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Is Ryanair conning customers over refunds?

Ryanair is sending out a new, potentially misleading email to its customers with cancelled flights.
It says: 'We're offering customers travel vouchers as these are automated and give an immediate alternative instead of waiting for a refund.'
It goes on to say: 'If you do not wish to accept this voucher and wish to move your flight or request a refund, please click hereto contact us.'
But clicking on the link takes you to a page headlined: 'Everything you need to know about using your voucher'. There is no link for requesting the refund.
At no point does the airline explain that, under EU law, its passengers are entitled to a full cash refund within seven days of their flight being cancelled.
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Ryanair's second go at convincing customers to accept vouchers
This is not the first time that Which? has found the airline sending potentially misleading information to its customers. Initially Ryanair did have a link where customers could claim their cash refund. However, customers found that it was almost impossible to use.
It then began sending out unsolicited vouchers - even to passengers who'd said that they wanted a refund.
Which? has repeatedly called on the regulator, the Civil Aviation Authority (CAA), to take action against airlines that are not providing refunds, or are significantly delaying paying out. We have now launched a tool for consumers to report their airline to the regulator if they've been unable to get a refund for a cancelled flight, to encourage the CAA to take action.
Ryanair stalls - but other airlines pay out
Ryanair told us it has processed more than u20ac400m in refunds and vouchers since mid-March, which is more than a third of the total backlog. Significantly, that figure is for refunds and vouchers combined.
When we surveyed passengers last month, just 5% of Ryanair's customers said they'd received a refund within seven days of a flight being cancelled.
In contrast, 39% of BA passengers and 29% of Jet2 passengers were refunded within the legally required timeframe. 84% of Ryanair customers said they were still waiting for a refund.
No cash refund - just voucher with strings attached
Unlike with a cash refund, there are conditions attached to the use of a voucher. For example, it's not possible to use it to pay for a family member or friend's flight if you're not planning to fly yourself. Travel vouchers are non-transferable.
Passenger name changes are also not permitted, if a booking has been paid for using a travel voucher.
Ryanair breaking consumer protection law?
Ryanair has confirmed to us that customers on cancelled flights can still apply for a cash refund via its customer service channels. However, by making it seem as though vouchers are a reasonable alternative to a cash refund - even for those who don't want them - Ryanair may be breaking the law. It's against the law to mislead consumers into making a 'transactional decision' that they would not otherwise have made.
Under European law EU261, refunds for applicable flights cancelled by the airline should be refunded within seven days.
Ryanair response
Ryanair denied doing anything wrong, and told us: 'For any cancelled flight, Ryanair is giving customers all of the options set out under EU regulations, including free moves and refunds in the form of cash or vouchers.'
It also confirmed: 'All Ryanair customers on cancelled flights can still apply for a cash refund - via the official customer service channels - if they so wish.'
Restore trust in travel
Which? has launched a 10-point plan to help rebuild trust in travel, which you can read in full here.