Working across and with people in both my sense is that Germany has gone further, faster when it comes to specific criminalisation of explicitly anti-Israel sentiment (red triangles, watermelon pins, anti-imperialist reading groups, Israeli loyalty oaths essentially to be in local office etc), but Britain is catching up on that and has now built a far scarier and more far-reaching legal precedent/power structure to classify everyone from pensioners to protesters, defense lawyers, charities, community groups, and journalists as terrorists or foreign spies/assets. And worse still it's not even specific, so they can hand the keys to Reform or whoever to immediately expand it to literally anyone at all (that isn't aligned with the fascist state).