7. Transposing the Package: A Cross-Country View

The chapter compares the implementation of MiFID II, along with the enactment of MiFIR, across the largest EU economies (Germany, Spain, France, Italy) plus the United Kingdom, whose exit—almost surely effective on 29 March 2019—raises several concerns over the destiny of Europe’s financial hub, especially in terms of its accessibility for EU-based investment firms. Before discussing each country’s attitude toward implementing the Package, we draw up a short overview of its macroeconomic and financial fundamentals. We underline the connection between the different characteristics of financial markets in a given country, along with the response to the GFC, on the one hand, and the positions held in respect of Package-related issues, on the other. In fact, EU Member States have dealt with said legislation in a variety of manners: some have pursued a copy-out approach; some have hardened the discipline of certain issues, on the edge of gold-plating; some have tried to soften it by listening to many of the industry’s complaints. Although maximal harmonisation is still far away, we highlight similarities to be enhanced and differences to be possibly overcome for the purpose of levelling the playing field and bettering the Single Market for investment services.