英德两国在欧洲资本市场中具有重要地位,其交易所和监管法律在世界上也颇具影响。随着欧盟一体化的加强,其监管的法律框架也在不断演进。本文通过对这两国资本市场不同的法律框架比较研究,对我国正走向规范化的资本市场法律体系有所借鉴。 Britain and Germany have important positions in European capital markets, and their exchanges and regulatory laws have also exerted influence in the world. With the strengthening of EU integration, the regulatory legal framework is also evolving. Through comparative study of the different legal frameworks of the capital markets in these two countries, this article draws lessons from our country’s legal system that is heading towards a standardized capital market.