2.3.5 Comparison on the basis of the legal variables

The examination, analysis and comparison of the three different legal regimes will be conducted on the basis of four key characteristics of the tailor-made legal forms for social enterprises, duly referred to as ‘legal variables’. These key characteristics were retrieved from the European definition for social enterprises, namely: (i) the social purpose; (ii) the participatory governance; (iii) the accountability/responsibility; and finally (iv) the financial structure (see Sub-section 2.2). The legal variables are explained in greater detail in the Sub-sections that follow. Additionally, we elaborate upon the national provisions pertinent to the four legal variables by means of doctrinal analysis. Initially, the findings from the doctrinal analysis will reveal the content of the legal rules regulating each of the four legal variables. We then compare the findings regarding the substance of these rules to chart the state of development of social enterprises in each national legal context.