Abstract
A comparative legal analysis between Ghana and South Africa on the labour protection for domestic workers in both countries will be the basis of this study. It is a universal truth that domestic workers remain undervalued, undermined and underpaid in most countries. To remedy this, both Ghana and South Africa have implemented progressive legislative reforms leading to the protection of domestic workers. However, the private homes they work in make it difficult to fully enforce the rights and protection afforded to them by labour legislation. This study looks at applicable international instruments, the South African and Ghanaian legislative framework of domestic workers, and the enforcement thereof. The study aims to show that there are gaps in the labour laws that govern domestic workers in South Africa which render the country not wholly compliant with the Domestic Workers Convention No.189 of 2011. Like Ghana, although not perfect, South Africa needs to consider its international obligations and the unique nature of the sector when domestic legislation is put into effect.