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Cross-Border Employment: Key Considerations for Employers

If your business operates across Ireland and Northern Ireland, there are several important areas to consider to stay compliant and support your employees effectively.

Building blocks with complaince terms

Here's a practical checklist to guide you:

1. Employment Law
  • Make sure employment contracts meet the legal requirements of the country where the employee is working.
  • Keep up to date with:
    • UK National Minimum Wage / Living Wage
    • Irish Minimum Wage
2. Payroll & Tax
  • Set up and manage payroll in both jurisdictions:
    • UK PAYE and National Insurance Contributions (via HMRC)
    • Irish PAYE and Pay Related Social Insurance (via Revenue)
  • Understand cross-border tax residence rules for employees
  • Check for double taxation treaty relief between UK and Ireland
3. Social Security Contributions
  • Identify which country’s social security rules apply to each employee.
  • Where required, apply for certificates of coverage:
    • HMRC in the UK
    • Department of Social Protection in Ireland
4. Immigration & Right to Work
  • Confirm that employees have the right to work in both jurisdictions.
  • Check if any visa requirements for non-Irish/UK nationals
  • Note: Irish citizens can freely work in the UK (and vice versa) under the Common Travel Area (CTA)
5. Health & Safety
  • Ensure your business complies with the relevant health and safety authorities:
    • HSENI (Northern Ireland)
    • HSA (Republic of Ireland)

Don’t overlook remote workers—make sure they also have a safe working environment.

6. Employee Benefits & Rights
  • Provide employees with their full legal entitlements, including:
    • Holiday leave
    • Sick pay
    • Redundancy pay
    • Family leave (maternity/paternity, etc.)

Consider whether you need to enrol employees in a pension scheme in line with local rules.

7. Reporting & Compliance
  • Submit real-time payroll reporting:
    • RTI (Real Time Information) to HMRC
    • ROS submissions to Revenue
8. Data Protection
  • Comply with UK GDPR (NI) and EU GDPR (ROI)
  • If you’re transferring HR or payroll data across borders, implement the necessary data protection safeguards.
9. Cross-Border Operational Issues
  • Assess the risk of creating a ‘permanent establishment’ from a tax perspective.
  • Align HR policies across both jurisdictions while respecting legal differences.

Need Help?

Trade Hub’s Live Chat offers access to fully funded, one-to-one support on all aspects of cross-border employment. Reach out for further information for your business. 

Do you need further help or advice?


Article published by the InterTradeIreland Trade Hub Team: October 2025