Abstract

The article discusses issues connected with implementation of the Concession Directive in French, British and German law. The EU regulations were transposed to those legal orders as scheduled. It has been noted that in France a special model of contracts concluded by public entities, so-called administrative contracts have been created and new legal regulations for concession contracts have been discussed. The article also outlines the provisions contained in the British act concerning concession contracts for construction works and services emphasizing those provisions which have not been copied from the Concession Directive. The provisions implemented in the German legal order have been analysed, and the analysis has been preceded by comments concerning centralization of public procurement regulations.