主权债务——走向更复杂、更昂贵的资本结构？

Sovereign Debt–Towards MoreComplex and Costly CapitalStructures? Lazard Policy Paper June 2026 Abstract.The liability side of a sovereign’s balance sheet has historically been simple,certainly as compared to banks and, to a large extent, corporates. This is changing, especiallyforemerging and frontier-market economies.Their capital structures are becomingincreasingly complex because of an intricate and largely implicit hierarchy of claims, and Two consequences are likely. First, a future impact on the overall cost of debt: absent clarityon the hierarchy of claims, which inevitably increases the loss given default for the least-seniorcreditor, and unless the shock-absorptive virtue of contingent instruments outweighs theircomplexity andunpredictability, the odds are that countries will pay a complexity/uncertaintypremium. Second, an impact on markets’ efficiency and restructuring feasibility: an unmapped, Introduction For most of the post-Brady era,the sovereign capital structure could be described in asentence: plain debt and no equity-like instruments. The hierarchy was legible, multilateralinstitutions at the top by convention, Paris Club bilateralsand commercial banks below themat broadly equivalent rank. Creditors coordinated well through the Paris and London Clubs, The simplicity of sovereign capital structure is eroding, and the central question of this paperis whether it is changing for the better. We argue that it is not, unless the changes are actively We proceed in two parts: first, why the capital structure of governments is becoming more 1.Why is the capital structure of governments becoming morecomplex? 1.1The explicit and implicit hierarchy of claims The international community has spent an inordinate amount of time over the last five yearsdebating what “Comparability ofTreatment” should mean in the context of sovereign debtworkouts. The debate has produced protracted processes and a wave of state contingent or Yet, in the meantime, the debt structure has become more unequal rather than less. A nominally“senior” unsecured creditor increasingly finds itself subordinated in substance. It is worth setting out the new, tentative and unofficial ranking of claims that applies when anissuer cannot repay, from the most protected claim to the least. 1.TheInternational Monetary Fund: top of the list,based on the analogy with a centralbank as a last resort andprotectedlender todomestic banks in distress. 2.Multilateral development banks with undisputed preferred creditor status(PCS),e.g. the World Bank or the African Development Bank. This is not bullet-proof protection.In practice it means that if these institutions stand ready to provide net financing at 3.Commercial creditors guaranteed by anAaa multilateral development bank.Ifanything goes wrong, they are repaid in full and on time. The guarantee makes them, inpractice, one of the most protectedclaimantsin the structure. This is true for the portionof the claim that is guaranteed, but PCS does not extend to partially-guaranteedstructures as evidenced by the case of Ghana’s 2030 Eurobond(seeLazard’s policy brief 4.Collateralised creditors.Their effective seniority is a function of the adequacy andactionability of the collateral. Such collateral usually consists of an asset of theborrowing government.A collateralized structure can be used by bilateral or commercialcreditors. In the case of recent sovereign total return swaps(TRS), it oddly consists of aliability of the government:indefault,the sovereign hands over more of its own debt to 5.MDBs with strong but not water-tight preferred creditor status.Typically,regionalMDBs with no universal membership, which may on rare occasions be caught in arestructuring, usually because of their near-commercial financing terms. Even so, their 6.Unsecured creditors bilateral and commercial lenders (loans and bonds).Theresidual claim, and the one that absorbs the consequences of everyone else’s protection. Much of the comparability-of-treatment debate sets these last two categories atloggerheads. In practice, however, a large share of the debt involves creditors who Note that this ranking is bound to become more significant over time, for a structuralreason. One of the most popular policies among MDBs is to offer guarantees to commerciallenders, in order to attract them into financing developing countries at affordable conditions.This is a powerful way to multiply development finance. But it also enlarges the protectedportion of thedebtstock and rigidifies the capital structure.Indeed, when commercial lenders A previous Lazard paper in this series addressed this “preferred-creditor-status glut“issue:not everyone can enjoy a preferred status whenthere are manyprivileged creditors and therepayment capacity is severely constrained(Lazard’s policy brief from June 2025: ThePreferred Creditor Status glut–The search for loss absorption in Africa).To be sure, the Contested ranking.The largest new cred