Employment Law - Understanding the Differences Across Great Britain, Northern Ireland & the Republic of Ireland

Introduction

One workforce, three legal systems. Employers and advisers with staff in Great Britain, Northern Ireland and the Republic of Ireland are dealing with three different statutory codes, three different tribunal systems and from 2026, three reform programmes moving at different speeds.

The Employment Rights Act 2025 is rewriting the rules in Great Britain through 2026 and 2027, but employment law is devolved and almost none of it crosses the Irish Sea. Northern Ireland keeps its own statutory dismissal procedures, a separate equality framework and a pending Good Jobs Employment Rights Bill of its own. Ireland's Workplace Relations Commission runs on different principles again.

This virtual classroom seminar works through the differences that actually change advice and outcomes, using worked scenarios drawn from practice on both sides of the border and the Irish Sea.

What You Will Learn

This live and interactive course will cover the following:

• The three frameworks side by side: the Employment Rights Act 1996 and the Employment Rights Act 2025 in Great Britain, the Employment Rights (Northern Ireland) Order 1996, and the Unfair Dismissals Acts 1977 to 2015 in Ireland - which law applies to a cross-border or remote worker
• Unfair dismissal: the Great Britain qualifying period falling from two years to six months from January 2027, one year in Northern Ireland, twelve months in Ireland and the different tests of fairness in each
• Northern Ireland's statutory dismissal and disciplinary procedures and the Labour Relations Agency Code: the automatic unfairness and uplift consequences Great Britain abolished in 2009
• Discrimination: The Equality Act 2010 against Northern Ireland's separate statutes, fair employment, political opinion and the Equality Commission's monitoring regime and Ireland's nine grounds under the Employment Equality Acts
• Harassment: the preventative duty and third-party harassment in Great Britain and the position in Northern Ireland and Ireland
• Time limits, conciliation and forums: six months in Great Britain from October 2026, three months and early conciliation in Northern Ireland, six months extendable at the WRC, and how the Employment Tribunal, the Industrial and Fair Employment Tribunals, the WRC and the Labour Court differ in practice
• Remedies: removal of the compensatory award cap in Great Britain, the Northern Ireland cap, Ireland's limit of two years' remuneration for financial loss, injury to feelings and costs
• Holiday pay after Agnew: uncapped back pay in Northern Ireland and the two-year limit in Great Britain
• Family and flexible rights: day-one rights in Great Britain, where Northern Ireland lags (flexible working, carer's leave, neonatal care leave) and where it leads (paid miscarriage leave) and Ireland's Work Life Balance Act
• Redundancy, TUPE and settlement: collective consultation and the protective award, the Irish 2003 Transfer Regulations, and the statutory conditions for a binding settlement in each jurisdiction
• The reform map: the Employment Rights Act 2025 timetable, the Northern Ireland Good Jobs Employment Rights Bill and Ireland's pay transparency, auto-enrolment, retirement age and platform work changes
• A practical checklist for advising employers with staff in more than one jurisdiction

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.