditions étant cumulatives et devant faire l’objet d’une appréciation au cas par cas”, meaning both conditions are cumulative and must be assessed case by case, following the Court of Justice TAP Portugal judgments of 11 May 2023. The carrier must further establish that the circumstances could not have been avoided by measures suited to the situation, meeting technically and economically bearable conditions, and that it deployed all the staff, equipment and financial means at its disposal to avoid the long delay. The full reasoning appears in Cass. 1re civ., 23 September 2026, No 25-14.563. Two published illustrations show how the test bites in opposite directions, and both are useful to a British claimant. In the Vueling case, the airline argued that the night curfew at Orly airport, imposed by a ministerial decision prohibiting movements between 23:30 and 06:15, forced the diversion to Charles de Gaulle and constituted an extraordinary circumstance; the Court of Cassation answered that such a permanent regulation could not constitute an extraordinary circumstance, quashed the judgment that had accepted the excuse, and ordered the airline to pay 3,000 euros under article 700 of the Code of Civil Procedure in addition to the costs. A known, permanent operating constraint of the destination airport is therefore the airline’s problem to schedule around, not the passenger’s loss to absorb. In the Air France case, by contrast, the first flight had been delayed because a passenger suffered a medical emergency requiring disembarkation, the claimant missed her connection and arrived more than five hours late at her final destination, and the Court held that “le malaise d’un passager ayant nécessité son débarquement, n’étant pas inhérent à l’exercice normal de l’activité du transporteur aérien et échappant à sa maîtrise effective, peut caractériser pour le transporteur aérien une circonstance extraordinaire”, meaning a passenger’s illness requiring disembarkation, not being inherent in the normal exercise of the carrier’s activity and escaping its effective control, may constitute an extraordinary circumstance for the carrier, so the rejection of the claim was upheld. Read together, the two rulings draw the line judges apply every week: structural and foreseeable operating difficulties stay with the airline, while a genuine external event escaping its control, proved with documents and accompanied by proof that the airline did everything reasonable to limit the delay, can release it.

Measure your own file against that line before writing back to the airline. A technical breakdown of the aircraft, a late incoming aircraft caused by the airline’s own rotation, a crew shortage, or a strike by the airline’s own staff are routinely rejected as extraordinary, because they are inherent in operating an airline; a medical emergency on board, severe weather closing the airport, or a proven air traffic control ban can qualify, but only with dated evidence and proof of mitigation such as rerouting you at the earliest opportunity. Answer a refusal point by point: ask for the exact event with its date and time, the documents proving it, the reasonable measures taken, and the rerouting offered, and set a final deadline before escalation. Keep your own evidence symmetrical: the booking, the boarding pass, a photograph of the departure board, the airline’s delay certificate or its refusal to issue one, meal and hotel receipts, and any written rerouting proposal. Where the airline offers vouchers, remember they require your signed agreement, so an unsolicited voucher sent by post settles nothing and does not stop the clock.

If the airline maintains its refusal, France gives you an administrative lever before the courts: the report to the national enforcement body. Each European Union Member State designates a national body responsible for the general application of the regulation, and the body designated by France is the Direction générale de l’aviation civile, the DGAC, the French civil aviation authority, competent for flights departing from an airport in France whatever the destination and the nationality of the carrier, as well as flights to those airports coming from a country outside the European Union. The official procedure is published by the Ministry for Ecological Transition on ecologie.gouv.fr. The order is strict: reporting to the DGAC is pointless unless you have already complained to the carrier and waited at least two months for its reply. File the report online through the dedicated portal at droits-passagers-aeriens.aviation-civile.gouv.fr, whose existence is confirmed on the official service-public.fr information page, or by post to the air passengers office of the DGAC air transport directorate at 50 rue Henry Farman, 75720 Paris Cedex 15. Understand what the report does and does not do: in cases of proven breaches, administrative fines may be imposed on carriers that disregard the regulation, where breaches are established, administrative fines can be imposed on airlines that disregard the regulation, yet the DGAC’s action is separate from the resolution of individual compensation and reimbursement claims against carriers, for which passengers must apply to the competent court. The DGAC report therefore punishes and deters, and it creates an official trace of your dispute, but the money itself is recovered from the airline, by agreement or by judgment.

Between the administrative report and the courtroom sits consumer mediation, known in French as médiation de la consommation, an amicable procedure in which an independent mediator proposes a solution to the dispute between you and the airline. Article L612-1 of the Code de la consommation, the French consumer code, gives every consumer the right to refer a dispute with a trader to a consumer mediator for amicable resolution, and obliges the trader to guarantee effective access to such a scheme, with the official text published on Légifrance. Airlines operating in France must designate a mediator, and for air travel the sector mediator most often competent is the Tourism and Travel Mediator, the Médiateur Tourisme et Voyage. Mediation suspends the limitation clock while it runs, costs you nothing beyond postage, and produces a reasoned proposal that airlines follow in a large share of cases because a refusal looks poor before a judge. It is particularly suited to mid-value family claims of 1,000 to 2,400 euros where court proceedings feel disproportionate but surrender feels wrong. If mediation fails or the airline ignores it, every document exchanged becomes exhibit material for the court, so draft your mediation statement as carefully as a claim form.

B. Which court and which deadline apply if the airline still refuses to pay?

The court with general jurisdiction over a compensation claim against an airline in France is the tribunal judiciaire, the judicial court that hears civil and commercial cases. Article L211-3 of the Code de l’organisation judiciaire, the code governing the court system, provides that “Le tribunal judiciaire connaît de toutes les affaires civiles et commerciales pour lesquelles compétence n’est pas attribuée, en raison de la nature de la demande, à une autre juridiction”, meaning the judicial court hears all civil and commercial cases not assigned by their nature to another court, with the official text on Légifrance. For a British resident in Paris or the Ile-de-France region, which is the Paris region surrounding the capital, the claim is brought before the Paris judicial court, whose territorial jurisdiction covers disputes arising from flights departing from the Paris airports; elsewhere, the court of the place of departure or of the claimant’s domicile may be seised according to the ordinary rules of territorial jurisdiction, and the court registry will redirect a claim filed at the wrong venue rather than punish the error. File a clear, short claim form attaching the exhibits in chronological order: booking, boarding pass, proof of scheduled and actual times, complaint letter and its date, refusal letter, receipts, and where relevant the mediation opinion. Ask for the fixed compensation per passenger, the reimbursement of care costs with receipts, and interest from the date of formal notice, and keep the originals of everything.

Time limits favour claimants who act within months but punish those who sleep on their rights, so calendar the deadline on the day of the flight. An action for the fixed compensation is a personal or movable action, known in French as an action personnelle ou mobilière, and article 2224 of the Civil Code provides that “Les actions personnelles ou mobilières se prescrivent par cinq ans à compter du jour où le titulaire d’un droit a connu ou aurait dû connaître les faits lui permettant de l’exercer”, meaning personal or movable actions are time-barred after five years from the day the holder of a right knew or should have known the facts enabling him to exercise it, published on Légifrance. You therefore have five years from the disrupted flight to sue in France, and a complaint, a DGAC report or mediation proceedings do not by themselves stop that clock unless the specific mechanism provides for suspension, which mediation does and a simple letter does not. Do not confuse that five-year period with shorter periods found in international air law conventions or in other countries’ domestic rules: a British traveller suing in France benefits from the French five-year period for the European fixed compensation, and invoking it expressly in the claim form prevents the airline from quietly substituting a shorter foreign period. Conversely, do not wait four years and eleven months: exhibits fade, airlines merge or restructure, and a claim filed in the first year settles far more often than one filed in the fifth.

Beyond the fixed sum, French contract law allows the judge to top up compensation where the proven loss exceeds the lump sum. Article 1231-1 of the Civil Code provides that “Le débiteur est condamné, s’il y a lieu, au paiement de dommages et intérêts soit à raison de l’inexécution de l’obligation, soit à raison du retard dans l’exécution, s’il ne justifie pas que l’exécution a été empêchée par la force majeure”, meaning the debtor is ordered, where appropriate, to pay damages for non-performance or for delay in performance unless he shows performance was prevented by force majeure, the French doctrine of irresistible and unforeseeable external events, with the official text on Légifrance. A missed prepaid hotel night, a forfeited connecting ticket bought separately, a day of lost earnings documented by an employer, or the cost of essential items bought when luggage was delayed can be claimed as additional damages alongside the fixed sum, provided each head of loss is proved by documents and causally linked to the disruption. Judges reduce exaggerated or undocumented extras without hesitation, so claim the real loss with receipts rather than an inflated global figure. Where the airline’s conduct was particularly careless, for example ignoring a known curfew constraint of the kind condemned in the Vueling ruling while selling tickets on an unworkable schedule, invite the court to draw the consequences rather than asking for a punitive sum French civil law does not provide: French courts compensate loss, they do not punish, and a measured claim succeeds where an angry one fails.

For British claimants living in France, two cross-border wrinkles deserve attention before filing. First, after Brexit a French judgment against an airline must be enforced under the ordinary rules for foreign judgments in the airline’s home country rather than under the former intra-European Union automatic circulation, which in practice matters little where the airline operates aircraft, offices or bank accounts in France against which enforcement can proceed directly, but matters more against a small carrier with no French assets. Second, where the dispute concerns a flight departing from the United Kingdom under UK261 rather than a flight departing from France, consider whether the British route is more practical: the Civil Aviation Authority and approved alternative dispute resolution bodies in the United Kingdom handle UK261 complaints without charge to the passenger, and county court money claims can be filed online, although any proceedings in England will apply the British version of the rules and its sterling scale. The choice of forum is a tactical decision turning on language, evidence location and the airline’s assets, and it should be made once, at the start, because parallel proceedings in two countries over the same flight waste costs and risk contradictory outcomes.

Conclusion

A delayed or cancelled flight between France and the United Kingdom now sits at the junction of two sibling compensation systems, and the traveller who identifies the right one, counts the right hours, and keeps the right papers recovers money that many passengers abandon. Flights leaving France carry the European scale of 250, 400 or 600 euros per passenger with a three-hour arrival threshold confirmed by the Court of Cassation; flights leaving Britain carry the British scale in pounds under UK261 with the same architecture; care at the airport is due in both cases whatever the cause; extraordinary circumstances are a narrow, documented, case-by-case defence on which the airline bears the full burden of proof; and the path from complaint to DGAC report to mediation to the judicial court gives every refusal at least three further lives within a five-year horizon. Apply that sequence to your own file, starting tonight with the boarding pass still in your jacket pocket, and the regulation will do the rest of the work it was written to do.