This consultation provided an opportunity to provide feedback on the latest draft of the Mental Health Moratorium Regulations and the detailed implementation of the Moratorium process.

A working group was formed of members from R3’s Scottish Technical Committee to respond to the consultation. The group consisted of the following R3 members –

•  Emerita Professor Donna Mckenzie Skene (University of Aberdeen) - LinkedIn

• Dr Alisdair MacPherson (University of Aberdeen) - LinkedIn

• Eileen Maclean (Insolvency Support Services Limited) – LinkedIn

• Tim Cooper (Addleshaw Goddard) – LinkedIn

• Eilidh MacEwan (Anderson Strathern) – LinkedIn

• Angela Paterson (Dunedin Advisory) - LinkedIn

R3’s response was formally submitted on 14 March 2025.

While we support the principles behind the Mental Health Moratorium, we remain concerned that the overly complex nature of the regulations may limit their effectiveness. We strongly advocate for a streamlined approach that aligns with existing moratorium frameworks and includes more practical safeguards for both debtors and creditors. We also consider that the regulations should have an inbuilt provision for review after a suitable period.