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I thought so as well, but aparantly that is not needed. If you look at the withdrawal intention to agreement, they make some exceptions in it. Goods standards must be SM, but there is nothing about people. But, goods checks cannot be avoided completely.
However... the "gentleman's agreement" of the Common Travel area for UK/Ireland really has to be padded out to ensure there really is NO difference between UK and Irish citizens in NI.
Taxation may also be an issue, as right now working over the border is super easy.And businesses in NI are already screaming they can't find EU workers as it is so this doesn't help.
And as Prof Dougan points out, Scotland ain't too happy about NI have easier access to the EU than they do [customs union only] so......
My point being that NI border needs SM, and no SM without FOM.