A Comparative Perspective on Loyalty- and Multiple Voting Shares: Regulatory Competition in the EU, Towards Where?

In this article, we analyse the growing regulatory competition between EU Member States regarding loyalty and multiple voting shares (MVS). We compare recent legislative developments in seven jurisdictions and examine their approaches to voting ratios, allocation criteria, majority thresholds, agenda limitations, and sunset provisions. Finally, we argue that two distinct models have emerged - ex ante regulation and ex post judicial review - and reflect on the legal uncertainty and reputational risks each entails.