Debt Relief: Why Scotland Has a Different System from England

11th July 2026

A recent announcement from the UK Insolvency Service highlighted reforms designed to make Debt Relief Orders (DROs) more accessible in England and Wales. It is welcome news for people struggling with problem debt, but it also raises an important question for Scottish readers.

Does Scotland have the same system?

The answer is no.

Although debt problems affect people across the UK, Scotland has its own insolvency laws and its own debt relief schemes. Instead of the Insolvency Service administering Debt Relief Orders, Scotland's system is overseen by the Accountant in Bankruptcy (AiB), an executive agency of the Scottish Government.

A Different Approach

Debt Relief Orders were introduced in England and Wales to provide a simple and relatively inexpensive way for people with low incomes, few assets and limited debts to obtain relief from debts they cannot realistically repay.

Scotland chose a different route.

Its nearest equivalent is known as the Minimal Asset Process (MAP). It is a simplified form of bankruptcy designed for people with very limited assets, little disposable income and relatively modest levels of debt.

Like a Debt Relief Order, the aim is to give people who have no realistic prospect of clearing their debts an opportunity to make a fresh start while ensuring the process is properly regulated.

More Than One Solution

One feature of the Scottish system is that it offers several different statutory debt solutions depending on individual circumstances.

Someone who can afford to repay their debts over time may be better suited to the Debt Arrangement Scheme (DAS). Under DAS, affordable repayments are agreed while interest and most additional charges are frozen, allowing debts to be repaid in an organised way without the pressure of continued enforcement action.

Others may choose a Protected Trust Deed, which is broadly similar to an Individual Voluntary Arrangement (IVA) used in England and Wales. Regular affordable payments are made for an agreed period, after which any remaining qualifying debt is normally written off.

For those with almost no assets or income, the Minimal Asset Process provides another route to debt relief.

Why the Difference?

Many areas of law are devolved to the Scottish Parliament, and insolvency is one of them. Over many decades Scotland has developed its own legal framework rather than simply copying arrangements used elsewhere in the UK.

As a result, newspaper articles and television reports about changes to Debt Relief Orders often do not apply in Scotland, even though they are presented as UK-wide financial news.

This can cause understandable confusion.

Lessons from the Latest Reforms

The recent reforms announced for England and Wales are intended to widen access to debt relief by reducing barriers for people in financial difficulty.

That naturally raises the question of whether Scotland should also review its own arrangements to ensure they remain fit for purpose.

Debt levels, household finances and the cost of living have all changed significantly over recent years. As economic conditions evolve, every debt relief system needs to be examined regularly to ensure it strikes the right balance between helping people recover financially while protecting creditors and maintaining confidence in the system.

An Important Reminder

Anyone facing serious debt problems should seek independent advice before deciding which option is appropriate.

Scotland's debt solutions differ from those available elsewhere in the UK, and the right choice will depend on income, assets, housing circumstances and the amount owed.

The Announcement for England 11 July 2026
Insolvency Service review confirms reforms have widened important access to debt relief

England
Insolvency Service

Scotland
Accountancy in Bankruptcy