All 27 EU member states must implement the European Restructuring Directive of 20 June 2019 by 17 July 2021. The Directive was in part a reaction to the phenomenon observed with continental European companies in a financial crisis to restructure their debt under an English Scheme of Arrangement. The Scheme of Arrangement, which is not an insolvency process, offers the possibility to implement a debt restructuring on the basis of a majority decision by the creditors. Under these rules, a single “hold-out” creditor is unable to block a reasonable restructuring plan if the majority of creditors approves it.