On the Road to Anglo-Saxon Capitalism?: German Corporate Governance Regulation between Market and Multilevel Governance

Financial internationalization and European regulatory harmonization put the German corporate governance regime under pressure to move towards a market-oriented, Anglo-Saxon model. While International Political Economy approaches expect Anglo-Saxon standards to spread across national borders, Comparative Political Economy predicts persistent diversity. In our paper, we trace the patterns and driving forces of change in two areas of corporate governance regulation, namely internal governance and accounting. In accounting, processes of multilevel coordination entailed a high degree of convergence towards Anglo-Saxon standards and institutions. A much greater stability of the domestic institutional framework can be seen in the case of internal governance. While political economy approaches offer important insights for analyzing these changes, both fail to account for the different patterns of convergence and divergence in the two cases. Therefore, we argue in favor of a policy analysis perspective to capture the sectorally distinct interplay of forces that shape the processes of regulatory change