Social security coordination rules protect the rights of citizens should they move between the jurisdictions for work. The jurisdiction responsible for social security payments, also called the Competent State, is often the place of employment or self-employment.

Social insurance contributions are referred to as Pay Related Social Insurance (PRSI) in Ireland and National Insurance Contributions in NI.

Competent state example:

• Live North, Work South 5 days per week = the responsible state will be Ireland and the worker will pay PRSI.
• Live South, Work North 5 days per week = the responsible state will be NI and the worker will pay National Insurance Contributions.

These two examples refer to people commuting full-time across the border, however working from home more than 25% of the time*, carrying out work duties in the jurisdiction of residence, or working in both jurisdictions could change the Competent State to where the person lives.

• Live North, Commute South 3 days per week, Work from Home 2 days per week,  = the responsible state will be NI and the person will pay National Insurance Contributions.

Proof of Competent State

If the situation is unclear, the worker or their employer can ask the Irish or UK authorities to confirm which jurisdiction is responsible and a Certificate of Coverage (PDA1) will be issued. This is especially useful if the worker is employed in both jurisdictions as it states exactly which system the person is linked to.

The coordination rules state that a person is only obliged to pay in one jurisdiction at a time.

Social Insurance Record

As workers pay social insurance contributions they build up a record which can be relied upon in event that a social welfare payment is needed (e.g. illness benefit).  Any social security payments that are linked to social insurance contributions are usually exportable across the border.  PRSI contributions can be combined with National Insurance Contributions to help a person qualify for a contribution-based payment.

Sickness benefit example:

• Living North, Working South 5 days per week = the responsible state will be Ireland, the worker will pay PRSI and will claim Irish Illness Benefit if they are too ill to go to work.
• Living South, Working North 5 days per week = the responsible state will be NI, the worker will pay National Insurance and will claim UK Employment and Support Allowance if they are too ill to go to work.

Exporting benefits

The coordination rules list the benefits that can be exported by each country, the benefits are listed by category e.g. sickness payments, long term care benefits, old age benefits, family benefits, etc.  The rules prevent a person claiming the same type of benefit from both jurisdictions (there are only a few exceptions e.g. state pensions).

Sources:

• Welfare Benefits and Tax Credits Handbook 2024/25Part 11: Immigration and residence rules for benefits and tax credits Chapter 71: European Union co-ordination rules 4. Principles of coordination 
• Border People – Comparable UK and Irish benefits in cash
• EU Coordination Rules 
• UK Ireland Social Security Convention
• Trade and Cooperation Agreement

*Note that the 25% rule is commonly used, but other factors may also be taken into consideration. See Article 14 of Regulation (EC) No 987/2009 laying down the procedure for implementing Regulation (EC) No 883/2004 on the coordination of social security systems (see Articles 12 and 13)

Page last checked: 12 November 2024

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