From Darkness to Light: A Comparative Study of Special Purpose Acquisition Companies in the European Union, the UK, and the US

Abstract

Abstract This article analyses the financial regulation of Special Purpose Acquisition Companies (‘SPACs’) in the European Union and SPAC reform in the UK against the main legal system where the SPAC originates: the US. I argue that the US and financial regulators in Europe have opposing views on SPACs, evidenced by the adoption of two different regulatory approaches. As opposed to a SPAC regulation by business or function and by enforcement in the US, the European Union and the UK are implementing a SPAC regulation by objectives, where general principles of company and financial law inform the SPAC legal discipline. This enormously enriches the SPAC current debate, and sheds new light on the subject.