Extraordinary circumstances: when does the exception really apply?

Airlines use this term far too broadly. Here is exactly what EU law and European courts say.

An airline may refuse EU261 compensation if the delay or cancellation resulted from "extraordinary circumstances" that could not have been avoided even if all reasonable measures had been taken. However, the European Court of Justice has defined this exception narrowly: a technical fault is almost never extraordinary, nor is a strike by the airline's own staff. The burden of proof rests entirely with the airline — not with you. Never simply accept a refusal citing extraordinary circumstances without verifying the evidence.

What does EU261 say exactly?

Article 5(3) of EU Regulation 261/2004 states that an airline is not obliged to pay compensation if it can demonstrate that the cancellation (or delay) was caused by extraordinary circumstances which could not have been avoided even if all reasonable measures had been taken. Two cumulative conditions: the circumstance must be extraordinary, and the airline must have done everything reasonably possible to limit the consequences.

Technical fault: almost never a valid reason

This is the most commonly misused ground for refusal. Airlines routinely state that the flight was delayed due to "a technical defect on the aircraft." The Court of Justice of the EU ruled explicitly in Wallentin-Hermann v Alitalia (C-549/07, 2008) that technical problems inherent to the normal operation of an airline are not extraordinary circumstances.

The reasoning: an airline that operates aircraft must account for the possibility of technical problems. That risk is part of the business risk. Routine maintenance and repair are normal business activities, not exceptional events.

Only in a very limited situation can a technical problem qualify as extraordinary: if it involves a hidden manufacturing defect that could not have been discovered even through normal maintenance. This is a high bar that the airline itself must prove with documentation from the manufacturer.

The Van der Lans ruling (C-257/14, 2015) confirmed this again: an unexpected technical problem that arose during the flight is not an extraordinary circumstance, even if it was unforeseeable.

Strikes: own staff versus external parties

This is a nuanced area. The Court has drawn an important distinction:

  • Strike by own staff (pilots, cabin crew, ground staff employed by the airline): not an extraordinary circumstance if it is a lawful labour action. The airline bears the risk of its own employment relationships.
  • Strike by external parties (air traffic control, airport personnel not employed by the airline): can be an extraordinary circumstance, provided the strike was spontaneous and the airline could not reasonably have anticipated it.

What does count as an extraordinary circumstance?

CircumstanceExtraordinary?Notes
Severe weather (storm, ice, dense fog)YesMust be verifiable via METAR or official report
Volcanic eruption (e.g. Eyjafjallajokull 2010)YesNOTAM from Eurocontrol
Airspace closure by government authorityYesOfficial decision required
Hidden security risk identified by authorityYesE.g. unexpected inspection
Air traffic control (ATC) restrictionsSometimesStructural ATC staff shortages no longer qualify
Spontaneous strike by external airport staffSometimesDepends on foreseeability
Technical fault (standard)NoWallentin-Hermann / Van der Lans
Strike by airline's own staffNoKruis ruling, CJEU 2018
Technical fault on a previous aircraft (cascade)NoCascade delays are an operational business risk

The "cascade" delay: airline remains responsible

Airlines sometimes invoke a "cascade": your flight's delay was caused by a delay to an earlier aircraft, which was in turn delayed by something outside their control. But if that earlier aircraft was delayed by a technical fault or organisational cause, the argument fails. The cascade exception only applies if the origin of the cascade was itself a genuine extraordinary circumstance.

Burden of proof: the airline proves, you evaluate

This is the most practical point: the airline must prove that extraordinary circumstances existed. You do not have to prove anything. When you receive a rejection citing extraordinary circumstances, always ask:

  • What was the exact cause?
  • Which official document (METAR, NOTAM, government report) supports this?
  • What measures did the airline take to limit the consequences?

A vague statement without documentation is not proof. You may resubmit your claim or file a complaint with the national enforcement body if the airline provides no concrete evidence.

Two tests: extraordinary AND unavoidable

Even if the circumstance was extraordinary, the airline must also demonstrate that it took all reasonable measures to avoid the delay or cancellation. Could it have offered rebooking on another flight departing earlier? Could it have deployed a spare aircraft? If the airline failed to use available alternatives, the exception lapses.

Challenge a standard refusal

Most rejections citing extraordinary circumstances are not backed by concrete evidence. You are not obliged to accept a rejection. Always ask for documentation. You can challenge the rejection yourself for free via the ILT (Netherlands). Alternatively, DelayPaid reviews the rejection on your behalf — 25% success fee incl. VAT, no win no fee.

Was your rejection justified?

Use our check tool or send us the refusal letter. We assess whether the stated reason holds up legally.

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