When the UK left the European Union, the hardest question was the land border in Ireland. The answer chosen, the Northern Ireland Protocol, avoided checks on that border by moving them to the Irish Sea instead. For unionists, that was a direct challenge to Northern Ireland's place in the United Kingdom's own internal market. The Windsor Framework, agreed between the UK and the EU in 2023, was meant to fix it. It improved things. It did not fix everything.
From Protocol to Framework
The Protocol came into force on 1 January 2021. It kept Northern Ireland following many EU rules on goods and placed customs and food checks on goods moving from Great Britain to Northern Ireland. Businesses faced paperwork and delays, some suppliers in Great Britain stopped sending goods here, and unionists of every party opposed it.
The Windsor Framework, agreed in February 2023, changed how the Protocol works in practice. A further UK Government package in January 2024, Safeguarding the Union, made more changes and led to the return of the Stormont Executive in February 2024.
What changed for the better
- A UK internal market route for goods staying in Northern Ireland. Goods from Great Britain that are not going on to the Republic can travel with far fewer checks and much less paperwork.
- UK rules for many everyday goods. Food, plants, medicines and parcels for people here can largely follow UK standards.
- The Stormont Brake. 30 MLAs from at least two parties can object to a new or changed EU rule that would have a significant impact on daily life here, allowing the UK Government to stop it applying.
- New legal guarantees. Safeguarding the Union added commitments in UK law to protect unfettered access for Northern Ireland businesses to the rest of the UK.
What has not changed
- A border in the Irish Sea still exists. Fewer checks are not no checks. Goods at risk of entering the EU still face controls, and businesses still carry extra costs.
- EU law still applies here. In areas covered by the Framework, laws are made in Brussels by an EU in which Northern Ireland has no vote.
- The Acts of Union were changed. In 2023 the UK Supreme Court ruled that Parliament had lawfully modified Article 6 of the Acts of Union, which guaranteed equal trade within the UK, to make room for the Protocol.
- Consent was given without unionist support. In December 2024 the Assembly voted to continue the arrangements for four years, by 48 votes to 36. The vote passed without cross-community support, because nearly all unionist MLAs voted against.
What happens next
Because the vote lacked cross-community support, the UK Government commissioned an independent review by Lord Murphy, published in September 2025. It called for more scrutiny of EU law at Stormont, better support for businesses facing paperwork, and stronger efforts to win wider confidence before the next consent vote in 2028.
Why it matters for the Union
The Union is not only about flags and identity. It is also about whether Northern Ireland is treated as a full and equal part of the United Kingdom. On trade, the Windsor Framework still falls short of that.
The answer is not to abandon devolution or wreck the institutions. It is to keep pressing, through the Stormont Brake, the UK Government and every democratic route, until businesses and families here can trade within their own country as freely as anyone in England, Scotland or Wales. The 2028 consent vote is the next test.
Sources
- The Windsor Framework (GOV.UK)
- Safeguarding the Union (GOV.UK)
- Outcome of the democratic consent process in the NI Assembly (GOV.UK, Dec 2024)
- Independent Review of the Windsor Framework by Lord Murphy (GOV.UK, Sept 2025)
- Government response to the Independent Review (GOV.UK)
- In the matter of an application by James Hugh Allister and others, UK Supreme Court [2023] UKSC 5



