There are to the best of my knowledge at least three 300 litre or smaller breweries in Ireland. It takes dedication as the return is going to be limited. And all breweries have to go through the same regulatory hoops.
All the food safety hoops come from the EU, so they're broadly the same across the EU. Where I am at the moment (Utah) they're remarkably similar.
Additionally setting up your own pub in GB is simpler and cheaper (a tied house in essence) to sell your produce. This is probably the biggest difference.