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International Upstream ABS: Building the Framework for Global Adoption

Can the success of upstream asset-backed securitisation (ABS) in the U.S. be replicated internationally?

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That was the central question explored during PRAGMA's workshop with Haynes Boone, where producers, investors, lenders and legal experts examined what it will take to adapt upstream ABS structures to international oil and gas markets.

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While the financing principles behind U.S. upstream ABS are well established, expanding the model internationally requires more than simply replicating existing transactions. Ownership regimes, licensing structures, insolvency laws and decommissioning obligations vary significantly between jurisdictions, meaning each transaction will require a tailored legal and contractual framework.

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The discussion explored how international ABS could provide an alternative to traditional reserve-based lending while broadening access to institutional capital. Participants also examined the challenges of structuring transactions around offshore assets, managing operator and development risk, and addressing insolvency and licence-loss risk, all of which will be critical to establishing the first successful international transaction.

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Although the first deal is expected to be the most complex, the workshop concluded that establishing a successful precedent could create a pathway for broader adoption across global upstream markets.

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Download the report to explore the key insights and practical considerations shaping the future of international upstream ABS.