The regulatory framework of consumer over-indebtedness in the UK, Germany, Italy, and Greece: comparative profiles of responsible credit and personal insolvency law

This article compares and analyses the regulatory framework addressing consumer over-indebtedness in the UK, Germany, Greece and Italy against the policy and law of the European Union.The ultimate goal is to identify good practices and major shortcomings that the EU should attend to repair failures that an uncoordinated nature of national regimes could generate in a common market and its side effects, as well as the economic and social cohesion of its citizens.The paper concludes that if Member States to some extent have harmonized their preventive measures – yet with differences that need attention – the cure of overindebtedness remains to individual but uncoordinated national initiatives that expose an under-resourced strategy at EU level.