当前解决涉及私营部门债权人的主权债务的国际架构盘点

IMF staff regularly produces papers proposing new IMF policies, exploring options forreform, or reviewing existing IMF policies and operations. The following document hasbeen released and is included in this package: TheStaff Reportprepared by IMF staff and completed on September 19, 2025 forthe Executive’s Board consideration on October 3, 2025. The report prepared by IMF staff and presented to the Executive Board in an informalsession on October 3, 2025. Such informal sessions are used to brief ExecutiveDirectors on policy issues. No decisions are taken at these informal sessions. Theviews expressed in this paper are those of the IMF staff and do not necessarilyrepresent the views of the IMF's Executive Board. The IMF’s transparency policy allows for the deletion of market-sensitive informationand premature disclosure of the authorities’ policy intentions in published staff reportsand other documents. Electronic copies of IMF Policy Papersare available to the public fromhttp://www.imf.org/external/pp/ppindex.aspx International Monetary FundWashington, D.C. A STOCKTAKING OF THECURRENTINTERNATIONALARCHITECTURE FOR RESOLVING SOVEREIGN DEBTINVOLVINGPRIVATE SECTOR CREDITORS EXECUTIVE SUMMARY There have been major developments in the global economyand sovereign debtmarketssincethe Fund’s laststocktakingin 2020.TheCOVID-19 pandemicnecessitated extraordinary fiscal support to economies, leading to a significant increasein government deficitsand debt.General government debt levels have stabilized, butrisks remain elevated.Financing flows from private creditors to sovereigns declinedsignificantly after 2021, thoughaggregate flows had recovered by 2024.Domesticsovereigndebt levels have increased andwithin the official sector there has been a shiftfrom bilateral to multilateralfinancing.There has been an increase in the use of creditenhancements, such ascollateral (or collateral-like arrangements)andguarantees. Recentsovereigndebt restructurings have taken longer compared to the 2020 stocktaking.Recent restructurings have been more complex, although therestructurings have delivered substantial debt relief so far.Restructuring of sovereigndomestic debt continues to involve complex macro-financial trade-offs.Many of therecentsovereign debtrestructurings required debt relief from both official and privatecreditors, with a sequential approach that has contributed to lengthy outcomes.Coordinationbetween official sector creditors and private sector creditors is becomingmore agile with experience, though more progress is needed. In particular, officialcreditors have committed to enhanced transparency and information sharing. Whilethese are positive developments, there isroom for further improvements. The contractual framework fortheresolutionofprivately held sovereign debthasevolved further. Progress has been made in certain areas,althoughgaps stillremain.Specifically: •The contractual framework remains effective for bonded debt. The restructuring ofinternational bonds has been effectively facilitated by enhanced collective actionclauses (CACs),delivering very high creditor participation rates in bondrestructurings and only one case of a holdout. There continues to be a very highuptake of enhanced CACs in new issuances under English or New York laws,covering a vast majority of all international bond issuances, although not under thelaws of other jurisdictions. •The contractual framework has been less effective in resolving non-bonded debt. Certaincontractual provisions, such as majority voting provisions,can be helpful, but have not beenadopted and are not a comprehensive solution. In addition, better coordination and informationsharing among creditors appears necessary. •Collateral or collateral-like arrangements have hampered restructurings in a few cases.Policyrecommendations previouslydiscussed by the Fundon these issuesremain appropriate. •The contractual framework has been evolving.Certain contractual features such as state-contingent debt instruments, loss reinstatement clauses and most favored creditor clauses haveemerged or seen increased use. These clauses can help facilitate and speed up restructurings,but they present both costs and benefits, requiring acareful and tailored approach to their use. •In recent debt restructuring cases, creditors have pushed for the inclusion of informationprovisionobligationsin new instruments. Such clauses are one potential tool for improving debttransparency, but they impose a cost on the resources and capacity of the sovereign, and shouldbe carefully tailored.Both sovereign issuers and creditors have roles to play in improving debttransparency. •Statutory approaches have not changed since the 2020 stocktaking, although proposals areunder consideration in some jurisdictions. Existing legislative tools in the UK, Belgium andFrance are still in place but have not been used. New legislative initiatives have been proposedin key jurisdictions.While there could be cer