Personal bankruptcy has existed in diverse forms almost for three centuries. The ratio of this institute is to procure a certain type of insurance for physical persons against insolvency and unexpected expenses. Therefore, the philosophy behind it calls for legislative regulation of release of debts which would allow individuals to retain a certain property and procure necessary life needs as well as prevent any kind of discrimination after the release of debts. Even though the personal bankruptcy is not regulated in Croatia, it has been an object of numerous analysis and discussions due to the fact that personal bankruptcy proceedings manifest through application of diverse methods. Having this in mind, the American personal bankruptcy legislation is considered to be the most generous in the world. On the other hand, until recently, the most European legal systems did not have any incorporated provisions on release of debts for physical persons. Therefore, the aim of this article is to analyse models of personal bankruptcy. The author presents a short historical overview and talks about existing comparative models stressing their weaknesses and advantages in following chapters. The last part of the article contains conclusive remarks with regard to short recommendations which should be taken into consideration during the reform of passive bankruptcy ability.