The paper sets out the legal foundations of an incremental approach to sovereign debt restructuring. As the political momentum that would be necessary to adopt an international treaty governing sovereign debt workouts is currently lacking, the incremental approach explores the possibility of...

The first two decades of the twenty-first century witnessed a series of large-scale sovereign defaults and debt restructurings, in which sovereigns struggled to negotiate with recalcitrant bondholders, particularly hedge funds. Also, the outbreak of the COVID-19 pandemic in 2020 heralded a bleak...