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Understanding the growing differences between employment laws in Great Britain and Northern Ireland: comparative employment law table

30 November 2021

Over recent years, employment law in Great Britain (GB) and Northern Ireland (NI) has increasingly diverged. This is due to NI employment law largely remaining static, while there have been continuing significant changes in GB. Employers should be mindful of the differences when engaging staff in both jurisdictions.

Authors: Legal Island, Adam Brett

As part of the Good Friday Agreement, NI employment and discrimination law were largely devolved to the new NI institutions. For the first few years this did not make any material difference to the employment laws being passed by the Assembly in NI, which continued to mirror those in GB. However, during the period from around 2010, the position has diverged considerably. Perhaps the word ‘diverge’ is not exactly appropriate because, in many ways what has happened is that, with a few exceptions, employment and discrimination law in NI has remained static, while there have been continuing significant changes in GB.

Help for employers: Comparative table

The attached comparative employment law table, prepared by Legal Island, with a foreword by Adam Brett, outlines the key differences between GB and NI employment law as of 10 November 2021. In his foreward, Adam further explains the reasons for the differing employment law position between GB and NI.

The table is intended to be a handy reference guide, complete with links to relevant legislation and other documents, to assist employers in understanding and dealing with the differences in employment law developments over the last three years in NI and GB.

The table is split by subject area, with an index at the front to make it easy to find particular comparisons.

Neither we, nor Legal Island, confirm that this table is comprehensive – indeed, especially as regards to case law, it could not be so.

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