Bankruptcy in the United Kingdom is divided into separate local regimes for England and Wales, for Northern Ireland, and for Scotland.
If a bankruptcy order is made the administration of the bankrupt person's affairs is handled by a trustee in bankruptcy who must be either an official receiver (a civil servant) or a licensed insolvency practitioner appointed either by the Secretary of State or by the creditors at a meeting called for that purpose.
The bankrupt's assets (excluding tools of his trade and other essentials) vest in his trustee who is obliged to realise them (generally by selling them) to pay a dividend to creditors.
Similarly the court has power to undo a range of transactions entered into by the bankrupt with a view to dissipating or reducing the value of his assets in the period before his bankruptcy.
An IVA takes the form of a proposal to creditors to pay some or all of the debtor's debts over a period of time by selling assets or making payment out of income or a combination of the two.
The proposal must be approved by a licensed insolvency practitioner who will convene a meeting of creditors to consider it.
Other options include protected trust deeds, these are agreements arranged between the individual in debt and his or her creditors.