The paper includes an overview of regulations related to natural person - consumer bankruptcy and debt reduction in a few selected legislations of European countries and the USA.

The notion of consumer bankruptcy is not equivalent to the bankruptcy of an economic entity. The loss of the juridical personality through bankruptcy by an entity pursuing economic activity is a normal phenomenon frequently occurring in a market economy. The situation is different in the case of consumer bankruptcy. The declaration of bankruptcy cannot have the same legal consequences in the case of a natural person since the loss of personality by a natural person is not possible in such proceedings. The paper shows how legislations of selected countries have dealt with the protection of the individual's existence in the case of his/her bankruptcy and how, by protecting him/her, the state makes it possible for the individual to continue his/her existence in the society and to reconstruct his/her economic potential.

American legislation was the pioneer of consumer bankruptcy regulations since it was the first one to provide a natural person - consumer with the right to be subject to bankruptcy proceedings. The paper presents the fresh start rule used in the American legislation to relieve persons from excessive debts and to facilitate their new functioning in the society, without discrimination in everyday life and without any restrictions of the right to assume new obligations.

The paper also shows the directions in which legal solutions for bankruptcy and debt reduction of natural persons go in various European countries. Composition proceedings, suspension of the proceedings, arbitration solutions are used both in the very liberal American law and in European legislative systems to support the debtor's existence, his/her professional activity and to improve his/her financial situation. If the debt level is maintained and cannot be considered as a temporary lack of funds, legal regulations make it possible to reduce the debt partially, frequently against the creditors' will or following their enforced consent. However, the consent is enforced only if there are no prospects for the full satisfaction of claims from the debtor's property, i.e. the creditors are deprived of the rights they would not be able to exercise anyway.

Legal systems of the European countries that introduced regulations for bankruptcy and debt reduction of persons were largely following the American model. However, full transition of American solutions did not occur. The differences in the European countries' regulations stem from known assumptions applied by the legislators and pertain to the requirements for debtors in order to relieve them from excessive debts.

The protection of natural persons as related to the bankruptcy and debt reduction law has not been regulated in the European Union Directives yet. It means that the members of the Community are not bound by any exemplary regulation and that there are no minimum standards for the protection of natural persons - consumers to be met by regulations of individual Member States.