Title Pending 93856

This article examines the implementation of Directive (EU) 2020/1828 on representative actions in Austria and Germany. Although the legal systems are often perceived as closely aligned, significant differences emerge in their approaches to collective redress. Austria’s traditionally pragmatic and flexible litigation framework—characterised by its assignment model and openness to third-party funding—contrasts with Germany’s more individualistic and restrictive procedural traditions, shaped by historical resistance to collective actions. The paper highlights how each jurisdiction transposed the Directive into national law, assessing legal innovations, institutional structures, and procedural challenges. Special attention is given to the political and cultural influences shaping these legal developments and the practical implications for access to justice, particularly in the evolving landscape of legal tech and platform-based litigation. The study briefly contextualises the Belgian implementation as a comparative touchstone.