Which? calls for investigation of Ryanair’s Wallet refunds policy over possible breaches of consumer law

Ryanair’s approach to refunds for passengers of cancelled flights may be a breach of consumer protection law, Which? believes.

Last year, the airline introduced a policy of automatically paying refunds into a ‘Wallet’ attached to customers’ Ryanair accounts – from which they must then request to withdraw their funds. Which? believes this creates an extra step in the process, which could result in fewer people claiming their money back in cash. 

One passenger who had problems withdrawing funds from her Wallet threatened legal action against Ryanair unless it offered her a refund. She told Which? she believed the airline has deliberately made it an “intimidating process” for customers to withdraw cash “in the hope that many people simply give up”.

Which? has called on the Civil Aviation Authority (CAA) to step in to investigate this potential breach of consumer protection law and inform passengers of their rights if an airline cancels their flight. Any traveller whose flight is cancelled by their airline is entitled to re-routing or a full cash reimbursement within seven days.

Airlines are required to obtain travellers’ signed agreement if they wish to provide a voucher or ‘other services’ as an alternative. Ryanair does not appear to give passengers a choice as to whether their refunds are issued into the Wallet. 

Which? says the scheme is the latest example of the budget carrier potentially skirting around the rules. Ryanair ranked bottom of a recent Which? survey of passenger refund satisfaction. In October 2021, we asked more than 1,100 passengers about their experiences with disrupted flights since March 2020 and 47 per cent of Ryanair customers said they were satisfied with how it handled the issue, with one in five telling Which? it took them more than a month to get a refund.

Which? has shared its findings with the CAA and is urging the regulator to investigate Ryanair’s Wallet refund policy. Which? is also calling on the Department for Transport to give the CAA greater powers to more effectively enforce the law – including the ability to fine airlines that break the rules. 

In the meantime, the CAA must use its existing powers to investigate and crack down on sharp practices across the airline industry where possible, as well as ensure passengers are properly informed of their refund rights when their flight is cancelled and how vouchers work.

Rory Boland, Editor of Which? Travel, said:

“Ryanair is showing what scant regard it holds for its customers yet again by forcing them to jump through hoops to get what they are legally owed. The airline should change its policy to offer cash refunds as default. 

“Which? investigations have repeatedly shown that some airlines are prepared to flout the law when it comes to refunds and consumer rights, with little fear of facing any consequences. The CAA must step in to investigate the issue, and take action against Ryanair if it confirms the policy is breaching the law. It is crucial the CAA is given the powers it needs to effectively hold airlines to account – including fining powers.”


Case study: Voluntary worker Gill, 39, from Essex, booked flights to Salzburg but last year, the month before she was due to fly, Ryanair changed the dates. The airline said she would have a refund put in her Ryanair Wallet and could use this to book another flight, or withdraw the cash from her wallet.

She wanted to withdraw the money but ran into technical problems and issues with Ryanair’s customer service.

Gill told Which?: “When I went to withdraw the cash, it did not work. I tried multiple times and had no success. I tried emailing Ryanair and live chatting with them and initially got no response, but was eventually able to speak with an actual person online. I said I would take them to court and this resulted in them refunding the money to my credit card.”

She added: “I felt so frustrated that they made it so difficult for me to get my money back and think it is pretty disgusting that it takes a threat of legal action to do this. The cynic in me believes it was absolutely intentional that I was not able to withdraw the money from the wallet. I suspect they do this in the hope that many people simply give up.

“I am a former lawyer so don’t have any problem with following through on my legal threat, but many people would find it a difficult or intimidating process.”

Right of replies:

A spokesperson for the UK Civil Aviation Authority said:

“The Civil Aviation Authority has been clear that consumers owed a refund should only accept airline credit or vouchers where it is in their interest to do so and that it is important that consumers are given a clear option to request a cash refund without unnecessary barriers. We regularly monitor the approaches that airlines take to complying with their obligations and review any evidence provided to us about how they meet their obligations.”

A spokesperson for Ryanair said:  

“Customers are clearly informed in our Refund Hub that refunds are issued via the Wallet. It provides customers with complete control over their refunds, by giving them immediate access to their Wallet balance (for use on future bookings) and the ability to withdraw their refund in cash in just one click. All passengers’ rights and entitlements under consumer protection law continue to be fully respected.”

About Which? 

Which? is the UK’s consumer champion, here to make life simpler, fairer and safer for everyone. Our research gets to the heart of consumer issues, our advice is impartial, and our rigorous product tests lead to expert recommendations. We’re the independent consumer voice that influences politicians and lawmakers, investigates, holds businesses to account and makes change happen. As an organisation, we’re not for profit and all for making consumers more powerful.

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