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Implementation has often been described as a key weakness affecting European Union (EU) counter-terrorism. However, this view is often adopted as a given and there has not been so far a systematic examination of the degree to which this represents an obstacle to the effectiveness of the EU response. This paper aims to contribute towards this goal through the use of primary sources in the study of the legal transposition of counter-terror instruments into national law, a key stage in the implementation process. It shows the presence of major implementation delays in this policy sector but, importantly, also significant cross-national variation with regards transposition failure associated with the administrative endowment of the individual member states. Furthermore, the mechanisms deployed by the Union to encourage a fluid implementation of European measures are critically evaluated and the potential impact in the process of the institutional transformations brought about by Lisbon is also examined. [ABSTRACT FROM AUTHOR]