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A key change since the financial crisis of 2008 is the internationalization of interest in consumer finance. International institutions monitor household credit because of its impact on financial stability and market expansion. Macroprudential concerns drove this interest, resulting in a sea change in approaches to consumer credit regulation in many jurisdictions. This article critically analyses the emerging international policy paradigm, contrasting pre-and post-crisis regulatory approaches and highlighting continuing tensions about key policy choices. It then uses two recent sites of contestation, debt adjustment and the regulation of high-cost credit to demostrate the persistence of conflict over the positioning of consumers within an emergent stability focused paradigm of financial consumer protection.

England and France have developed distinct treatment systems to address the shock of a substantial increase in over‐indebted individuals since the mid‐1980s. In France, Over‐Indebtedness Commissions, with the Bank of France playing a central role in their management, now dominate the system. A more fragmented system of private and public providers of remedies developed in England, with innovation driven by private actors modifying existing commercial procedures and increased access to bankruptcy relief a side‐effect of government promotion of entrepreneurialism. This article explains the differences between these countries in terms of the influence of interest groups, including state actors, and ideologies. Historical contingency also plays a role. The distinct responses were not hard‐wired to legal origins and the article argues that analysis of the interaction of interest groups, state actors and ideology in shaping institutions, which in turn structure future change, provides a productive approach for future comparative research in this area.