/ Travel & Leisure

Why is Ryanair issuing refunds through its ‘Wallet’?

Has your Ryanair refund been issued as a voucher through Ryanair Wallet? Here’s why we’ve asked the Civil Aviation Authority to investigate.

When booking a flight, I find my mind is often full of excitement and anticipation. As the purchase is complete and my screen refreshes to show a booking confirmation my mind tends to drift and I picture where I am going and the fun I will be having when I get there. At no point do I tend to think or imagine how I will be refunded or compensated should my flight be delayed or cancelled.

However, with so much refund malpractice by airlines before and during the pandemic, Ryanair potentially bending the rules again in its practices of paying refunds and the government proposing to make changes to domestic flight compensation – I will be thinking deeply next time I book.

What is Ryanair Wallet?

Our investigation has found that Ryanair is paying refunds via its own online account system, the Ryanair Wallet. Accessed through its website, it is essentially an online voucher system where refunds are kept that can exclusively be spent on Ryanair flights.

Ryanair has been using the system to refund customers who have faced disruption since November 2021, depositing the money into the online wallet facility which is attached to customers’ Ryanair accounts.

From there, if you want to have the money refunded to the original form of payment, you will have to log into your “Ryanair Wallet” account to withdraw the funds

Potentially a breach of the law?

We feel that all this is adding additional headaches and confusion to a system that should be as simple as possible for anyone seeking to receive their money back. Flight delays and cancellations can cause panic and rushes to re-book – we don’t think adding further hurdles to jump through to receive your money back is fair.

In addition to that, Ryanair may be in breach of the law on airline refunds: Denied Boarding Regulation (Regulation 261/2004 EC). If customers choose to be reimbursed (rather than re-routed), airlines are legally bound to directly refund customers for cancelled flights within seven days, and are required to ask and gain customers’ signed agreement if they are offering a voucher (or ‘other services’) as an alternative.

We’ve asked the Civil Aviation Authority (CAA) to investigate and asked them to inform passengers of their rights. We are very pleased to see the government is finally looking at giving them stronger powers which would allow them to police airlines effectively through its aviation consumer policy reform consultation, however within these proposals are some concerning changes to compensation.

Drastic changes to compensation

The government is looking at changing the law that Ryanair may be in breach of in order to create a whole new system for delay compensation to domestic flights. These plans would reduce the financial penalty paid by airlines to their customers when they are delayed by three hours or more and we would argue this will reduce the level to which airlines are deterred from delaying, cancelling or overbooking flights.

We think the government and the CAA should work together to enforce the current laws before they consider changes, making sure that refunds and compensation are paid out with little or no extra headache to us when we are affected by disruption.

In order to make this case, we want to hear from you: Have you been refunded via the “Ryanair Wallet”? If so, what was your experience of it?

Have you ever struggled to receive refunds or compensation owed to you by the airlines? Let us know in the comments. 


Usually refunds are made to the original payment method, typically a credit card.

It says above “From there, if you want to have the money deposited into your bank account you will have to log into your “Ryanair Wallet” account to withdraw the funds“.

If the Ryanair Wallet allows you to deposit the money into your bank account, rather than refunding the money to the original payment method, then you get to keep any airmiles, points or cashback that you earnt by buying flights on your credit card. So I see this as positive.

That’s a big “If”. I cannot imagine RyanAir giving away anything approaching the cost of a packet of crisps. I won’t pretend I’ve ever had the pleasure of Mr. O’Leary’s hospitality, but BA only award Avios for flights actually boarded and flown. Or are you referring to airmiles awarded by the credit card operator?

Anyway, it’s there in the Terms and Conditions as I expected:

“Withdrawals requested via the RyanAir Wallet will be processed within 5 working days to the original form of payment used to make the booking.”

And in view of the above, I’m not sure how that breaches the 7 day CAA refund rule.

Thanks Em. Yes, I was indeed referring to airmiles awarded by the credit card issuer.

The T&Cs that you quote suggest that George was wrong to say that it’s possible to deposit the money into your bank account. It will almost always be a refund to the payment card, never a bank deposit unless Ryanair allows payment for flights by bank transfer (which Wizz does allow for example).

A refund to a debit card is not a bank deposit. It is very different with different implications. For example, some banks give cashback for spending on debit card, and a card refund would cause the cashback to be lost, whereas a bank deposit would not.

Thanks everyone for your comments.

Regulation EC261 on compensation for flight delays and cancellations, as retained in UK law, states that passengers should be offered a choice between a refund or re-routing, and that the refund must be paid within seven days of the cancellation.

In addition, the Regulation states that the payment to the passenger “shall be paid in cash, by electronic bank transfer, bank orders or bank cheques or, with the signed agreement of the passenger, in travel vouchers and/or other services.”

In our view, the Ryanair Wallet is not cash, electronic bank transfer, bank orders or bank cheques – we are therefore assuming that the Wallet would be viewed as travel vouchers and/or other services.

Ryanair does not appear to obtain passengers’ signed agreements for their refunds to pass into the Wallet. Indeed, from what we know about the Wallet process, it appears that Ryanair does not obtain passengers’ signed agreement for their refunds to pass into the Wallet – for example, their terms and conditions say that ‘Any refund requested for a flight disruption will be deposited to the Ryanair Wallet …’.

For this reason, we are concerned that the Ryanair Wallet refund policy may be in breach of Regulation EC261.

On a separate note, and as mentioned in a previous comment, the Ryanair Wallet Terms of Use state that “Withdrawals requested via the Ryanair Wallet will be processed within 5 working days to the original form of payment used to make the booking”. We’ve clarified the information in the conversation post above to reflect this.

Francesca — Perhaps Ryanair are relying on a construction of their terms and conditions whereby anyone signing to accept them in order to complete their booking is deemed to have given implied consent to the clauses relating to the Wallet. It would be worth testing this interpretation before everyone else starts applying it. It is well known that hardly anyone reads the full T&C’s even though they tick to indicate their acceptance. With a budget carrier it’s a case of take it or leave it since the alternative would be much more expensive.

John, contractual terms cannot override statute. If a contractual term attempts to override statute, then it is unenforceable.

That’s right, but Currys are calling consumers’ bluff and anticipating that people will not challenge their methods. I wouldn’t expect them to back down until legal action is instigated.

Hi John, absolutely. That is a very good point and something we are looking into both in terms of what other airlines’ policies are and if they use similar ‘wallet’ systems but also in terms of assessing general terms and conditions in this sector.

Thanks, Francesca.

Pigs might not fly but weasels clearly can.

Or “Eagles may soar, but weasels don’t get sucked into jet engines.”

Ryanair uses jet engines in their kites??? It’s a no trills outfit so I tought they were little Fokkers with turbo props.

For the avoidance of doubt, John’s “Fokkers with turbo props” is an aircraft type, known as the F27 and not the company.

Thanks for that clarification, Em. Much appreciated. At least the moderators desisted from deleting a presumed expletive.

I think you spoke too soon John. I appears we are not allowed to mention the name of a Dutch aviation pioneer, aviation entrepreneur, aircraft designer, and aircraft manufacturer. I wonder if Elon Musk will be permitted 🙂

I’ve restored them for you. Imagine they were spotted by out of hours without the context. No harm done.