4. Enforcement rules: comparative law in the main European Union countries

It is beyond the scope of this article to describe in detail the national regulations governing the performance of public contracts in the member states of the European Union. On the one hand, they are difficult to access in French, and on the other, they are scarcely available in the embassies of the countries concerned. They are also subject to change, due to the absence of a European directive on the subject.

It should be noted that the country whose law is closest to French law, Belgium, has updated its regulations in this area with a Royal Decree dated September 26, 1996, laying down general rules for the execution of public contracts and public works concessions, and including a highly elaborate set of general specifications in an appendix.

Germany has VOB/B – Allgemeine Vertragsbedingungen für die Ausführung von Bauleistungen (general...