GARI Insight Report: Global Trends in Repossession and Restructuring – Part 2 28 July 2026

Watson Farley & Williams’ Global Aviation Resource Index (“GARI”), has become a core reference tool for analysing repossession, deregistration and restructuring procedures across 116 jurisdictions worldwide.

Following Part 1 which explored global repossession trends, we now look at some of the key data trends relating to restructuring procedures that can be derived from GARI. A key takeaway is that GARI is more than just a comparative dataset; it is a window into how restructuring systems actually behave under pressure across jurisdictions.

A Global Embrace of Rescue – With Mixed Results  

Across the 202 restructuring procedures captured by GARI, the majority (161 procedures) have the primary objective of preserving the debtor and its business. On paper, at least, rescue remains the global norm.

Practice tells a more uneven story. Only 46% of procedures (94) in the GARI data are classified as well-developed and consistently applied. In these systems, the framework is clear, with no material gaps in the relevant statutes or case law and courts exercise discretion predictably. These 94 procedures are largely concentrated in established restructuring jurisdictions such as the UK, the US, Australia, Canada and Singapore. All have long-standing insolvency regimes, experienced courts and restructuring tools that are regularly tested, providing a degree of certainty on the processes and outcomes.

Elsewhere, the picture is more fragmented. Many jurisdictions boast multiple restructuring processes but with differing levels of development and consistent application, indicating that restructuring law within those jurisdictions is not applied uniformly. Whilst some procedures are well‑established and predictably used, others may suffer from inconsistent court interpretation or lack sufficient case law. As a result, the reliability of restructuring outcomes in these jurisdictions may depend on the specific process used and the forum in which it is applied, rather than on the legal system as a whole.

At the other end of the spectrum, 29% of procedures (58) are classified as substantially untested. These tend to be found in emerging economies, such as some jurisdictions in Eastern Europe, Africa and the Middle East. These jurisdictions commonly have recently reformed insolvency systems or jurisdictions with historically low restructuring case volume. Of course, this does not indicate that a creditor may obtain a poor result from the usage of such a process, merely that the outcome will be less predictable for the time being at least.

Creditor Friendliness, the Cape Town Convention (“CTC”) and the Rule of Law

GARI’s creditor friendliness scores for a particular restructuring process assess a combination of factors: the strength of creditor rights, speed and cost of the procedure, procedural competence and rule‑of‑law compliance.

Of the 202 restructuring procedures reviewed:

• 42 score high for creditor friendliness. Of these, 81% are located in jurisdictions that have ratified the CTC and the average rule of law compliance score is a robust 83%; and
• 61 score low for creditor friendliness. Almost half of these (29) are found in jurisdictions that have not ratified the CTC and the average rule of law compliance score drops sharply to 32%.

The message is consistent with the findings in Part 1 of this report – ratification of the CTC by a jurisdiction, either separately or together with a high rule of law compliance, not only work together to be advantageous from a repossession perspective, but also demonstrate huge benefits in restructurings. When the CTC operates in conjunction with a broader ecosystem of strong courts, predictable enforcement and institutional experience, maximum benefit can be derived for creditors in restructurings.

A Different Dynamic for Debtors