Last reviewed: 22 June 2022
- There are differences in the laws that apply within Great Britain, the United Kingdom, Channel Islands and Isle of Man.
- The Equality Act only applies to Great Britain – England, Wales and Scotland – and not Northern Ireland, the Isle of Man or the Channel Islands.
- In Northern Ireland, this area is primarily governed by the Disability Discrimination Act 1995.
Great Britain
The Equality Act 2010 applies only to Great Britain – England, Wales and Scotland.
Note that the “specific duties” under the Public Sector Equality Duty are different for Scotland and Wales (excluding non-devolved bodies).
Northern Ireland
The Equality Act 2010 does not apply to Northern Ireland. Northern Ireland is part of the United Kingdom and not Great Britain.
The Disability Discrimination Act 1995 (DDA – which used to be the act that applied to Great Britain before the Equality Act 2010) still applies in Northern Ireland. There are differences between the Disability Discrimination Act 1995 and the Equality Act 2010 and so the law has evolved differently in Northern Ireland.
Brexit
Another difference between Great Britain and Northern Ireland is that under the Withdrawal Agreement, after Brexit, Northern Ireland disability discrimination law must continue to meet EU law minimum standards.
Isle of Man and the Channel Islands
The Isle of Man and the Channel Islands are not part of the United Kingdom and the Equality Act 2010 does not apply to them.
The Isle of Man has its own legislation – the Disability Discrimination Act 2006.
Some of the Channel Islands (listed below) have their own disability discrimination legislation:
Jersey:
- Discrimination (Jersey) Law, 2013 – Jersey Advisory and Conciliation Service
- Discrimination (Jersey) Law, 2013 – Official Consolidated Version.
Guernsey:
- Discrimination legislation consultation
- Guernsey Disability Alliance – Anti-Discrimination Legislation.
Further information
For tailored guidance about your organisation’s legal duties, contact our Advice Service.
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