Andrew Tetley

Assigning receivables on either side of the Channel: a comparative note on French and English law

As between English law and French law, the key principles behind assigning receivables are similar. The 2016 reform of French contract law has undoubtedly brought the French regime applicable to assigning receivables closer to English law. However, practical differences between the two systems continue to exist. This is due to the inherently contrasting nature of civil and common law systems and the role, in particular, of equity in matters of assignment. This article presents the French regime on assigning receivables, contrasting it with English law on certain points.