The Design of Regulatory Institutions in the European Union

In this paper we analyse the manner in which the regulatory function is discharged in five European countries for the telecommunications, electricity and gas industries. For each case we describe the past, current and foreseeable regulatory arrangements, and compare the different country scenarios and the respective degree of compliance with EU directives and recommendations. We also analyse each case and the current EU proposals in the light of existing regulation literature. Our main conclusion is that, amongst EU countries, the*UK is a distinctive case, since its current dispositions are well beyond those approved at the EU level. Independent regulation of public utilities is virtually non-existent in all the other countries studied in this paper.N/