Our international restructuring teams have authored two chapters for the Global Restructuring Review (GRR) Americas Restructuring Review 2026. The GRR Restructuring Review is recognised as a leading source of cross-border insight and thought leadership, offering a comprehensive perspective on developments in restructuring and insolvency worldwide.

Holding the line: how documentary protections are shaping investor risk in the era of holdco capital solutions

This chapter explores the rise of holdco payment-in-kind (PIK) debt and preferred equity. It also discusses how these trends are reshaping investor risk profiles and deal structuring amid evolving macroeconomic pressures, especially for sub-investment grade, private equity-owned businesses. The chapter delves into the unique risks of holdco instruments compared to traditional operating company (opco) debt. In doing so it highlights the growing importance of tailored documentary protections for investors - including covenant controls, good behaviour rights, and alignment of interests with shareholders. The chapter further examines the use of holdco instruments in restructurings, showing how they can address legal and commercial barriers to equity ownership while incentivising improved business performance and facilitating asset recovery for both creditors and shareholders.

This chapter was written by Marvin Knapp based in Hamburg, Damian Ridealgh, based in the US and London based partners Paul Stewart, Mark Davis and Nick Fortune.

To read the chapter online, click here.

The EU’s restructuring revolution: how jurisdictions are adapting Chapter 11 provisions

Building on last year’s analysis, this chapter takes a closer look at how European jurisdictions have shaped new restructuring tools to fit their local context, drawing inspiration from US Chapter 11 but adapting the model for domestic needs. Through a comparative lens, it examines the practical gateways to jurisdiction, creditor protection, stays, financing options, and mechanisms to bind dissenting creditors or implement cramdowns across the Netherlands, France, Germany, Spain and the UK. With these developments, European businesses and creditors now have a broader menu of effective options for cross-border restructurings, positioning the region as a dynamic alternative to classic US processes.

This chapter was written by London – based partner Ken Baird and senior associate Sally Montague, New York-based partner Mark Liscio and counsel Samantha Braunstein, Amsterdam-based partner Michael Broeders, Hamburg-based partner Marvin Knapp, Paris-based partners Laurent Mabilat and Guilhem Bremond, Madrid-based partner Ana López, and knowledge lawyer Silvia Angós.

To read the chapter online, click here.