Payment Orders were originally introduced in the CPC as a fast track route for creditors holding a financial instrument, such as a letter of credit or cheque, to obtain judgment against their debtor for what is a simple and indisputable debt. Payment Orders were rarely issued by the onshore UAE courts. In 2018, Cabinet Resolution No 57 of 2018 (the “2018 Cabinet Resolution”) significantly expanded the scope of application of Payment Orders by extending them to all admitted debts rather than simply those arising out of financial instruments only.

It has been suggested that Ireland improperly transposed the Employer’s Insolvency Directive into Irish Law by adopting a definition of “insolvency” which requires an actual winding up order (or a resolution of voluntary winding up to be passed) before an employee can have access to the Insolvency Fund, a Government payment scheme which provides for the payment of certain employee entitlements, in the event of the insolvency of their employer.