The paper provides an overview and comparative legal analysis of the bankruptcy institution in Russia and foreign models. The purpose of the study is to identify common features and differences in the legal regulation of bankruptcy procedures, the mechanisms for restructuring and maintaining solvency, and the roles of key participants (debtors, creditors, bankruptcy administrators, and government agencies). The comparison examines domestic approaches and foreign examples: the United States (Chapter 11), the United Kingdom (Administration, Enterprise Act), Germany (Insolvenzordnung), France, and the principles of the European Union, focusing on the procedures, the priority of claims, the timing, the cost of procedures, the conditions for access to restructuring, the protection of small and medium-sized businesses, and the regulatory and institutional framework.