Harmonization of the structure of audit firms: incorporation in the UK and Germany

The Eighth EU Council Directive addresses the harmonization of the conditions for the approval of auditors. This paper deals specifically with the approval of incorporated audit firms, which is regulated by Article 2 of the Directive, and with the extent to which the Eighth Directive has improved de jure harmonization of the rules for incorporated audit firms between UK and German law. The development of Article 2 from the proposal to the final version of the Directive is studied, as is the implementation of Article 2 into UK and German law and the reasoning behind the choices made by both Member States in this process. Although considerable changes were made to the laws of both countries, little greater de jure harmony was achieved.