The article compares independent regulatory agencies (IRAs) for markets in France and Britain. It relates the case to broader debates about the extent to which one regulatory state has spread across Europe, breaking sharply with previous institutions and policies, or whether different countries representing different ‘varieties of capitalism’ have followed distinct adjustment paths with strong continuities with the past. Looking at network industries, it argues that IRAs in France have spread to a similar extent to Britain. This represents a sharp change for France and supports the regulatory state hypothesis. But, when the strategies, behaviour and relationships of IRAs and governments are examined, important differences are seen across the two nations and strong continuities are found within France, showing that similar regulatory institutions can be adopted for different reasons and operate in diverse ways across nations. Indeed, French policy-makers have been remarkably successful in adapting to new conditions. State forms and instruments may have altered but an activist industrial policy is alive and well in France
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