Hiring employees in both Ireland and the UK means complying with two separate employment law systems. While they share a common legal heritage, the rules governing contracts, working hours, leave, pay, and termination differ. These differences can create risk and confusion for employers who assume the laws align.
Cross-border HR compliance demands legal precision. What’s acceptable in London might breach working time laws in Dublin. A redundancy policy that fits UK thresholds may fall short of Irish statutory entitlements. Employers must recognise these legal contrasts and manage them correctly in each jurisdiction.
This article outlines the key legal differences between Irish and UK employment law as of 2025. It covers contracts, wages, leave entitlements, family rights, dismissal rules, equality protections, and more, giving directors and HR leaders clarity on what separates the two systems.
Contracts of Employment – What Employers Must Provide
Employment contract requirements differ significantly between Ireland and the UK. In the UK, employers must give all employees and workers a written statement of the main terms on day one. In Ireland, the first core terms, known as the “Day 5 Statement,” must be provided within five days, with the full contract supplied within one month.
Probation rules also vary. In Ireland, probation is now legally capped at six months, with extension only permitted in exceptional cases. UK law sets no statutory limit on probation periods, giving employers more discretion. Any cross-border contract that includes an extended probation period must be reviewed for Irish compliance.
Employers must also handle disciplinary and grievance procedures differently. UK contracts must explicitly reference these policies. In Ireland, while not legally required in the contract, clear guidelines are essential to defend against any future dismissal. Without them, even a minor contract breach can become a legal risk.
Post-termination clauses, such as non-competes, are legally valid in both countries but enforced differently. Irish courts often scrutinise their scope more tightly, and garden leave is not implied in Irish law; it must be written into the contract.
Pay and Pension Obligations
Minimum wage rates are higher in Ireland. As of 2025, Ireland’s national minimum wage is €13.50 per hour for adults. The UK’s minimum for workers aged 21 and above is £11.44 per hour. While both offer lower rates for younger workers, Ireland’s rates are more compressed and increase more predictably.
Pension obligations show a sharper divide. In the UK, auto-enrolment is mandatory. Employers must contribute a minimum of 3% into a pension scheme for eligible workers. Ireland currently has no such obligation, though auto-enrolment will be phased in from early 2026. Until then, Irish employers are only required to offer access to a PRSA.
Pay deductions and treatment of tips also differ. In Ireland, tips must be distributed transparently under recent legislation. The UK has similar laws, but enforcement mechanisms vary. Employers operating in both countries must track region-specific rules to avoid unlawful deductions or non-compliance with wage transparency requirements.
Working Hours and Rest Periods
Working time laws diverge in key areas. Both countries cap average working hours at 48 per week, but the UK allows employees to opt out of this limit. Ireland does not. No opt-out means that longer working patterns, which are legal in the UK, would break Irish law, even with employee consent.
Break entitlements also differ. In the UK, workers are entitled to a 20-minute break after six hours. Ireland grants a 15-minute break after 4.5 hours and 30 minutes after six hours, making it slightly more generous than the standard 15-minute break after five hours. These rest periods must be uninterrupted and cannot be split or delayed in any way.
Ireland also gives employees the right to be placed in a band of hours that reflects actual hours worked, helping prevent casual contract abuse. The UK has no equivalent. Employers managing workers in both regions must track hours, breaks, and scheduling rules separately to remain compliant.
Annual Leave and Public Holidays
Holiday entitlements follow different legal structures. In Ireland, employees receive four weeks of annual leave, plus 10 paid public holidays. These are treated separately by law. In the UK, workers are entitled to 5.6 weeks’ paid leave—28 days for full-time staff—which often includes the 8 public/bank holidays.
That means Irish employees often receive more total days off, especially when public holidays fall outside annual leave. In contrast, UK employers may roll public holidays into the 28-day entitlement, giving them flexibility but reducing clarity for employees.
Carryover rules also differ. Irish workers can carry leave into the following year under specific conditions, especially after long-term sick leave or maternity leave. In the UK, leave not taken usually expires unless extended by agreement or protected under illness rules. Employers must structure policies carefully to align with local law.
Sick Pay and Occupational Health
Sick pay entitlements differ in both duration and payment source. In the UK, employees receive Statutory Sick Pay (SSP) for up to 28 weeks, starting from day four. The employer pays SSP directly. In Ireland, the new Statutory Sick Pay scheme covers 5 paid sick days per year from day one.
Irish sick pay is calculated at 70% of normal pay, capped at €110 per day. UK SSP is a flat rate (around £109.40 per week). This means Irish employees on higher wages may receive more pay during short illnesses, while UK employees benefit from longer-duration cover.
Health and safety laws are robust in both jurisdictions, but with different enforcement bodies. Ireland’s Health and Safety Authority (HSA) and the UK’s Health and Safety Executive (HSE) impose similar employer duties. However, incident reporting and safety rep structures differ, requiring localised compliance procedures.
Family Leave – Maternity, Paternity, and More
Maternity leave differs in both duration and who pays. In the UK, employees get 52 weeks of maternity leave, with Statutory Maternity Pay for 39 weeks, paid by the employer. In Ireland, maternity leave lasts 42 weeks (26 paid + 16 unpaid), but the state pays Maternity Benefit directly. Employers have no legal obligation to top it up.
Paternity leave is two weeks in both countries. In the UK, employers must pay Statutory Paternity Pay. In Ireland, paternity leave is state-paid only, with no employer contribution required. This makes Irish paternity leave less costly for employers but less generous unless voluntarily topped up.
Ireland also offers Parent’s Leave. It’s currently 7 weeks paid by the state. The UK has no equivalent but offers Shared Parental Leave, allowing couples to split up to 50 weeks of leave. Employers must treat these requests separately and apply the correct jurisdiction-specific entitlements.
Termination, Redundancy, and TUPE Transfers
Termination law varies in key areas. In Ireland, employees gain unfair dismissal protection after 12 months’ service. In the UK, it takes 24 months. That means UK employers have a longer window to end employment without triggering unfair dismissal rights, unless discrimination or automatic unfair grounds apply.
Redundancy entitlements also differ. Irish employees receive 2 weeks’ pay per year of service, plus a bonus week, with no cap on total payout. The UK uses an age-based formula with a 20-year cap and weekly pay limits, making Irish redundancy payments significantly higher in most cases.
TUPE rules don’t fully align. In the UK, TUPE covers service provision changes like outsourcing. Ireland only applies TUPE when an economic entity transfers with its identity intact. Employers must not assume automatic transfer rights apply in both jurisdictions, especially when tendering contracts or restructuring teams.
Equality, Discrimination, and Gender Pay Reporting
Both Ireland and the UK prohibit workplace discrimination, but their legal frameworks differ. The UK protects 9 characteristics under the Equality Act, including gender reassignment. Ireland protects 9 grounds too, including family status and membership of the Traveller community, which are not separately defined in UK law.
Compensation limits vary. UK tribunals can award uncapped damages for all discrimination claims. In Ireland, awards are generally capped at 2 years’ pay, except for gender-based claims, which are uncapped under EU law. This cap can reduce employer liability in Ireland but increases risk exposure in the UK.
Gender pay gap rules also diverge. The UK requires reporting from companies with 250+ employees. Ireland is phasing in stricter thresholds, 50+ employees by 2025. Irish reports must also include action plans and explanations, giving the law more depth. Employers operating in both regions must manage separate compliance calendars.
Cross-Border HR Compliance: Ireland vs UK Employment Law Differences Explained
Assuming Irish and UK employment laws are interchangeable is a mistake. From probation rules and working time to sick pay, redundancy, and discrimination claims, the legal contrasts are clear and growing. Even shared principles like fairness or equality are enforced differently, with unique thresholds, obligations, and penalties in each jurisdiction.
For employers managing teams across both countries, these differences impact contracts, policies, payroll, and risk exposure. What’s lawful in Manchester may be unlawful in Cork. Applying the wrong rule in the wrong country could lead to claims, audits, or reputational harm, especially as legislation continues to diverge post-Brexit.
Cross-border compliance starts with clarity. HR Team helps you align policies with local law, avoid costly errors, and stay confident in your people strategy, no matter which side of the border you’re on.
Contact HR Team today to align your HR practices across Ireland and the UK.
FAQ – Cross-Border HR Compliance Between Ireland and the UK
Do Irish and UK employment laws apply the same rules for contracts?
No. Ireland requires a Day 5 Statement of core terms, with full terms within a month. The UK requires a full written statement on Day 1. Probation periods are also legally capped in Ireland—typically at six months—unlike in the UK.
Are employees entitled to more holidays in Ireland or the UK?
Irish employees receive four weeks of annual leave plus 10 public holidays, treated separately. UK workers receive 5.6 weeks’ leave, which often includes public holidays. The structure and total number of days differ between the jurisdictions.
What’s the difference in statutory sick pay between Ireland and the UK?
Ireland provides 5 paid sick days per year. UK employees can receive Statutory Sick Pay for up to 28 weeks, starting from day four. The Irish model pays a percentage of wages, while the UK SSP is a flat rate.
Do both countries require employers to provide pension contributions?
Yes, in the UK, auto-enrolment is mandatory for eligible staff, with a minimum 3% employer contribution. In Ireland, there is no current legal obligation, but auto-enrolment is expected from 2026, which will introduce mandatory contributions.
What is the main difference in redundancy costs?
Redundancy payouts are higher in Ireland. Irish law grants 2 weeks’ pay per year of service plus a bonus week, with no cap. The UK applies age-based calculations, caps at 20 years, and limits weekly pay, reducing total liability.
