Comparative analysis between Malta and Romania from an institutional architecture perspective : governance of supervision

Abstract

This dissertation examines how institutional architectures for financial supervision shape independence, accountability, and effectiveness, using Malta and Romania as comparative case studies. While European Union (EU) directives and international standards provide common frameworks, national institutional design continues to influence supervisory outcomes. By contrasting Malta’s single integrated supervisor with Romania’s multi-agency model, the study explores how governance arrangements affect autonomy, accountability, and regulatory reliability. A qualitative methodology was employed, combining twelve semi-structured interviews with officials from supervisory authorities and analysis of secondary sources including legislation, annual reports, and international evaluations such as IMF FSAPs and MONEYVAL reviews. Thematic analysis (Braun & Clarke, 2006) was used to identify patterns and interpret them through institutional theory and regulatory governance literature. Findings show that both Malta and Romania have formally aligned with EU and international standards but face persistent challenges. Malta’s integrated model promotes efficiency but increases exposure to political and reputational pressures, while Romania’s fragmented framework enables specialisation but suffers from coordination gaps and fiscal constraints. The study concludes that institutional architecture matters, but effectiveness depends less on structure than on resources, governance culture, and international engagement. Reforms should prioritise fiscal independence, inter-agency cooperation, and transparency to sustain credibility. The research contributes to debates on regulatory governance by providing evidence from small-state and transitional EU contexts, while also offering practical insights for policymakers seeking to strengthen supervisory governance across the Union.