Comparative study on authentic instruments: National provisions of private law, circulation, mutual recognition and enforcement, possible legislative initiative by the European Union (United Kingdom, France, Germany, Poland, Romania, Sweden)

This study provides an in-depth and objective comparative analysis of the national provisions of private law and private international law in the field of authentic instruments with special focus on their mutual recognition and enforcement within selected EU Member States. The results of this comparative analysis serve as a basis for evaluating if a legislative initiative of the European Union in this field is worthwhile or necessary. For that purpose, the study contains some proposals on the legal basis and the form, as well as on the scope and the content, of a possible regulatory intervention by the European Union.