The Indonesian Supreme Court has reinstated the right of secured creditors to file a bankruptcy and suspension of payment (Penundaan Kewajiban Pembayaran Utang or PKPU) process.

Lock-up agreements typically involve the company's creditors committing in advance to vote at the relevant class meeting in favour of the contemplated scheme. Lock-up agreements serve an important commercial purpose of either securing support or giving an indicator as to likely support for the scheme before the parties incur the time and expense in finalising the negotiation process of the scheme.

The automatic stay under the version of the UNCITRAL Model Law on Cross-Border Insolvency adopted by Singapore ("Singapore Model Law") is an accessible and powerful tool for protection under the Singapore restructuring regime for non-Singapore debtors facing enforcement action in Singapore. Non-Singapore debtors subject to restructuring or liquidation cases outside Singapore may obtain protection from creditor action in Singapore through the application of the Singapore Model Law, thereby facilitating the debtor's ability to restructure.