This study aims to examine the historical development of independent regulatory agencies in Türkiye and the United States, their establishment reasons, and the similarities and differences in their authority and functional structures from a comparative perspective. Türkiye represents the Continental European tradition, while the United States reflects the Anglo-Saxon model; they were chosen for comparison because their regulatory agencies differ in principles, independence, and legitimacy.In this study, which is based on the literature review method, the rise of the regulatory state approach and the emergence of independent administrative authorities are first discussed within a theoretical framework. Subsequently, the establishment rationales and legal frameworks of the institutions in both countries are compared; sample-based analyses have been conducted through key institutions such as SPK, RTÜK, BTK, the Competition Authority, and BDDK in Türkiye, and the SEC, FCC, FTC, FED, OCC, and FDIC in the United States. Finally, criticisms directed at regulatory agencies in both countries—such as issues concerning de facto independence, lack of financial autonomy, and weaknesses in institutional capacity—are discussed from a comparative perspective. In the conclusion section, legal improvements, the strengthening of internal audit mechanisms, and the promotion of transparency principles are proposed to enhance regulatory effectiveness.
Zengen et al. (Thu,) studied this question.