The power of implementers: A three level game model of compliance with EU policy and its application to cultural heritage

In this article we focus on compliance with European Union (EU) directives in the context of multilevel governance. Policies specified by EU directives move through different decision-making stages before they are implemented. We integrate these decision-making stages and actors in a game-theoretical model aiming to explain implementation in the EU setting. Practice and organizational literature findings already indicate that in this setting formal and informal policies can differ considerably. Our model shows that such a divergence is the result of the interactions of three sets of actors at different levels. We illustrate the main findings of our model with cases of transposition and implementation of the EU rules regarding cultural heritage in the European Union. Based on our analysis, we suggest that EU policy implementation is best understood as a patchwork of domestic processes in which implementing actors affect outcomes within limits set by national and European decision-makers.The politics and administration of institutional chang