While both jurisdictions share the island of Ireland, their immigration systems are distinct—one governed by the Republic of Ireland, an EU member state, and the other by the United Kingdom.
The Common Travel Area
The Common Travel Area (CTA) is a longstanding arrangement allowing free movement of Irish and UK citizens across both jurisdictions. This means Irish and British citizens do not require visas or residence permits to live or work in either Ireland or Northern Ireland. However, for non-Irish and non-British nationals, immigration rules diverge sharply at the border.
Calculating Residence in Northern Ireland for Irish Citizenship
Irish law requires “reckonable residence” to be physically in the State (the Republic of Ireland). Time spent living in Northern Ireland does not count towards the residency requirement for Irish citizenship, save in the case of a spouse or civil partner of an Irish citizen which treats time in the “island of Ireland” as reckonable.
Frontier workers
EEA/Swiss and non-EEA citizens who were living in one jurisdiction and working in the other (frontier workers) prior to 1 January 2021 retain their rights. Those taking up their frontier worker status after that face more complex requirements post-Brexit, including permits and compliance with both Irish and UK immigration systems.
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