"Single Rulebook" but Different Implementation? – Financial Regulation in the European Union Member States

The EU is one of the world's largest financial jurisdictions and therefore an important player in the regulation of the international financial system. In response to the Global Financial Crisis in 2008, the EU adopted a series of legislative acts to regulate the financial sector. One of the key legislative acts was the "Single Rulebook", which lays down capital requirements for banks, ensures better protection for depositors and regulates the preventions and management of bank failures. However, the regulation of banks and financial markets by the "Single Rulebook" is decisively influenced by decisions at the national level as well. Since the "Single Rulebook" directives leave a certain degree of national flexibility, the Member States' use of this discretion leads to a legal variety in the regulation of financial markets. This diversity in implementation considerably affects the effectiveness of European financial market regulation. With my article, I would like to contribute to the study of differentiated policy implementation in the EU. Theoretically, the paper proposes a typology to analyse and understand the role of government bureaucracy in transposing EU directives at the member state level. The typology assumes that both formal and informal structures affect public decision-making behaviour at the stage of transposition. Empirically, the article follows two objectives. First, based on case studies in four European countries (Germany, France, Denmark, and Netherlands), it will be examined whether the patterns of administrative behaviour described in the typology actually exist with regard to the transposition of directives. Second, in the countries under consideration, the article analyses the transposition of the "Single Rulebook", in order to achieve a more comprehensive understanding of the regulation of banks and financial markets within the EU. It will be examined to what extent the different administrative patterns have an influence on the transposition of the directives.