The following chapter is extracted from GRR’s Americas Restructuring Review 2022 and is posted with permission. The entire publication is available here

Chapter 11 has been both a model and a vision for the EU restructuring community for the past 20 years. Following the enactment of the EU Restructuring Directive in 2019, the United Kingdom, the Netherlands and Germany have adopted insolvency and restructuring laws that have many of the same features of Chapter 11. This chapter compares a number of the new ‘Chapter 11-like’ laws in those countries with their US Bankruptcy Code counterparts.