The national and cross-national approach

The UK has four separate nations / jurisdictions with different sets of devolved powers, and three separate legal aid jurisdictions - England and Wales together, Scotland, and Northern Ireland.

They organise legal aid in quite different ways, with different fee structures, eligibility thresholds, quality control regimes, rules about what issues are covered by legal aid, and regulations on who is allowed to do legal aid work.

The cross-national approach offers a comparison between the three different legal aid models used in the UK and to examine the advantages and disadvantages of each, in context.

This House of Commons Library Briefing Paper (no 7603, 9 June 2016) gives a useful introduction to the differences. https://commonslibrary.parliament.uk/research-briefings/cbp-7603/