T This research compares the regulatory frameworks of creditor approval within the suspension of debt payment obligations (pkpu) mechanism in indonesia and the cross-class cramdown in the netherlands to determine which regime offers better protection for debtors. the problem formulations address the advantages and disadvantages of the creditor approval processes in both pkpu and cross-class cramdown, as well as which regulatory system provides superior protection for the debtor\\\'s interests. employing a normative legal research method with a comparative law approach, the results indicate that indonesia\\\'s pkpu is rigid due to its requirement for absolute cumulative approval. failure to achieve a quorum leaves the process vulnerable to being held hostage by minority creditors, ultimately leading to automatic bankruptcy. conversely, the cross-class cramdown mechanism in the netherlands is oriented towards business continuity (going concern), allowing the court to ratify a restructuring plan even if it is rejected by certain creditor classes. in conclusion, while pkpu has the advantage of a strict timeframe, it carries a high risk of automatic bankruptcy. on the other hand, the cross-class cramdown focuses on going concern; despite its more complex evidentiary requirements, the dutch mechanism provides significantly stronger protection for good-faith debtors compared to pkpu. it is recommended that legislators immediately adopt this mechanism in future revisions of bankruptcy regulations, and that business actors prioritize out-of-court restructuring.