The three systems at a glance
| Feature | Ireland | United Kingdom | United States |
|---|---|---|---|
| Constitution | Written, 1937, changed only by referendum | Uncodified: statutes, conventions and case law | Written, 1787, amended by Congress and the states |
| Head of State | President, directly elected for seven years | Hereditary monarch | President, who is also head of government |
| Head of government | Taoiseach, nominated by the Dáil | Prime Minister, who must command the Commons | President, elected via the Electoral College |
| Lower house | Dáil Éireann, 174 TDs | House of Commons, 650 MPs | House of Representatives, 435 members |
| Electoral system | PR-STV in multi-seat constituencies | First past the post in single-seat constituencies | Mostly plurality in single-seat districts |
| Upper house | Seanad, 60 members, mostly indirectly elected or nominated | House of Lords, mostly appointed | Senate, 100 directly elected members |
| Courts and laws | Courts can strike down unconstitutional Acts | Courts cannot strike down Acts of Parliament | Courts can strike down unconstitutional laws |
| Removing the executive | Loss of Dáil confidence | Loss of Commons confidence | Impeachment and conviction only |
Ireland and the UK: same family, different rulebook
Both are parliamentary democracies. The head of government comes from the lower house, keeps office only with its confidence, and leads a cabinet bound by collective responsibility. Terms such as whip, division and Order of Business will feel familiar to anyone who has studied Westminster.
The big difference is legal. The UK has parliamentary sovereignty: no Act of Parliament can be struck down by a UK court, although courts can issue declarations of incompatibility under the Human Rights Act 1998. In Ireland the Constitution is supreme and the courts can invalidate an Act of the Oireachtas. Ireland's European Convention on Human Rights Act 2003 borrows the UK's declaration of incompatibility tool, but the Constitution remains the stronger shield.
Elections differ sharply too. First past the post tends to produce single-party majorities in the Commons. PR-STV tends to produce more proportional outcomes, more parties and coalition government, which is why Irish government formation can take weeks of negotiation.See how PR-STV and transfers work.
Ireland and the US: two written constitutions, two designs
Both countries have a written constitution, a supreme court that can strike down laws, and a directly elected President. The similarity stops there. The US President runs the executive branch and cannot be removed by a congressional vote of no confidence. The Irish President has mainly formal and guardian functions, while the Taoiseach runs the Government.
US members of the Cabinet cannot sit in Congress at the same time. Irish Ministers must sit in the Oireachtas. That single rule explains much of the difference between the gridlock and bargaining of Washington and the party discipline of Leinster House.
Constitutional change also works differently. In the US, amendments need two thirds of both Houses of Congress and ratification by three quarters of the states, with no national popular vote. In Ireland, every amendment goes to the people.
Two Presidents, very different jobs
| President of Ireland | President of the United States | |
|---|---|---|
| Election | Direct popular vote | Electoral College, based on state results |
| Term | Seven years, maximum two terms | Four years, maximum two terms |
| Runs the Government? | No, acts mostly on Government advice | Yes, heads the executive branch |
| Signature power | Refer a Bill to the Supreme Court under Article 26 | Veto a Bill, which Congress can override |
Inside Ireland, the more important comparison is often between the two top offices. Compare the Taoiseach and the President.
Questions to test yourself
- Why can an Irish court strike down an Act when a UK court cannot?
- How does PR-STV change the kind of government a country is likely to get?
- Is the Irish President more like a monarch or a US President? Justify your answer.
- Which system gives backbench legislators the most independence, and why?
- What are the advantages of requiring a referendum for every constitutional change?