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Both Spain and the UK have introduced restructuring agreements as a new restructuring tool. In Spain, the new framework implements the Restructuring Directive. The UK, in turn, approved the new framework during the early days of the COVID-19 pandemic and in the wake of Brexit and will coexist with the scheme of arrangement that draws from its longstanding practices and principles. Although both frameworks share more similarities than differences, this paper identifies six key features on which they diverge: stays or moratoriums, the entry test to file a plan, claims that may be affected by that plan, the majority required to approve a plan, class formation and cross-class cram down.
