Comments on the proposal for a Directive for the further harmonisation of insolvency law

The German banking industry rejects, above all, the introduction of a pre-pack procedure and a simplified liquidation procedure for micro-entities, which is intended in the light of an improvement of the Capital Markets Union.

The publication of the German statement with the same content has already taken place under 27 February 2023. 

Publication of a supplemented comment on the proposed directive, containing further comments on Article 2 q, took place on August 29, 2023

A further supplement to the comment on the proposed directive, which slightly modified the right of avoidance complex, was issued on 10 November 2023.