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Comparative Studies

We compare insolvency regimes of thirty different jurisdictions across the globe. The selected countries are economically important, geographically, and culturally wide-ranging and represent various legal systems. The goal is to quantitatively compare these jurisdictions by means of readily quantifiable key parameters that coin the design of insolvency regimes. While some factors apply to both corporate and consumer insolvency procedures – such as opening reasons, actors or stay – others are tailored to the specifics of each debtor group. 

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. 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.

Funded by the European Union (ERC, RESOLVENCY, 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.