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Schemes of arrangement are a hybrid figure, long established in English law, that include an agreement between the debtor and its creditors and a judicial mechanism for restructuring. They have been gradually used by English and foreign companies, especially after the 2007-08 financial crisis. Before Brexit, there was a debate as to whether schemes of arrangement should be recognised under European Union insolvency regulations, in judgments in civil or commercial matters, or as an agreement establishing contractual obligations. After Brexit, the debate on the recognition of schemes of arrangement outside the United Kingdom has surfaced again, and the issue is being re-examined under other legal instruments of public and private international law and, particularly, of national law. [ABSTRACT FROM AUTHOR]