Three Worlds of Compliance or Four? The EU-15 Compared to New Member States


  • This article is part of a larger research project on the transposition and application of EU Directives in new member states funded by the Austrian Ministry of Science under the TRAFO programme for transdisciplinary research (for details see: «» and Falkner et al., 2008). Thanks to our collaborators Elisabeth Holzleithner, Emmanuelle Causse, Petra Furtlehner, Marianne Schulze and Clemens Wiedermann for their important input and to the Robert Schuman Centre for Advanced Studies at the European University Institute in Florence for hosting Gerda Falkner while she was writing her part of this paper. An earlier version was presented at the ECPR's 3rd Pan-European Conference on EU Politics, Istanbul, 21–23 September 2006. We would like to thank the panellists and our discussant Andrea Lenschow as well as Sylvia Kritzinger and two anonymous referees for their helpful comments.


Starting from the findings of an earlier compliance study covering the 15 ‘old’ Member States of the European Union, which identified three ‘worlds of compliance’, this article seeks to establish whether or not the new Member States from Central and Eastern Europe (CEE) represent a separate world of compliance. We present empirical findings from a research project on the implementation of three EU Directives from the field of working time and equal treatment in four CEE countries. The evidence suggests that the new Member States display implementation styles that are similar to a few countries in the EU-15. The expectation that the new Member States might behave according to their own specific logic, such as significantly decreasing their compliance efforts after accession in order to take ‘revenge’ for the strong pressure of conditionality, is not supported by our case studies. Instead, all four new Member States appear to fall within a group that could be dubbed the ‘world of dead letters’. It is crucial to highlight, however, that this specific ‘world of compliance’, characterized by politicized transposition processes and systematic application and enforcement problems, also includes two countries from the EU-15.