The United Kingdom

Applicable law

Insolvency Act 1986 (the Insolvency Act) and the Insolvency Rules (England and Wales) 2016 (the Insolvency Rules as amended in 2017) governing liquidations, administrations and company voluntary arrangement (CVA) including a stand-alone moratorium process (introduced by the Corporate Insolvency and Governance Act 2020)

Companies Act 2006 (the Companies Act) containing rules in relation to schemes of arrangement (schemes) and pre-insolvency restructuring plans (introduced by the Corporate Insolvency and Governance Act 2020)

Cross-Border Insolvency Regulations 2006 (SI 2006/1030) (CBIR) implementing the UNCITRAL Model Law on Cross-Border Insolvency in the United Kingdom and governing rules for the recognition of foreign insolvency proceedings.

NB: Please note that the provisions above are mostly applicable to companies. Consumer insolvency is delegated, so the laws in England, Scotland and Northern Ireland are different.

Consumer bankruptcy is indeed a devolved matter in the United Kingdom. Separate regulation is made for indebted individuals by the three legal jurisdictions of (1) England and Wales, (2) Scotland and (3) Northern Ireland. 

(1) The rules in England and Wales are contained in the Insolvency Act 1986 (as amended), which provide for a range of procedures: debt relief orders, individual voluntary arrangements and bankruptcy, while, under section 112, County Court Act 1984, administration orders for individual debt repayment can be made available. 

(2) The law in Northern Ireland is similar, given the extension to the province of the above measures by statutory instrument. 

(3) In Scotland, the Insolvency Act 1986 also makes available bankruptcy (with certain differences respecting local law and procedure). However, other procedures have also been introduced: protected trust deeds under the Bankruptcy (Scotland) Act 1985, debt arrangement schemes under the Debtors (Scotland) Act 1987 and, at a stage prior to any of the above procedures being initiated, the moratorium under the Bankruptcy and Debt Advice (Scotland) Act 2014.

Additional resource
How the UK has implemented Directive (EU) 2019/1023 even though the UK later exited the EU on 31 December 2020 (as part of the Joint Project between INSOL Europe and LexisPSL on the implementation analysis of the Directive (EU) 2019/1023 in the EU Member States - as at 20/04/2022)

Update: April 2023

Souce: Paul Omar, INSOL Europe Research Coordinator