Reform in Other Jurisdictions

Reform of the law of secured transactions is a subject of debate and interest all over the world.   Many jurisdictions are in the process of reforming their law, or have already enacted widescale reform. Some have opted for models along the lines of the PPSA scheme and others are adopting more limited reforms. Please click on the relevant jurisdiction on the right-hand menu for more information.

The first PPSAs

Originally, the Canadian and New Zealand PPSAs were modelled on Article 9 of the Uniform Commercial Code. These Acts have themselves become the model for reform in other jurisdictions, such has Australia.

You can also view an Outline of a typical PPSA scheme, presented at our recent Conference on Secured Transaction Reform in Other Jurisdictions by Professor Hugh Beale.

Other model laws

The UNCITRAL Legislative Guide on Secured Transactions has been a tool in recent reforms in Malawi and Ghana.

The Organisation of American States’s Inter-American Model Law on Secured Transactions formed  the basis of reform in Colombia, Costa Rica,  Honduras, El Salvador, and Mexico.

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