Each of these is a refusal this regime lets a counterparty attempt, paired with the answer to it. Reading them before you write is worth more than any amount of polish on the letter itself.
"Extraordinary circumstances — no compensation is due"
high likelihoodThe railway relies on the exemption introduced by Regulation (EU) 2021/782 and refuses compensation for weather, a third party on the line, or a external event.
What answers it
This defence is real but narrow, and it is the railway’s to prove. It requires circumstances outside the railway’s operation that it could not have avoided even with all due care — severe weather, a major natural disaster, sabotage or trespass, a public health crisis. It does not cover rolling-stock failure, crew shortages, or a strike by the railway’s own staff. Ask them to state the circumstance and explain what they did to avoid it. Crucially, the exemption removes the compensation; it does not remove your Article 18 re-routing rights or the Article 20 duty to feed and house you.
Regulation (EU) 2021/782, Art. 19 — Art. 19 (compensation of the ticket price)
"The delay was caused by Network Rail / the infrastructure manager / a third party"
high likelihoodThe operator points at signalling failure, a broken-down freight train, trespass or someone else’s infrastructure and says the delay was not their doing.
What answers it
Under the contractual UK Delay Repay schemes, cause is irrelevant to your entitlement: the schemes pay on the delay, whoever caused it, and the operator recovers internally from the infrastructure manager. Under Regulation (EU) 2021/782 the railway undertaking is the passenger’s counterparty and only a genuinely exceptional, unavoidable circumstance excuses it — and a staff strike at the railway itself is expressly not one.
"Here is a voucher"
high likelihoodThe operator settles in rail travel vouchers or credit rather than money, often at a discount to what is owed.
What answers it
You are entitled to be paid in money. UK operators must offer at least one monetary method — bank transfer, cheque or refund to the original card — and Regulation (EU) 2021/782 allows vouchers only where the passenger accepts them, meaning you can simply decline and ask for cash. A voucher is worth less than its face value to you and more than its face value to them, which is why it is offered first.
"It is below our minimum payment"
medium likelihoodThe railway declines a small claim on the basis of a minimum payment threshold.
What answers it
A railway may set a minimum threshold, but it may not exceed EUR 4 per ticket. If they are refusing a larger sum than that on this basis, they are wrong. And where you were delayed repeatedly, ask whether the threshold is applied per ticket rather than per claim — it is per ticket.
Regulation (EU) 2021/782, Art. 19 — Art. 19 (compensation of the ticket price)