Comments
9th of November 2023
Additional Comments on the further harmonisation of insolvency law

The German banking industry committee 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.
Added the need for correction of the definitions under Article 2q. (Comments from 29. August 2023) Furthermore, the statement on the right of avoidance was slightly modified.
The publication of the comments of 16 March 2023 on the European Commission's proposal for a directive on the harmonization of insolvency law to improve the Capital Markets Union can be found in the link section.
Comments on further harmonisation of insolvency law
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