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

Abstract

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.