Insider

💶 Airlines owe €3.2B in delay payouts. How much belongs to your travellers?

The EU's new air passenger rights law takes effect today. Compensation stays at €250–600, but the time to claim shrinks to nine months. Your policy should say who claims, who keeps the money, and where refunds go.

Egor Karpovich

22 Oct 2026 — 5 min read

This week

The EU's new air passenger rights law takes effect today, 22 October. Regulation (EU) 2026/2202 is the first big rewrite of the 2004 "EU261" rules. It was published on 2 October and enters into force today. Most of the new rules apply from 23 October 2027. The headline numbers stay the same: a flight that arrives three hours late or more still pays €250, €400 or €600, depending on distance. What changes is the process. Passengers will have nine months to claim, and airlines will have 30 days to pay or explain why they won't. Today, very few claim. The European consumer group BEUC says only 38% of eligible passengers use their rights, and only 22% end up getting paid. It estimates airlines are holding around €3.2 billion in unpaid delay compensation. Your travellers fly more than most passengers, so some of that money is probably theirs. Does your travel policy say who claims it, and who keeps it?

Why it matters

1. The money goes to the passenger, not to the company that bought the ticket. EU261 gives the right to compensation to the person on the plane. Unless your employment terms or travel policy say otherwise, a consultant who sits through a five-hour delay on a ticket you paid for can keep the €600, or never claim it at all. Neither is wrong. Not having decided is the problem.

2. The time to claim is getting much shorter. EU261 has never set a deadline for claims, so each country's civil law decides. In Germany, for example, a claim can be brought until the end of the third year after the flight. Once the new rules apply, passengers will generally have nine months from departure. A programme that relies on someone "going through last year's delays" later will lose money.

3. Refunds will be automatic, but it's not clear where they will land. Passengers who choose a refund after a cancellation must get it automatically within seven days, including any fees charged by the agent who sold the ticket. Lawyers at Burges Salmon note it "remains to be seen" how this will work for bookings made through intermediaries. If you book through a travel agency or a booking platform, the refund could go back to the company, the agency or the traveller's own card.

What this means for your program

Decide who keeps the compensation, and write it down. The usual options: the traveller keeps it (for the lost evening), the company claims it back (it paid for the ticket), or a fixed split. Agree the rule with HR and legal, put it in the travel policy, and tell travellers before their next trip, not after their next delay.
Treat a delay of three hours or more as a claim, not just a bad day. Ask travellers to report any arrival that is three hours late or more, with the flight number and the reason the airline gave. Under the new rules airlines will have to tell passengers within four days how to claim, so keep those emails.
Ask your travel agency where refunds will go. You need a written answer on how a cancelled company-paid ticket is refunded, including the agency's own fee, and how fast. The new rule says seven days. Get your provider's process in writing before October 2027.
Avoid booking tight connections. A missed connection is how a two-hour delay turns into a lost day. Compensation helps afterwards; a realistic transfer time stops it happening.

The numbers

2 October / 22 October / 23 October 2027: Regulation (EU) 2026/2202 was published in the Official Journal on 2 October, enters into force on 22 October 2026, and its main provisions apply from 23 October 2027. (Burges Salmon, 8 Oct 2026)
646 votes to 12: the European Parliament's final vote on the reform on 7 July. Compensation stays at €250 (up to 1,500 km), €400 (intra-EU over 1,500 km and other flights of 1,500–3,500 km) and €600 (longer flights). Airlines may halve it on the longest flights if the delay on arrival is no more than four hours. (The Sofia Globe, 7 Jul 2026)
9 months and 30 days: passengers will have nine months to file a claim, and airlines 30 days to pay it or cite extraordinary circumstances. (The Sofia Globe, 7 Jul 2026)
38% claim, 22% get paid, around €3.2B unpaid: BEUC figures on how many eligible passengers use their rights, and an estimate of the delay compensation airlines haven't paid. (Euronews, 21 Jul 2026)
7 days and up to 400%: refunds must be paid automatically within seven days, including intermediary fees. If an airline doesn't offer comparable rerouting within three hours of a cancellation, passengers can book their own and recover up to 400% of the original ticket price. (Burges Salmon, 8 Oct 2026)

Two tools built exactly for this moment

A disrupted trip leaves a trail of money behind it: a refund, a rebooked ticket, a hotel night, sometimes a €600 compensation payment. You want each one recorded against the right trip, so nothing gets paid twice or lost.

Travel Code Expense Management →: receipt capture, automatic checks against your policy, and approval routing, with bookings and card transactions reconciled in one ledger. Disruption costs and refunds sit next to the original trip, so you can see what delays really cost you. Everything exports to Excel.
Travel Code Net-60 Card →: 60-day settlement at 0% interest, per-transaction visibility, and budget rules that auto-freeze at 80%. When a traveller rebooks on the spot, the cost goes on a card you control, and you see it line by line the same day.

The bottom line

The new law doesn't change how much an airline owes. It changes how quickly passengers have to ask, and it makes refunds automatic. For a company, that leaves three questions to answer in writing: who claims, who keeps the money, and where refunds go. A year from now the nine-month clock starts. Programmes that have answered these questions will get their money back. The rest will add to that €3.2 billion.

What's new at Travel Code

Did you know Travel Code flags short connections in flight search? Flight results show a "Short Connection" badge on itineraries with tight transfer times, so travellers and approvers can see the risk before booking, not at the gate. If there are no direct flights, search suggests two next steps: look at itineraries with stopovers, or change the dates. (Changelog →)

Sources

Travel Code helps corporate travel and finance teams see, control, and reconcile every dollar of trip spend in one platform. travel-code.com · Expense Management · Net-60 Card