The English floating charge and the conceptualisation of a French global security

Muriel Renaudin

Chapter 8 in Floating Charges in Comparative Perspective, 2025, pp 253-283 from Edward Elgar Publishing

Abstract: France does not recognise a true equivalent security to the English floating charge. Yet, several French law reforms have adopted some features of the floating charge, suggesting that French law is beginning to develop the conceptual foundations of a global security. A global security would bring many advantages, including the possibility for the debtor to charge all of their assets, thereby increasing access to credit. Adopting a global security would also significantly contribute to the rationalisation and modernisation of French law. The aim of this chapter is twofold. It contributes to a better understanding of the English floating charge by drawing out and analysing its key characteristics in order to identify possible functional equivalents in French law. It further discusses the laws of Mexico and Quebec, which adopted the concept of a global security and which may contribute to the conceptualisation of a French global security in the future.

Keywords: Commercial law reforms; Floating charge; Global security right; French law (search for similar items in EconPapers)
Date: 2025
ISBN: 9781035317134
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