This report aims to analyse how European accounting standards (European System of Accounts ESA-95) are interpreted and applied to the public healthcare sector, from the standpoint of comparative law. Specifically, the study focuses on the application of ESA-95 to healthcare centres in the United Kingdom, France and Germany, with the aim of reaching useful conclusions for the Public Companies and Consortia (EPIC, for their initials in Catalan) in the Catalan Public Healthcare System.

The study falls under the framework of the research project entitled "Public-private partnership as an alternative for funding public works and services" (DER 2009-10470, Ministry of Science and Innovation).