The main difference between Irish and UK accounting is that while both use FRS 102 as a common standard, the UK has additional frameworks such as FRS 101 (reduced disclosures) and FRS 105 (micro-entities regime), whereas Ireland does not offer the same micro-entity option. There are also differences in terminology, deferred tax treatment, disclosure exemptions, and size thresholds for small companies.
Why Compare Ireland and UK Accounting?
Businesses that trade or operate across both Ireland and the UK often face confusion when preparing statutory accounts. While the frameworks are closely aligned, there are important differences in GAAP application, company size regimes, and disclosure requirements. Understanding these differences is crucial for:
Companies expanding across borders
Multinationals preparing consolidated accounts
Investors comparing financial statements
SMEs working under small company exemptions
Accounting Frameworks in Ireland vs UK
Ireland
Irish companies generally apply FRS 102 (The Financial Reporting Standard applicable in the UK and Republic of Ireland).
Larger or listed entities may be required to use IFRS (International Financial Reporting Standards).
Legacy “Old Irish GAAP” has been phased out, with FRS 102 now the default standard.
United Kingdom
UK entities can apply:
FRS 102 (for most SMEs and medium companies).
FRS 101 (reduced disclosure framework for subsidiaries of IFRS reporters).
FRS 105 (micro-entities regime for the very smallest companies).
IFRS (mandatory for listed groups, optional for others).
👉 Key difference: UK offers additional frameworks (FRS 101 and FRS 105) not available in Ireland.
Key Differences in Practice
1. Financial Instruments & Loans
Under FRS 102, many basic loans (such as director loans) are recognised at present value, not just face value.
The treatment of interest-free or below-market loans often creates differences between UK and Ireland in practice.
2. Goodwill & Intangibles
In both jurisdictions under FRS 102, goodwill must be amortised over its useful life.
If the useful life cannot be reliably determined, UK companies can use up to 10 years, while Ireland often limits to 5 years.
Disclosure expectations around impairment also differ.
3. Deferred Tax Treatment
Revaluations of property and other assets generally require deferred tax recognition.
Ireland historically applied a “timing difference” approach; under FRS 102 this has aligned more closely with the UK, but local interpretation still varies.
4. Presentation & Terminology
FRS 102 has modernised terminology:
Profit and Loss Account → Income Statement
Balance Sheet → Statement of Financial Position
In Ireland, older terms are still seen in practice, while UK companies have moved faster to adopt new terminology.
5. Small & Micro Companies
UK:
Small companies benefit from reduced disclosures under FRS 102 Section 1A.
Micro entities can apply FRS 105, with minimal disclosures.
Ireland:
Small company regime exists (similar to Section 1A), but no micro-entities equivalent.
Small company thresholds differ slightly from the UK.
👉 This is a critical distinction for startups: UK micro-companies can prepare very simplified accounts; Irish micro-businesses cannot.
6. Local Modifications & Updates
UK FRS 102 is under periodic review (2025 amendments expected).
Ireland follows the same framework but with fewer alternative standards.
Disclosure exemptions under FRS 101 (UK only) mean UK subsidiaries of IFRS groups can prepare much shorter accounts — not possible in Ireland.
Implications for Businesses
For companies operating across both jurisdictions:
Subsidiaries in the UK may file lighter accounts under FRS 101 or FRS 105, while Irish subsidiaries cannot.
Consolidation may require restatements to align with parent company policies.
Disclosure and deferred tax treatment may vary, requiring careful review.
Investors and lenders must understand these differences to compare Irish and UK companies fairly.
Best Practices for Cross-Jurisdiction Accounting
Plan ahead if you operate across Ireland and the UK: choose consistent accounting policies where possible.
Prepare reconciliations for group accounts to explain differences.
Stay updated with FRC (UK) and IAASA (Ireland) guidance on FRS 102 amendments.
Use specialist advisors familiar with both frameworks to avoid non-compliance.
Ireland vs UK Accounting
Is Irish GAAP the same as UK GAAP?
Both countries use FRS 102, but the UK also allows FRS 101 and FRS 105, which Ireland does not.
Does Ireland have a micro-entities accounting standard?
No. Only the UK has FRS 105 for micro-entities.
Are the accounting terms the same?
Not always — UK companies more often use modern terms like “Statement of Financial Position,” while Irish companies may still use traditional terms.
What about deferred tax?
Both countries require deferred tax on revaluations under FRS 102, but there are differences in interpretation and disclosure.
Conclusion
While Ireland and the UK share FRS 102 as a common foundation, the UK allows for reduced disclosure and micro-entity regimes not available in Ireland. There are also differences in terminology, tax treatment, and disclosure obligations.
For businesses working across both jurisdictions, aligning policies and working with accountants experienced in both markets is key to avoiding errors.
👉 At Persona Finance, we help companies manage their accounts in Ireland, the UK, or both. Contact us today to streamline your compliance across borders.