The concept of policy style provides a useful lens through which policy divergence between the UK and EU can be understood. In initial studies on Germany, France and the UK, national jurisdictions were theorised to have developed distinct policy styles identified as rationalist consensus, concertation and Westminster (Richardson, 1982). This framework has since been expanded to encompass additional states (Tosun and Howlett, 2022). Zahariadis et al. further extended the framework, moving beyond policymaking to include regulation and administrative traditions (2021:47).

Essentially, policy style addresses how decisions are made, the involvement of various actors in decision-making, and how problems are approached within different institutional contexts. Richardson theorised that France, the Netherlands, Norway, Sweden, and the UK had tendencies towards either anticipatory or reactive decision-making (1982). He also examined whether decision-making was conducted through consensus-based bargaining through organised societal actors or by imposed top-down by governments. According to this framework, Germany is characterised by a 'rationalist consensus' style (anticipatory and consensual), the UK follows a 'negotiation' style (reactive and consensual), France adopts a 'concertation' style (anticipatory and impositional), and the Netherlands is marked by a 'negotiation and conflict' style (reactive and consensual within a transitional model).

Post-Brexit, the EU has witnessed a growing EU reliance on protectionist policies within its digital market strategy increasingly reflecting a blend of French and German policy approaches to digital market regulation. (Farrand and Carrapico, 2022:446). These include trade restrictions, investment screening, and standardisation requirements, as well as limitations on foreign investment, measures such as export controls, foreign direct investment (FDI) screening, and e-privacy regulations that limit the participation of non-EU firms in European digital supply chains (Akcali Gur, 2022: 6 - 9).

The UK instead favours trade openness and the liberalisation of data flows across borders which is evident in the Media Act, proposed Data (Use and Access) Bill, Online Safety Act, and emerging discussions surrounding AI regulation. The UK has focused on creating an adaptable regulatory framework that evolves alongside technological advancements and market shifts involving greater stakeholder involvement. This is reflected for example in the Digital Markets Unit (DMU)’s approach to increasing the use of AI.

We explain regulatory divergence between the EU and UK taking policy style as an explanatory tool. The new Labour government has marked a return to the UK’s reactive and consensual policy style. The EU is demonstrating mix of German 'rationalist consensus' and French 'concertation' styles.

In 2024 the European Union approved Regulation (EU) 2024/1083 of the European Parliament and of the Council of 11 April 2024 establishing a common framework for media services in the internal market and amending Directive 2010/13/EU (European Media Freedom Act), the so called European Media Freedom Act (EMFA). This is a groundbreaking regulation as it recognises media freedom and pluralism as crucial for democracy and the rule of law within a well-functioning internal market. The Regulation also reforms the public governance of the media sector and establishes a European Board for Media Services (EBMS), to ensure that the EMFA and other relevant Union media law (such as the Audiovisual media services directive) are consistently applied across the EU. The Board is envisaged as an independent body gathering national regulatory authorities or bodies and coordinating their actions. The Article will delve into the nature of the EBMS, its tasks, the challenges it faces when it comes to its independence and effectiveness. The Article will also focus on the role of the EBMS in the enforcement of the EMFA, also exploring the interaction and potential regulatory overlaps of the EMFA with with the Digital Services Act and of the tasks of the EBMS with those of the Digital Services Coordinators and the European Board for Digital Services, established by the same DSA.

In 2024 the EU adopted Regulation 2024/1689 laying down harmonised rules on artificial intelligence (the Artificial Intelligence Act). The AIA aspires to foster responsible and trustworthy Al development and use in line with the Union's values laid down in Article 2 of the Treaty on European Union. Based on a risk-based classification approach, it lays down requirements for Al developers and deployers and bans particularly harmful uses of Al. It also establishes an intricate governance model for the implementation and enforcement of the rules enacted. Besides requiring the Member States to designate distinct national authorities for supervising the application of the rules introduced, the AIA creates a European Al Office within the European Commission to oversee implementation, with a focus on general level Al models and systems, Al regulatory sandboxes, joint enforcement and global Al governance. It also provides for a European Al Board to ensure coordination and consistency in implementation, and sets up an Advisory Forum for the provision of technical expertise and a Scientific Panel tasked with offering scientific advice. This paper delves into the governance structure of the AIA. It studies the nature and composition of the bodies involved, and examines their mission, tasks, safeguards for independence and impartiality, their interaction and avenues for collaboration with stakeholders and a broader set of regulators, agencies, standardisation entities and other bodies at national and supranational levels. In doing so, the paper aspires to shed light on the ability of the AIA governance model to genuinely uphold the Union's values.

The last decade has seen the adoption of several legislative acts focused on the cybersecurity perspective: from the Cybersecurity Act (Regulation 2019/881) to the NIS 2 Directive (Directive 2022/2555), the Digital Operational Resilience Act (Regulation 2022/2554), the Cyber Resilience Act (Regulation 2024/2847) and the Cyber Solidarity Act (Regulation pending final approval). Their structure and organisation are convergent and rely strongly on creating a set of European and national authorities in charge of tackling the risks and challenges that emerge from an increasing number and impact of cyber threats. However, this structure, on the one hand, partially overlaps with some competencies already covered by pre-existing national authorities, such as data protection authorities. On the other hand, it distinguishes between monitoring functions across allocated pre- and post-market availability of services and goods, increasing complexities and coordination. This contribution maps the roles and functions of the independent administrative authorities whose creation has been triggered by the recent cybersecurity legislation highlighting the potential gaps and overlaps that emerge looking at the wider digital market perspective.