Legal diversity and regulatory competition: which model for Europe?

Simon Deakin

Working Papers from Centre for Business Research, University of Cambridge

Abstract: Two models of regulatory competition are contrasted, one based on a US pattern of Ôcompetitive federalismÕ, the other a European conception of Ôreflexive harmonisationÕ. In the European context, harmonization of corporate and labour law, contrary to its critics, has been a force for the preservation of diversity, and of an approach to regulatory interaction based on mutual learning between nation states. It is thus paradoxical, and arguably antithetical to the goal of European integration, that this approach is in danger of being undermined by attempts, following the Centros case, to introduce a Delaware-type form of inter-jurisdictional competition into European company law.

Keywords: corporate law; labour law; regulatory competition (search for similar items in EconPapers)
JEL-codes: K22 K31 (search for similar items in EconPapers)
Date: 2006-03
New Economics Papers: this item is included in nep-eec, nep-law and nep-reg
Note: PRO-2
References: View complete reference list from CitEc
Citations: View citations in EconPapers (7)

Downloads: (external link)
https://www.jbs.cam.ac.uk/wp-content/uploads/2023/05/cbrwp323.pdf (application/pdf)

Related works:
This item may be available elsewhere in EconPapers: Search for items with the same title.

Export reference: BibTeX RIS (EndNote, ProCite, RefMan) HTML/Text

Persistent link: https://EconPapers.repec.org/RePEc:cbr:cbrwps:wp323

Access Statistics for this paper

More papers in Working Papers from Centre for Business Research, University of Cambridge
Bibliographic data for series maintained by Ruth Newman ().