Flight Delay Compensation in Turkey: The Three-Hour Rule and SHGM Claims

Flight delay compensation Turkey: when does a delay qualify?

For a flight within the Turkish SHY-YOLCU framework, Article 7(3) addresses technical or operational delay resulting in arrival at the planned final destination three hours or more late. The provision refers to the compensation and reimbursement or rerouting obligations in Articles 8 and 9. It is not a rule that every late departure automatically earns the maximum payment. Route, operating carrier, actual arrival delay, cause and applicable conditions must be examined.

The consolidated Turkish regulation includes the amendment published on 10 December 2024. An old discussion saying that Turkish passenger rules never provide compensation for delayed flights should not be used to assess a later flight without checking the amended text. This guide explains the claim process in English; the governing regulation is Turkish. Our English legal services homepage explains our Mersin-based legal work across Turkey.

What do SHY-YOLCU, SHGM and the complaint form mean?

SHY-YOLCU is the common short name used for Turkey’s Regulation on the Rights of Passengers Travelling by Air. English searches sometimes shorten this further to “SHY regulation” or “SHY passenger regulation,” but the controlling instrument is the current Turkish text and its amendments. SHGM is the Directorate General of Civil Aviation, the Turkish aviation authority that publishes passenger guidance and operates the administrative complaint channel.

The terms should not be treated as interchangeable. The regulation supplies the legal framework; the operating airline is normally the first recipient of a fact-specific compensation request; and the SHGM complaint form is an administrative escalation channel when the airline response does not resolve a covered passenger-rights issue. Filing a form is not the same as receiving a court judgment or an immediately enforceable payment order.

Practical SHGM complaint-form sequence

1. Send a written application to the operating carrier and save the submission confirmation.
2. Wait for and preserve the carrier’s answer, or keep proof that the response period shown in the current official guidance expired.
3. Use the official SHGM passenger-rights application page; foreign passengers should follow the registration route displayed there.
4. Upload the ticket or booking, boarding documents, delay and arrival evidence, airline correspondence and a concise chronology.
5. Describe the unresolved regulatory issue precisely. Do not submit passwords, altered screenshots or unrelated identity material to unofficial websites.

Portal wording and required fields can change. Check the live official page on the filing date and retain the application number and a PDF or screenshot of the final submission. If the dispute concerns baggage, a voluntary cancellation or only a ticket seller’s conduct, first verify whether the selected SHGM category actually covers it.

Three different questions after a delay

1. Check the route, operating airline and passenger conditions

Article 2 of the consolidated SHY-YOLCU regulation covers the specified flights of Turkish carriers to and from airports in Turkey and flights of foreign carriers departing from airports in Turkey. A foreign carrier’s flight from another country is not brought within this territorial rule merely because the passenger later plans to visit Turkey.

Identify the airline that actually operated or was to operate the flight. A booking website, ticket seller and marketing airline can be different from the operating carrier. Save the itinerary showing any “operated by” information and the flight number used on the boarding pass. This avoids directing the operational claim only to an intermediary that did not perform the flight.

The regulation also specifies reservation and check-in conditions. Keep evidence of the confirmed booking and compliance with the applicable check-in instructions. A passenger who arrived after the required time presents a different factual issue from someone who checked in and then waited because the aircraft was delayed.

Other legal regimes can require separate assessment for an international itinerary. Do not assume that Turkish rules and European or other foreign passenger rules are identical simply because some compensation figures resemble one another. Explain every relevant flight leg and any payment already obtained when asking for advice.

2. Separate late departure from delay at the final destination

The amended Article 7(3) focuses on the planned final destination and a delay of three hours or more there. A departure board showing a three-hour delay is important evidence, but it does not by itself settle the actual final arrival calculation. An aircraft can recover time, or an initial delay can cause a missed connection and a much later final arrival.

Record the original scheduled departure and arrival, actual flight details and any replacement itinerary. Keep local time zones explicit. Comparing a departure time in Turkey with an arrival time printed in another time zone without adjustment creates avoidable arithmetic errors.

For connecting travel, preserve the complete booking and ticket structure. A single protected itinerary and independently purchased flights should not be assumed to have the same legal treatment. The definition of final destination and the relevant contractual connection need to be applied to the documents, not inferred from a traveller’s personal plan.

Do not alter screenshots to make a delay appear longer. Keep the original notifications, boarding documents and contemporaneous records. Where different sources show different arrival information, identify the discrepancy and obtain the appropriate operational record rather than selecting whichever number produces the largest claim.

3. Ask the airline to identify the reason for the delay

The three-hour provision addresses technical and operational causes. The airline’s explanation therefore matters. Ask for a written statement identifying the reason connected with the specific flight rather than relying only on an airport announcement that nobody recorded.

A label such as “operational reasons” is not a complete factual chronology. Record when the explanation was given, whether it changed and what replacement arrangements followed. Conversely, a passenger should not assume that every disruption described as technical necessarily resolves all questions about the applicable obligation without examining the circumstances.

Weather, air-traffic restrictions, security events and other asserted causes require examination in the relevant framework. A disagreement about compensation should not be confused with the separate question of assistance owed during the wait. Different rights can have different conditions.

Keep the account factual. A passenger normally cannot establish the aircraft’s maintenance history from a photograph at the gate. Photographs and staff messages can support the chronology, but they should not be presented as a technical expert conclusion. Request the material explanation and challenge an inadequate answer through the appropriate process.

4. Understand the compensation bands and currency rule

Where Article 8 compensation is due, the regulation sets EUR 100 for domestic flights. International bands are EUR 250 for flights up to 1,500 kilometres, EUR 400 for the intermediate band up to 3,500 kilometres, and EUR 600 for longer flights. The applicable distance and any legally permitted reduction must still be checked.

The current Article 8 specifies the Central Bank of the Republic of Türkiye’s foreign-exchange selling rate on the payment date when determining the Turkish-lira equivalent. Do not calculate a binding lira amount from an old screenshot of an exchange rate or assume that the ticket-purchase rate controls this compensation conversion.

Article 8 also addresses a fifty-percent reduction in specified rerouting circumstances. A careful calculation identifies the relevant rule and proposed alternative journey rather than quoting the highest band as an unconditional amount payable to every passenger.

Compensation, ticket reimbursement and documented expenses are separate entries. A low ticket price does not itself establish that fixed compensation is unavailable, while an expensive ticket does not automatically increase the fixed band. Prepare the legal basis for each amount and disclose payments already received so that the same loss is not counted twice.

5. Request practical assistance while the disruption is happening

Articles 7 and 10 address assistance, using the applicable distance and expected delay thresholds. The framework distinguishes the shorter-flight and domestic threshold from the longer international bands and addresses refreshments, communication and, where required, accommodation and transfers.

Ask the airline or its authorised ground-handling representative what assistance is being arranged. Keep any voucher, hotel allocation, transfer instructions or written refusal. A contemporaneous record is more useful than trying to reconstruct the entire overnight disruption after returning home.

Where necessary services are not provided, preserve reasonable receipts and explain why the expense was incurred. Separate food, accommodation and necessary transport from unrelated shopping or a voluntarily chosen luxury upgrade. A receipt proves an expenditure; it does not alone establish that every part of it is legally recoverable.

Passengers with reduced mobility, accompanying persons and unaccompanied children receive specific attention in the regulation. Communicate practical needs promptly and record the assistance requested. Do not delay an urgent safety or medical decision merely to continue collecting claim evidence.

Keep compensation correspondence separate from immediate travel arrangements. A passenger can need help at the airport before the airline has completed its investigation into the reason for the delay. Asking for necessary assistance should not be replaced with an argument solely about the eventual fixed payment.

6. Make an informed choice about reimbursement and rerouting

The regulation provides particular reimbursement and travel options where the relevant provisions apply. Article 7 also refers to the Article 9(1)(a) option when delay reaches at least five hours. The exact choice should be assessed against the journey and whether continuing it still serves its original purpose.

Before accepting a refund, understand whether it ends the airline’s arrangements for the unused journey. Before buying an independent replacement ticket, record what the airline offered and why the available option was not suitable. Do not assume that any replacement purchased at any price will automatically be reimbursed.

Keep the original itinerary and every subsequent booking version. An application is harder to evaluate when the only surviving document is the final replacement boarding pass. Note who changed each reservation and whether the passenger accepted a particular option.

Vouchers require care. Check expiry, eligible routes, transferability, fees and any release language. A voucher with restrictions is not necessarily equivalent to cash in practical value. The regulation addresses signed agreement for specified non-cash forms; do not accept a document in an unfamiliar language without understanding the choice being made.

7. Build a compact evidence file

If your suitcase also arrived late or damaged, keep a separate baggage record. Our guide to lost, delayed and damaged baggage explains the different written-complaint periods and the Montreal Convention liability framework.

The useful core is the passenger’s booking, ticket, boarding pass, original schedule, changed itinerary, delay notifications and the airline’s explanation. Add the claim submitted to the airline, its acknowledgement and response. Keep identity documents secure and disclose only what the official process requires.

For a family booking, identify each passenger and their ticket information. Payment by one person does not make every other passenger’s identity irrelevant. A representative must have the required authority for the people whose claims are advanced, with appropriate arrangements where children are involved.

Use a chronological index. Label an email by its date and subject rather than by an emotional description. Preserve original messages as well as readable copies. A concise chronology allows a reviewer to distinguish scheduled travel, actual travel, assistance and later negotiations without guessing.

Bank details should be provided through a verified channel. A compensation message from an unknown account requesting a card security code or online-banking password is not a normal reason to disclose those credentials. Verify the sender independently before supplying sensitive information.

8. Submit a specific claim to the operating carrier first

The SHGM application guidance directs passengers first to the airline concerned for claims within the passenger-rights framework. Identify the flight, date, route, passengers, actual disruption and the separate remedies requested.

Attach the most relevant documents instead of an unstructured collection. State whether the claim concerns compensation, reimbursement, assistance expenses or more than one distinct head. Credit any voucher or payment already accepted and explain its purpose.

Keep the submission reference and exact text. A telephone conversation can help operationally, but a later reviewer needs a record of what was requested and how the airline answered. Where a web form fails, preserve the error and use the carrier’s verified alternative channel.

Do not use an aviation safety occurrence-reporting channel merely because the delay was frustrating. Safety reporting and passenger financial complaints serve different functions. An allegation of an actual safety event should be accurate and separate from a demand for payment.

9. Distinguish the SHGM complaint from a private payment claim

SHGM’s current passenger guidance directs applicants to its online system. Its passenger-rights entry page includes a foreign-passenger registration route. Follow the current official instructions instead of relying on an old blog’s portal address or an unofficial form collecting identity information.

Submit the airline application, response or evidence of the outstanding application, flight records and a clear description of the remaining issue. Check the applicable submission requirements at the time of filing. An administrative complaint should not be assumed to suspend every separate time limit for a private claim.

SHGM’s guidance distinguishes covered operational disruptions from unrelated matters such as a passenger’s voluntary cancellation, some ticketing disputes and baggage complaints. The fact that an airline is involved does not bring every consumer problem into the same complaint procedure.

Where payment remains disputed, assess the appropriate private-law route separately, including jurisdiction, claim value and any applicable pre-action requirements. Our English enforcement guide explains why establishing an entitlement and collecting money are not identical steps.

10. Review settlement offers and confirm actual payment

Compare the airline’s offer with the claim schedule. Identify which passenger and which head of claim the payment covers. A refund of the unused ticket should not be silently described as full settlement of every separate compensation issue unless that is the agreement being considered.

Read any waiver before accepting it. The regulation contains protections concerning limitations of passenger rights, but that is not a reason to sign documents without review. A release can create additional disputes about what was understood, paid and reserved.

For bank payment, retain the credited amount, currency, value date and deductions. If a shortfall appears, identify whether it concerns the compensation calculation, currency conversion, an intermediary-bank charge or a different issue. A precise reconciliation is more useful than simply repeating that the airline paid too little.

11. A hypothetical missed-connection scenario

Imagine a traveller with a documented connecting itinerary who reaches the final destination four hours after the original scheduled arrival. The airline describes the initial disruption as operational. This is an illustrative scenario, not a reported case or a promise of compensation.

The traveller preserves the full ticket, original schedule, replacement booking and actual arrival information. The review first checks the operating carrier, covered route, relevant ticket structure and the reason for the delay. It then examines the appropriate compensation band and any applicable reduction or other qualification.

Hotel and meal receipts are listed separately from fixed compensation. Any ticket refund or assistance already supplied is recorded. A claim is then directed to the operating carrier with the documents needed to understand the sequence.

The lesson is that “four hours late” begins the assessment but does not finish it. The legal framework, final destination, cause, passenger conditions and payments all belong in the file. A calculation based only on an airport display can miss those distinctions.

12. Arrange follow-up after returning home

Save travel records before airline applications stop displaying them. Keep a reliable email address and secure backup, and identify anyone authorised to act for you. Our power of attorney guide addresses authority prepared outside Turkey, while our remote legal matters guide explains the limits of travel-free handling.

For an overseas review, provide a short chronology beside the documents: scheduled route, actual arrival, operating carrier, first written claim and the airline’s response. Keep the booking reference and the complete response in the same file. Identify separately any refund already received, voucher accepted or amount still sought. This prevents an assistance request, ticket refund and compensation claim from being treated as one undifferentiated demand.

Bakırcı & Keskin Law Office has physical offices in Istanbul and Mersin. Turkish passenger-rights matters connected with airports and carriers elsewhere in Turkey are assessed and coordinated from our Istanbul and Mersin offices within the applicable jurisdiction, procedure and mandate. No recovery amount or completion time is guaranteed before the documents are examined.

Frequently asked questions

Does any three-hour late departure guarantee EUR 600?

No. The amended provision concerns the final arrival delay and specified causes within the applicable scope. Distance bands and other relevant conditions must be checked.

Does the airline’s nationality matter?

Yes, together with the route. The regulation distinguishes the covered operations of Turkish and foreign carriers. The ticket seller’s nationality is not a substitute for identifying the operating airline.

Can I rely on an older English translation?

Check it against the current Turkish text. The consolidated regulation includes the December 2024 amendment, which older summaries can omit.

Is compensation the same as a ticket refund?

No. Fixed compensation, reimbursement, rerouting and assistance expenses have separate conditions and should be recorded separately.

Must I accept a voucher?

Do not assume that a voucher is compulsory. Examine the applicable payment rule and any required agreement, including the voucher’s restrictions and release terms.

Can a foreign passenger use the SHGM system?

The official passenger portal provides a foreign-passenger registration route. Use its current identity and application instructions.

Does SHGM handle every baggage dispute?

No. Its passenger-rights guidance expressly distinguishes baggage complaints from the SHY-YOLCU operational complaint procedure.

Can the matter be reviewed from abroad?

Yes, the documents and possible route can be assessed remotely. Required authority, attendance and proceedings are determined for the individual file.

Official sources

SHY-YOLCU consolidated regulation, particularly Articles 2, 7, 8, 9, 10, 16 and 19; SHGM passenger application guidance; and the official passenger-rights portal. This is general English-language information, not an official translation or an individual entitlement decision.