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National Law Review
National Law Review
7/15/2026
UK restructuring plans emerge as Chapter 11 alternative for US companies

UK restructuring plans emerge as Chapter 11 alternative for US companies

Original: Restructuring Plans: An emerging alternative to Chapter 11 for US companies?

Short summary

UK restructuring plans (RPs) are increasingly used by US-listed companies as an alternative to Chapter 11 bankruptcy, offering advantages like preserving stock listings, favorable class voting thresholds, cost savings, and non-consensual third-party releases. Three US-listed debtors—Argo Blockchain, Fossil, and NFE Global Holdings—successfully obtained RP sanctions in English courts in the past 12 months. While not always viable, RPs are now a serious option in cross-border restructuring strategy.

  • UK restructuring plans (RPs) are emerging as a Chapter 11 alternative for US-listed companies
  • Key advantages include preserving stock listings, lower costs, favorable voting thresholds, and cram-down capability
  • Three US debtors (Argo Blockchain, Fossil, NFE Global Holdings) secured RP sanctions in English courts in the last 12 months

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