A comparative contribution by the editors analyses the similarities and differences between the various European systems. Furthermore, the editors discuss attempts to harmonise the law of civil procedure in this respect, which range from various recommendations of the Council of Europe to the 1998 draft of the Late Payment Directive, and provide concrete suggestions for a future harmonisation or unification of this area of the law.

The countries covered are Austria, Belgium, Denmark, England, Finland, France, Germany, Greece, Italy, Luxembourg, The Netherlands, Portugal, Spain, and Sweden.