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COMPARATIVE STUDIES

G20+ Data Set

Our comparative analysis of insolvency regimes examines different jurisdictions across the globe. Starting point are the G20 countries, which are economically important, geographically and culturally wide-ranging, and represent various legal systems. Further countries complete the sample to even extend that range. The goal is to quantitatively compare these jurisdictions by means of readily quantifiable key parameters that underpin the design of insolvency regimes. While some factors apply to both corporate and consumer insolvency procedures – such as opening reasons or stay – others are tailored to the specifics of each debtor group. Within each debtor group, especially relevant chosen factors play a central role in more in-depth analyses. The empirical data helps us to reconstruct and deepen our understanding of key normative decisions in legal insolvency designs. To contextualize quantitative findings, we complement them with qualitative analyses of normative insolvency principles. We visualize the data to open new perspectives on the chosen factors. Our goal is to categorize normative paradigms and to identify distinct concepts of debt. These insights may not only shed light on leverage points for reflexivity in insolvency law but can also serve as a starting point for a sustainable debt framework.

Project Funding

Funded by the European Union (ERC, RESOLVENCY, No. 950427). Views and opinions expressed are, however, those of the author(s) only and do not necessarily reflect those of the European Union or the European Research Council Executive Agency. Neither the European Union nor the granting authority can be held responsible for them.