@misc{9232417,
  abstract     = {{This thesis examines whether Directive (EU) 2019/2121 ('Mobility Directive') reduces legal fragmentation in the field of cross-border conversions. Using a doctrinal and comparative legal methodology, it analyses the EU framework governing cross-border conversions and compares its implementation in Germany and Denmark.

The analysis focuses on three areas in which the Directive leaves Member States discretion: procedural requirements, creditor protection, and abuse control. While the Directive establishes a common procedural framework and enhances legal certainty, significant differences remain at national level. Germany adopts a more formalised and court-centred approach, whereas Denmark relies more heavily on administrative procedures and procedural flexibility. These differences demonstrate how national implementation choices continue to shape the practical operation of cross-border conversions.

The thesis concludes that the Mobility Directive represents a significant step towards harmonisation but does not eliminate legal fragmentation entirely. Rather, it reflects the broader nature of EU directives, which seek to balance harmonisation with Member State autonomy.}},
  author       = {{Hanker, Jannike Nele}},
  language     = {{eng}},
  note         = {{Student Paper}},
  title        = {{Harmonisation or Fragmentation? Cross-Border Conversions under the Mobility Directive: A Comparative Analysis of Its Implementation in Germany and Denmark}},
  year         = {{2026}},
}