The Civil Aviation Authority (CAA) has launched a formal compliance programme to assess whether UK airlines are meeting their obligations to passengers under UK261 — the domestic assimilated version of EU Regulation 261/2004 that sets compensation and assistance rules for delays, cancellations and denied boarding. Announced on 2 October 2025, the exercise represents the regulator’s most sustained, system-wide review of airlines’ handling of disruption since the post-pandemic return to full schedules, and follows mounting evidence that many travellers remain confused about their rights when journeys go wrong. (CAA)
Why this matters now
Air travel remains a key part of UK economic life — for business, tourism and trade — and passengers expect predictable protections when flights are delayed or cancelled. UK261 creates clear entitlements: financial compensation for long delays or cancellations in many circumstances, and requirements on airlines to provide care (meals, refreshments, overnight accommodation where appropriate) and re-routing or refund options. But passengers repeatedly report inconsistent messaging from airlines, confusing claim processes and long delays in receiving compensation. The CAA’s programme aims to examine whether those statutory obligations are being met in practice and whether passengers are being informed and assisted as the law intended. (CAA)
Scope and objectives of the compliance programme
The CAA has framed the review around a set of concrete objectives: to test whether airlines comply with UK261 operationally; to assess airlines’ communications and the clarity of passenger information during disruption; to evaluate the timeliness and accuracy of compensation payments and care provided; and to identify systemic or recurring areas of non-compliance that could warrant enforcement action or guidance. The programme will gather evidence directly from airlines, analyse complaint data, and draw on passenger questionnaires and surveys. The regulator has also invited members of the public to share their experiences to help shape the findings. (CAA)
Legal and regulatory backdrop
After the UK’s exit from the EU, the UK assimilated EU261 into domestic law (commonly referred to as UK261) so that passengers retained broadly similar protections. But changes in enforcement powers and the post-Brexit legal environment have altered how consumer law is applied. In April 2025 the CAA’s consumer enforcement remit expanded under the DMCC Act 2024, giving the regulator enhanced tools — including the power to seek monetary penalties in court — to pursue breaches of consumer law in aviation. The new compliance programme sits within that updated enforcement context, signalling the CAA’s willingness to use stronger oversight where necessary. (CAA)
What the CAA will examine — practical detail
Practically, the CAA will look end-to-end at the passenger experience during disruption. That means assessing:
• Whether airlines correctly identify events that trigger care and compensation obligations under UK261 and act promptly;
• If communication to passengers (emails, SMS, app alerts, gate announcements, and public information at airports) is clear, timely and accurate about their rights and the options available;
• Whether airlines provide the required care (meals, accommodation, transport) without placing barriers on claiming;
• The speed and fairness of compensation decisions and refunds, including whether airlines apply narrow interpretations of exceptional circumstances to deny claims improperly; and
• Airlines’ complaints handling and record-keeping practices, since robust records are essential to both compliance and the CAA’s ability to investigate. (CAA)
Passenger confusion and communication failures
Independent surveys and CAA research in 2025 have repeatedly highlighted that a large majority of passengers — in some surveys as many as nine in ten — do not fully understand their rights during a disruption. Common problems flagged include inconsistent use of terminology (for example, “flight cancellation” vs “flight delayed”), lack of proactive explanation of compensation entitlements, and difficulties completing online claim forms. The CAA has therefore said it will place particular emphasis on the quality of airlines’ messaging and whether airlines make it easy for passengers to find and exercise their rights. (AGN)
Early signals: enforcement is on the table
The compliance programme is not just a paper exercise. The CAA’s expanded enforcement toolkit means it can escalate from guidance and improvement notices to monetary penalties if it uncovers systemic breaches. Past CAA enforcement activity — including prosecutions and fines for distinct types of aviation misconduct — shows the regulator is prepared to act where consumer protections are not respected. The message to carriers is clear: transparency, prompt care, and fair compensation must be embedded in operating practices or risk regulatory action. (CAA)
How airlines are likely to respond
Airline groups are expected to cooperate — but the review will expose operational pressures and resource constraints that have shaped recent practice. Since the pandemic, airlines have faced severe staffing challenges in ground operations, call centres and IT systems; these pressures can cause lapses in customer service and record-keeping. Some carriers have invested heavily in automation and apps to speed refunds and communications, while others still rely on manual processes that create delay. The CAA’s programme could push lagging carriers to upgrade systems and procedures, and to clarify policy language that feeds inconsistent passenger outcomes. (Travel Weekly)
Case studies and likely findings (illustrative)
While the CAA has not published results yet, the types of issues it will likely spotlight are predictable from complaint trends:
• Denied claims where airlines cite “extraordinary circumstances” without adequate evidence: regulators often find narrow interpretations of the exceptions that deny otherwise eligible passengers.
• Slow refunds for cancelled flights, particularly where bookings were made through third-party agents and the airline’s reimbursement processes are invoked only after the agent’s own delays.
• Poor on-the-ground care: passengers stranded overnight but unable to obtain accommodation vouchers promptly, or minimal meal allowances that do not reflect realistic wait times.
• Confusing or buried information on airlines’ websites about how to claim compensation and the evidence required, discouraging passengers from submitting claims.
If the CAA finds these patterns repeated across carriers, its recommendations could include stricter record-keeping requirements, expectations for response times, and clearer guidance on the evidence needed to claim compensation. (CAA)
Impact on passengers and intermediaries
A more assertive CAA that pushes for timely payments and clearer information would benefit travellers, especially those least able to navigate complex claims processes. It may also affect travel agents and third-party claim management firms. Airlines could change contract terms with agents or tighten refunds processes to ensure compliance, and a crackdown could reduce the market for speculative claim firms that operate in a legal grey area. Ultimately, better compliance should reduce complaint volumes to the regulator and free up consumer resources. (CAA)
What airlines can do now
The compliance programme creates a practical checklist for airlines and airports:
• Review and refresh customer communications — ensure UK261 rights are easy to find and explained in plain language across all channels.
• Audit operational decision-making frameworks for disruption to ensure staff consistently apply UK261 criteria.
• Improve record keeping so every disrupted journey has a clear paper trail (or electronic trail) of decisions and passenger communications.
• Speed up reimbursement and compensation processes — even a small improvement in turnaround time dramatically reduces complaints and reputational harm.
• Train frontline staff on passenger rights and empower them to act quickly during disruptions to provide appropriate care. (CAA)
Potential criticisms and challenges
Regulators must balance passenger protection with operational realities. Airlines will argue that some disruption drivers—severe weather, air traffic control decisions, strike action by third parties—are genuinely outside their control and can force quick decisions that are complicated to document under intense pressure. The CAA will need to be careful to distinguish isolated exceptions from systemic refusal to comply. A collaborative approach in the early stages of the programme — combining improvement notices and targeted engagement — may be most effective before the threat of tougher sanctions is deployed. (CAA)
Wider policy context: consumer law and post-Brexit developments
The CAA’s review sits alongside wider UK debates about strengthening consumer protection in aviation. Since 2023 the government has consulted on reforms to improve price transparency and consumer information, and the CAA itself has published responses and guidance on how consumer law applies to aviation. The regulator’s enhanced enforcement remit under the DMCC Act 2024 has given it more teeth to nudge the industry — and this compliance programme can be read as a practical application of that wider policy shift. (GOV.UK)
What to expect next and how the public can engage
The CAA has asked passengers to share experiences and complete a short survey to help it measure real-world outcomes. The regulator will gather data from airlines and complaint records, analyse systemic trends, and publish its findings and recommendations when the programme concludes. Depending on what it finds, the CAA may issue guidance, require remediation plans from specific carriers, or in extreme cases pursue enforcement action. Passengers with relevant experiences are encouraged to respond to the CAA’s call for evidence so the regulator can ground its review in everyday experiences. (CAA)
Case Study 1: Long-Haul Flight Cancellation at Heathrow
In July 2024, a family travelling from London Heathrow to Orlando faced a same-day cancellation due to a technical fault. While the airline quickly rebooked them on a flight 24 hours later, passengers reported that hotel accommodation was offered only after long queues at a customer service desk. Meal vouchers were limited to £8 per person, leaving the family out of pocket. Under UK261, the family was entitled not only to accommodation and reasonable meals but also compensation for a cancellation within the airline’s control. It took the family three months and multiple follow-ups to receive payment.
Comment: The CAA’s compliance checks will likely probe whether such delays in compensation are systemic and whether airlines make passengers aware of their rights proactively, rather than only when pressed.
Case Study 2: Weather-Related Delays at Manchester Airport
In February 2025, Storm Jocelyn grounded flights at Manchester Airport. Hundreds of passengers faced overnight disruption. Because severe weather counts as an “extraordinary circumstance,” airlines were not obliged to pay financial compensation. However, they were required to provide care. Some carriers arranged coaches to local hotels, while others told passengers to “make their own arrangements” and claim later. Many claims were subsequently rejected as “unreasonable expenses.”
Comment: Consumer groups argue that the phrase “reasonable” is too vague and allows airlines to deny claims, undermining confidence in protections. The CAA’s audit may push for clearer standards on what constitutes reasonable care.
Case Study 3: Refund Delays via Online Travel Agents
A business traveller booked a return flight from Glasgow to Amsterdam through an online travel agent. When the flight was cancelled, the airline refunded the agent within 7 days, but the passenger waited over two months for their money. Under UK law, passengers are entitled to refunds within 7 days, regardless of whether they booked directly or via an intermediary. The lack of clarity over accountability created frustration.
Comment: The CAA’s review is expected to explore the role of intermediaries and whether airlines must take greater responsibility for ensuring refunds reach passengers on time.
Case Study 4: Denied Boarding at Gatwick
A solo traveller was denied boarding on an overbooked flight to Barcelona, despite arriving on time at the gate. The airline offered £250 in compensation and a later flight. However, the passenger was initially told they had to “volunteer” for the denied boarding, which would have voided their entitlement. Only after challenging the staff did the traveller receive the compensation mandated by UK261.
Comment: This case highlights the importance of staff training and consistency. The CAA’s checks will likely examine whether frontline staff are properly informed and applying the law fairly.
Comments from Stakeholders
- CAA Spokesperson:
“Our aim is to ensure passengers not only have rights but can actually use them without unnecessary barriers. Too often, the process is unclear, slow, or inconsistent.” - Consumer Advocacy Group (Which?):
“Passengers have been left waiting months for payments they are legally entitled to. Stronger enforcement is essential to restore trust.” - Airline Industry Comment:
One major UK airline noted: “We already comply with UK261 and have invested heavily in digital claim portals. However, extraordinary events such as air traffic control strikes must be fairly recognised as outside our control.” - Passenger Perspective (Survey Response):
“I only found out I could claim compensation by searching online weeks later. The airline never told me at the airport.”
Examples of Best Practice
Not all stories are negative. Some airlines have taken proactive steps:
- Digital Claim Processing: One low-cost carrier now pays valid compensation claims within 10 working days via a dedicated app.
- Proactive Communication: A flag carrier automatically sends disruption alerts and links to claim forms via SMS and email, reducing confusion.
- Airport Support Teams: At Gatwick, one airline stationed extra staff with tablets during peak disruption, allowing passengers to submit claims immediately.
These examples show what effective compliance looks like — fast, transparent, and customer-focused.
Conclusion
The CAA’s compliance checks are not merely bureaucratic; they touch the everyday frustrations and expectations of millions of passengers. Case studies show where airlines fall short — from slow refunds to unclear communication — and where best practices demonstrate that compliance can be efficient and fair. With enhanced enforcement powers, the CAA is well-positioned to drive industry-wide improvements. The ultimate measure of success will be whether future passengers, facing delays or cancellations, find their rights not just written in law but delivered in practice.