In a judgment of 24 March 2017 (in Dutch), the Supreme Court of the Netherlands upheld the longstanding requirement that for a debtor to be declared bankrupt, there need to be at least two creditors.

Under Dutch law, bankruptcy can be applied for either by the debtor himself or by one or more creditors. The bankruptcy petition must include facts and circumstances which constitute prima facie evidence that the debtor has ceased to pay his debts. In order for this to be the case there must be at least two creditors.