Publication
Brexit and You: Northern Ireland
From Department of Foreign Affairs
Published on
Last updated on
From Department of Foreign Affairs
Published on
Last updated on
New UK import controls taking effect 30 April. This impacts Irish exporters. Click the below link for more information on the UK Border Target Operating Model.
The UK left the European Union on 31 January 2020 after both sides concluded a Withdrawal Agreement to facilitate an orderly departure.
There are significant and permanent changes as a result of the UK’s decision to leave the EU. The UK no longer applies the rules of the Single Market and Customs Union.
The Withdrawal Agreement includes the Protocol on Ireland/Northern Ireland, now known as the Windsor Framework, which means that many of the changes that apply to trade between Ireland and Great Britain do not apply between Ireland and Northern Ireland.
The Protocol came into force from 1 January 2021, following the end of the transition period - agreed as part of the Withdrawal Agreement - on 31 December 2020. In February 2023 the EU and the UK reached agreement on Windsor Framework, a new way forward on the Protocol on Ireland/Northern Ireland. The Windsor Framework sets out joint solutions on customs, agri-food, medicines, VAT and excise, as well as arrangements to give stakeholders in Northern Ireland have a greater say on EU issues that impact them.
The Common Travel Area between Ireland and the UK, including the associated rights and entitlements continues to operate as before Brexit.
In this section, you can find general information on the Windsor Framework arrangements for Northern Ireland, the Common Travel Area, and the all-island economy, as well as specific information on daily life, living and working, studying, and travel in Northern Ireland in the context of Brexit.
The Windsor Framework (formerly known as the Protocol on Ireland and Northern Ireland ) is an integral part of the Withdrawal Agreement. It is a comprehensive and legally operative solution that addresses the challenges of Brexit on the island of Ireland.
The Windsor Framework protects the Good Friday Agreement, North/South cooperation, and the all-island economy. It avoids a hard border on the island of Ireland, while preserving the integrity of the EU Single Market and Ireland’s place in it. The Windsor Framework fully respects Northern Ireland’s constitutional status, as set out in the Good Friday Agreement. It also includes commitments to ensure no diminution of rights, safeguards and equality of opportunity, as set out in the Good Friday Agreement, and confirms that Irish citizens in Northern Ireland will continue to enjoy their rights as EU citizens.
In addition, the Windsor Framework provides a legal framework for the continuation of the Single Electricity Market on the island of Ireland, and reaffirms the commitment of the EU and UK to the PEACE PLUS programme. The maintenance of the Common Travel Area by Ireland and the UK is also recognised in the Windsor Framework.
The UK’s departure from the EU means Ireland is now in a new chapter in our relationship with our nearest neighbour. The British-Irish relationship is strong and deep, through our trade and interconnected economies, our shared historical community, cultural and family ties, and the rich contribution of Irish and British citizens in our respective countries. We are continuing to work with the British Government in the post-Brexit context.
With regard to practical issues like living, working, studying, and accessing services like health and education, including certain aspects of cross-border healthcare on the island of Ireland, you will hear about the Common Travel Area (CTA).
The Common Travel Area is a long-standing arrangement between the UK and Ireland which means Irish citizens can move freely to live, work, and study in the UK on the same basis as British citizens, and vice versa. Irish and British citizens also enjoy associated rights and entitlements including access to employment, healthcare, education, social benefits, and the right to vote in certain elections.
Living, working, and travelling in Ireland or the UK, has not changed a lot because of the Common Travel Area and the rights it gives to Irish and British citizens.
The Common Travel Area is not reliant on membership of the EU, and dates back to before either the UK or Ireland were EU members.
The government, together with the British Government, has undertaken extensive work to maintain the Common Travel Area arrangements for all citizens of Ireland and the UK. This work will continue. Structures are in place to oversee the operation of the Common Travel Area and address any issues arising.
On 8 May 2019, the Irish and British Governments entered into a Memorandum of Understanding (MoU) reaffirming the joint commitment of both Governments to the Common Travel Area in all Brexit scenarios, and to maintaining the associated rights and privileges of Irish and British citizens.
Irish citizens in the UK and British citizens in Ireland are not required to take any action to protect their status, or the rights associated with the Common Travel Area. Irish citizens resident in the UK are not required to register or take any action under the British Government's Settled Status scheme. They continue to hold their Common Travel Area rights, which are not reliant on EU membership. However, as EU citizens, Irish citizens may apply to the British Government's Settled Status scheme, if they so wish. Similarly, British citizens resident in Ireland are not required to apply for a permanent residence document from the Irish Government, but they may choose to do so.
The UK is not part of the EU’s Single Market and Customs Union. This means that any business that moves goods from, to, or through the UK (excluding Northern Ireland) is subject to a range of customs formalities and other regulatory requirements, including Sanitary and Phytosanitary (SPS) controls in the case of food, animal and plant products.
These changes do not apply with respect to trade in goods between Northern Ireland and Ireland, and other EU Member States, in either direction, where the Windsor Framework applies.
The Windsor Framework provides that Northern Ireland is legally part of the UK customs territory, but subject to certain provisions of EU law. These EU law provisions include the Union Customs Code and EU legislation across a range of areas necessary to protect the integrity and operation of the Single Market in goods.
Under the Windsor Framework, no new checks or controls apply to goods moving between Ireland and Northern Ireland in either direction. This means that goods from Northern Ireland benefit from free and open access to the EU Single Market. Necessary checks and controls (including on SPS goods) take place on goods entering Northern Ireland from the rest of the United Kingdom and other third countries.
The Windsor Framework covers trade in goods and does not significantly address services trade. The EU-UK Trade and Cooperation Agreement facilitates trade in services between the EU (including Ireland) and the UK (including Northern Ireland).
However, British citizens and companies operating as service providers within the EU, including Ireland, cannot rely on the EU Services Directive, for instance, which facilitates EU businesses wishing to provide services in another EU Member State.
The UK does not apply the rules of the EU’s Single Market for services. The automatic facility in EU law that has generally allowed UK businesses, including those in Northern Ireland, to provide services in another EU Member State no longer exists. UK businesses no longer enjoy such benefits as freedom of establishment, a common regulatory and supervisory environment, or the EU’s system of mutual recognition of professional qualifications.
If you are an Irish company operating in the UK (including Northern Ireland), or a business in the UK, (including Northern Ireland) operating in the EU, you need to understand the impacts on your operations of any rules, procedures, and/or authorisations that control the provision of services in each jurisdiction. More information on trade in services.
For those trading on cross-border on the island of Ireland, whether in goods or services, InterTrade Ireland’s Brexit Advisory Service provides a range of practical advice, support and information for business on Brexit related issues.
Since 1 January 2021, a number of new steps must be completed in order to move goods between Northern Ireland and Great Britain via Irish ports. Further details are available from the Revenue Commissioners .
Following the the introduction of UK import controls on 31 January 2024, Qualifying Northern Ireland Goods will continue to have unfettered access to Great Britain.
Further information on moving qualifying Northern Ireland goods to GB through Ireland is available in the UK Government guidance on moving qualifying goods from Northern Ireland to the rest of the UK .
The new UK requirements will apply to goods from Ireland whether transported directly from Ireland to Great Britain or indirectly via Northern Ireland to Great Britain.
Irish and British citizens continue to enjoy the right to travel freely throughout Ireland and the UK.
Cross border bus and rail transport services continue to operate.
UK driving licences are no longer valid for persons living in Ireland. However, the Minister for Transport has signed an agreement with the United Kingdom that will allow residents of Ireland with a UK driving licence to exchange that licence (under this new agreement) for an Irish driving licence.
UK visitors to Ireland are not affected and can drive in Ireland with an existing UK driving licence.
Contact the National Driver Licence Service for more information.
The British Government advises that arrangements for EU licence holders who are visiting or living in the UK, including Northern Ireland, have not changed. Therefore, visitors to Northern Ireland with driving licences from EU Member States, including Ireland, should continue to enjoy the same arrangements as before.
Drivers from Northern Ireland travelling across the border will not be required to carry an International Driving Permit.
On 30 June 2021, the European Commission waived the obligation to show the motor insurance Green Card for drivers from the United Kingdom. This is particularly helpful for Northern Irish motorists from Northern Ireland crossing the land border into Ireland.
Irish and British citizens continue to enjoy the right to travel freely throughout Ireland and the UK in the same manner as before.
There is no requirement for Irish and British citizens to carry passports when travelling within the Common Travel Area.
However, it is the case that airline carriers in many instances require all passengers to have a passport in their possession before allowing them to board aircraft. This is not an immigration requirement.
For journeys on and across the island of Ireland, British and Irish citizens do not require any travel documents.
Immigration requirements, as appropriate, will continue to apply to non-Irish and non-British citizens in both jurisdictions. Under the Trade and Cooperation Agreement, EU citizens can continue to travel to the UK for holidays or short-term visits without the need for a visa. Details on documentary requirements for entry to the UK are available here .
Further information on entering Ireland can be found on the Irish Naturalisation and Immigration website .
Information on mobile phone and data usage can be found on the Brexit and You: Daily Life page.
Many students on the island of Ireland, North and South, receive some or all of their education in the other jurisdiction. This is one of the rights and entitlements associated with the Common Travel Area that is enjoyed by students both North and South and which will continue in all circumstances.
Every day, children and young people cross the border to attend school in either jurisdiction. This continues under the Common Travel Area.
Students from Northern Ireland will continue to be able to study in Ireland and vice versa.
Should you pursue your further and higher study in the UK, your fees will be set at the same level as citizens in the UK for the 2020/2021 academic year, and will continue on that basis for the duration of the programme for which you have registered. The Common Travel Area (CTA) means Ireland and the UK will take steps to ensure Irish and British citizens can continue to access further and higher education into the future.
Students from Northern Ireland will be eligible for the same fee structures as Irish students.
The usual SUSI student grant rules continue to apply for both British and Irish students.
The government is putting in place legislation to ensure that these arrangements continue to apply to eligible students studying in Northern Ireland, as well as the payment of SUSI grants to students from Northern Ireland studying in higher education institutions in the South.
Further education training and opportunities continue to be available to students and trainees from Northern Ireland, and vice versa, under the Common Travel Area.
The EU’s Erasmus+ programme provides funding for a range of international education and training projects, including student and staff mobility and exchanges, job shadowing, teaching assignments, and strategic partnerships between organisations.
The programme will continue to operate fully for Ireland and EU Member States. While the EU-UK Trade and Cooperation Agreement provides a basis for the UK to participate in specified EU Programmes, the UK has decided not to participate in Erasmus. Irish students and staff must now pursue their Erasmus mobilities within the remaining EU Member States.
The government will introduce a scheme to allow for the continued participation in Erasmus+ mobilities for eligible students of higher education institutions in Northern Ireland, on the basis of temporary registration at Irish higher education institutions. The Department of Further and Higher Education, Research, Innovation and Science is working with education institutions, North and South to put the appropriate processes in place. You should keep in contact with the Erasmus/ International Office in your institution for further details on this.
Please see the Studying section for further information on education and related matters.
Professional qualifications are specific qualification requirements that a person needs to possess by law in order to access or pursue a regulated profession, or to engage in regulated activities in a given country. Qualification requirements vary between professions. Through the introduction of a simplified, and in some cases, automatic recognition process, EU Directives have facilitated the movement of professionals between all jurisdictions within the EU, through the recognition of non-domestic qualifications.
As of 1 January 2021, mutual recognition of professional qualifications (MRPQ) between the EU and the UK no longer applies. British citizens, irrespective of where they acquired their qualifications, and EU citizens with qualifications acquired in the UK will need to have their qualifications recognised in the relevant Member State on the basis of that country's existing individual rules applicable to the qualifications of third-country nationals.
However, if you already had these qualifications recognised by the relevant EU regulator before the end of the transition period (31 December 2020), there will be no change and you can continue to practise in Ireland or elsewhere in the EU.
The Government of Ireland has encouraged regulatory authorities in Ireland, some of whom operate on an all-island basis, to engage with their counterparts in the UK in order to manage the process of continued recognition of UK qualifications in national law in Ireland. To date, significant progress has been made across a range of qualifications areas.
The EU-UK Trade and Cooperation Agreement nevertheless foresees a mechanism whereby the EU and the UK may later agree, on a case-by-case basis and for specific professions, on additional arrangements for the mutual recognition of certain professional qualifications.
If you have a query about your professional qualification, you should contact the relevant regulatory body for your profession.
Irish and British citizens can continue to live and work on both sides of the border on the island of Ireland. This is because both Ireland and the UK are part of the Common Travel Area, which gives Irish and British citizens the right to live and access services in both countries.
If you are an Irish citizen living in the UK, including Northern Ireland, or a British citizen living in Ireland, your social welfare rights and entitlements have not changed.
You are entitled to access social assistance schemes, including pensions and child benefit payments, in either jurisdiction just as before.
This also includes social insurance entitlements where British and Irish citizens living in Ireland maintain the right to benefit from social insurance contributions made when working in the UK, including Northern Ireland and to access social insurance payments if living in the UK (including Northern Ireland) and vice versa.
See Common Travel Area section above.
Irish citizens resident in the UK (including Northern Ireland), and British citizens resident in Ireland, have the right to vote in local and national parliamentary elections.
See Common Travel Area section above.
If you work on one side of a border but live on the other, and return home at least once a week, you are a frontier worker, or a cross-border worker.
If you are an Irish or British citizen living and working anywhere on the island of Ireland or between Ireland and Great Britain, including as a frontier worker, you do not need to take any action. The Common Travel Area provides Irish and British citizens with the continued right to work and/or reside in either jurisdiction.
From 1 January 2021, the UK introduced some changes for frontier, or cross-border workers who are not Irish or British. You should consider how these might affect you and take action if necessary.
Both the Irish and British Governments are committed to maintaining the current healthcare arrangements under the Common Travel Area . Under the Common Travel Area, Irish citizens and British citizens who live in, work in, or visit the other State have the right to access healthcare there.
Other cooperation arrangements on a North South basis also continue on the island of Ireland.
The Trade and Cooperation Agreement between the EU and the UK provides a framework for the continuation of access to healthcare for persons resident in Ireland who are working, visiting or residing in the UK, including Northern Ireland. The scope of these arrangements includes planned treatment and necessary healthcare.
For more information on healthcare arrangements after Brexit, please visit the Health and Brexit page.
Cross border health services (like the cardiology and cancer treatments in Altnagelvin, Derry and paediatric cardiology and related maternity services in Dublin) are managed by service level agreements. Similar arrangements are in place between the National Ambulance Services and the Northern Irish Ambulance Service for the provision of cross-border ambulance services. In all scenarios, services like these continue.
The Trade and Cooperation Agreement between the EU and the UK provides for a continuation of healthcare rights when on a temporary stay in a State covered by the Agreement.
Under the Agreement, residents of Northern Ireland can continue to use their current UK European Health Insurance Card (EHIC) to access necessary care while on a temporary stay in another EU Member State, until the card reaches its expiry date. At that point, residents of Northern Ireland may obtain a new ‘Global Health Insurance Card’ (GHIC), issued by the British Government.
Eligible EU citizens, including Irish citizens, who were living in the UK, including Northern Ireland, by the end of the transition period (31 December 2020), who exercised their right to free movement and are therefore covered by the EU-UK Withdrawal Agreement, can apply for a new UK-issued EHIC.
Further information can be found on the NHS website, on how residents of Northern Ireland can apply for a new GHIC.
The UK's withdrawal from the EU gave rise to concerns for people living in Northern Ireland about what it might mean for their rights and entitlements.
Throughout the negotiations, the government prioritised the protection of the Good Friday Agreement in all its parts, including the rights and citizenship provisions which are central to it. This is reflected in the Withdrawal Agreement and in the Windsor Framework.
It is also important to note:
Irish citizens continue to have EU citizenship wherever they live. They continue to enjoy the right to travel and live and work anywhere in the EU and the right not to be discriminated against on the grounds of nationality. Irish citizens do not need to take any action to protect their EU citizenship.
Neither Irish citizens nor British citizens are required to take any action to protect their status and rights associated with the Common Travel Area.
Further, through the Windsor Framework, the UK has confirmed its commitment to ensure no diminution of the rights, safeguards and equality of opportunity set out in the Good Friday Agreement.
This includes a commitment to no diminution in rights in the area of non-discrimination. Annex 1 of the Windsor Framework lists the EU Directives that have been adopted by the European Union in this area. These Directives continue to be applied and will be updated as necessary in Northern Ireland.
The commitment to no diminution applies further to all rights, safeguards and equality of opportunity concepts set out in the Good Friday Agreement.
The United Kingdom has set out its commitments in this respect, as well as on the operation of the dedicated mechanism comprising the Equality Commission of Northern Ireland and the Northern Ireland Human Rights Commission, established as part of its implementation of this commitment, in a document that was published in August 2020.
The commitment of the Irish Government to the Good Friday Agreement, in all its parts, including North South Cooperation and the work of the North South Ministerial Council and North South Implementation Bodies, is unwavering.
The Windsor Framework includes the maintenance of the necessary conditions for continued North-South cooperation, including in the areas of environment, health, agriculture, transport, education, tourism, energy, telecommunications, broadcasting, inland fisheries, justice and security, higher education and sport.
The Withdrawal Agreement maintains the Single Electricity Market.
Specifically, the Windsor Framework provides for the continuance of the Single Electricity Market on the island of Ireland.
Ireland and the UK both have a common law system and share a Common Travel Area , which includes certain legal rights and entitlements. However, since 1 January 2021, EU law no longer applies to or in respect of the UK.
The EU-UK Trade and Cooperation Agreement includes cooperation on law enforcement and criminal justice. The EU and the UK have agreed to establish a new framework for law enforcement and judicial cooperation in criminal matters, which will allow for strong cooperation between national police and judicial authorities.
Details of UK participation in future EU programmes are set out in the Joint Declaration on Participation in Union Programmes and Access to Programme Services that forms part of the overall agreement between the EU and UK.
The Trade and Cooperation Agreement provides for the UK's continued participation in EU programmes.
In 2023, the EU and the UK reached agreement on the UK rejoining the EU's Horizon and Copernicus programmes.
The EU and the UK agreed that the UK would have continued access to the services provided by EU Satellite Surveillance and Tracking (SST).
The Withdrawal Agreement provided for the continuation of thePEACE IV and INTERREG VA programmes and for a successor programme, PEACE PLUS, which will combine the previous PEACE and INTERREG EU funding strands into one cohesive cross-border programme.
EU leaders have agreed, in the framework of the EU’s 2021-2027 Multi-Annual Financial Framework, to provide substantial funding for PEACE PLUS in support of peace and reconciliation and of the continuation of North-South cooperation on the island of Ireland.This new North-South programme for the 2021-2027 period will support peace and prosperity across an eligible area of Northern Ireland and the border counties of Ireland (Counties Cavan, Donegal, Leitrim, Louth, Monaghan and Sligo). The Irish Government, the Northern Ireland Executive, and the North South Ministerial Council have approved the draft PEACE PLUS programme. The programme will now be reviewed by the European Commission for final consideration and approval, ahead of a formal launch in 2022.
The Joint Declaration on Participation in Union Programmes and Access to Programme Services renews the joint commitment of the EU and the UK to the new programme, which will be the subject of a separate financing agreement.