Since 31 December 2020 insolvency proceedings opened in England will no longer benefit from automatic recognition in an EU member state. Instead an application will need to be made for recognition in the relevant member state where there are cross border assets or an establishment.
Our quick guide gives an overview of the recognition procedure in Germany, France, Italy and Spain as well as an overview of the procedure in England for member state countries seeking recognition of their appointment here.
There is no one size fits all approach and to a degree, we will have to wait and see how member state courts respond to recognition applications to determine how easily recognition will be granted.