Casino: Chapter 15 Recognizes French Accelerated Safeguard Restructuring

Casino, Guichard-Perrachon S.A. used a chapter 15 case in the Southern District of New York to give U.S. effect to one of Europe’s most consequential retail restructurings of 2024: the group’s French accelerated safeguard plans. The company filed the chapter 15 petition in February 2024 after creditor and shareholder voting in France and as the restructuring implementation steps were moving from court approval into execution. In practice, the U.S. filing was about cross-border enforceability for debt instruments tied to New York law and New York market infrastructure, not a U.S. operating reorganization.

Casino’s U.S. chapter 15 docket shows what “recognition” looks like when a foreign plan needs to bind New York law-governed documentation and the agents/trustees that sit in the middle of that documentation. The French transaction was widely described as an approximately €8.2 billion restructuring built around a €4.9 billion debt-for-equity swap and a €1.2 billion new equity injection led by Daniel Křetínský’s investment platform. Casino’s investor-relations timeline shows the accelerated safeguard proceedings were opened on October 25, 2023, the plans were approved by a Paris court on February 26, 2024, and the restructuring was implemented at the end of March 2024.

Debtor / foreign proceeding	Casino, Guichard-Perrachon S.A. and affiliates in French accelerated safeguard proceedings, with U.S. chapter 15 recognition, as reflected in its restructuring timeline and bankruptcy filings
U.S. court	U.S. Bankruptcy Court, Southern District of New York
U.S. case number	24-10252 (DSJ)
U.S. judge	David S. Jones
U.S. petition date	2024-02-15
Foreign main proceeding	French accelerated safeguard proceedings in Paris, per the restructuring timeline
Foreign court	Tribunal de Commerce de Paris / Commercial Court of Paris
Foreign representative	Alexis Ravalais
Noticing agent (U.S.)	Kroll Restructuring Administration LLC
Recognition order entered	2024-03-14
U.S. chapter 15 case closing order	2024-06-04
Restructuring headline terms (as reported)	~€8.2B deal value; €4.9B debt-for-equity swap; €1.2B new equity injection
New controlling investor group (as reported)	Křetínský-led consortium with ~53.7% stake post-transaction
Store sale program (high level)	Multi-tranche disposals to Intermarché/Les Mousquetaires, Auchan, and Carrefour, including a first tranche of 121 stores

Chapter 15 Recognition of a French Accelerated Safeguard Restructuring

Recognition Relief and U.S. Case Mechanics

Why Casino needed a U.S. chapter 15 case (and why New York law matters). Casino’s U.S. filing was framed as a recognition proceeding designed to ensure U.S. enforceability of the French accelerated safeguard plans for debt documentation that was “wholly or partially governed by or interpreted in accordance with New York law,” and in some cases included New York forum-selection provisions . That is a common cross-border pressure point: even if a foreign court-approved plan cancels or restructures debt under local law, New York law instruments often require U.S.-recognition machinery to bind dissenting holders, constrain enforcement actions in New York courts, and compel performance by the agents and trustees that administer the documentation. A chapter 15 proceeding can “protect a firm’s US assets while insolvency proceedings play out elsewhere,” and, more importantly for this posture, it provides a U.S. court order recognizing the foreign main proceeding and extending stay-like and injunctive protections to prevent U.S.-based enforcement inconsistent with the foreign plan, as described in the chapter 15 petition. In Casino’s case, bankruptcy filings describe the chapter 15 relief as targeted at preventing parties from trying to “enforce or collect” on debt cancelled under the French process and at ensuring plan implementation steps could be carried out for New York law-governed instruments .

The recognition order itself reflects that transaction-focused intent. Bankruptcy filings describe the U.S. court recognizing the French proceedings as foreign main proceedings, applying section 1520(a) relief (including automatic-stay-like protections), and entering injunctions designed to prevent actions inconsistent with the French plans . Critically, the recognition order also includes implementation-direction language aimed at the market plumbing around the debt instruments: it restrained actions that would “interfere or disrupt” the plan treatment of the TLB loan, the Quatrim bonds, or the high-yield bonds, and it directed the relevant agent/trustee (Citibank in multiple capacities referenced in the filings) to take steps to cancel guarantees and terminate obligations under certain indentures and related instruments . In other words, the U.S. case was a legal bridge between a French court-approved restructuring and New York law documentation that could otherwise become a litigation and enforcement bottleneck.

Business Footprint and Operational Reset

Casino’s business footprint and why the restructuring was unusual for U.S. readers. Casino is a legacy European retailer with a 19th-century founding date and a modern portfolio spanning multiple grocery formats. Bankruptcy filings describe a broad French store network and a banner mix that included Géant Casino hypermarkets, Casino supermarkets, Monoprix and Franprix convenience-focused formats, and e-commerce exposure . Even for professionals used to U.S. retail restructurings, the Casino story reads differently: the restructuring was pursued through French conciliation and then an accelerated safeguard plan, rather than a U.S. chapter 11 process, and it was paired with a sweeping operational reset that sold or transferred large blocks of stores to competitors and shifted the footprint toward convenience-oriented banners.

Public reporting described Casino as “debt-laden” amid “stagnant sales in the highly competitive French grocery market,” with the chapter 15 petition arriving after creditor and shareholder votes on the French plans. Earlier reporting on the restructuring negotiations describes a business under severe cash pressure: Casino reported an operating loss in the first half of 2023 and negative French cash flow of approximately €1.6 billion as it sought a creditor-backed recapitalization. The French process ultimately produced a transaction described as one of the largest restructurings completed across Europe, the Middle East, and Africa in 2024, driven by the speed and voting framework of France’s accelerated safeguard regime.

New York Law Debt Perimeter and Capital Structure

Financial structure: the New York law-governed perimeter (and why it drove the U.S. relief package). Bankruptcy filings describe several instrument families that were central to the New York law story: a term loan “TLB” facility, Quatrim-issued bonds, and two series of euro-denominated high-yield notes governed by New York law . The U.S. chapter 15 case did not need to replicate the French plan; it needed to supply a U.S. court order that would (i) recognize the foreign main proceeding and (ii) restrain U.S.-based enforcement and compel implementation steps for the New York law instruments. Industry coverage described approximately €1.5 billion of New York law-governed debt in the perimeter of the chapter 15 recognition effort, and bankruptcy filings similarly describe relief affecting New York law-governed documentation with nominal value around that level .

Bankruptcy filings describe the following instruments, principal amounts, and key terms (including maturity, interest, and security/guarantee structure for the secured categories). These details matter because they show where enforcement risk could surface (agents and trustees, secured collateral packages, guarantor webs) and why a U.S. court order directing implementation steps can be as important as the recognition finding itself.

As a practical matter, the table explains why cross-border enforceability can become a “documentation execution” problem rather than a pure creditor-consent problem. A secured bond indenture with multiple guarantors and collateral accounts may have to be unwound through formal release mechanics. A term loan with a security agent and guarantor package creates a parallel set of consent and release pathways. A chapter 15 order that both restrains enforcement and directs action by the relevant agents/trustees can be the mechanism that makes a foreign plan self-executing in the United States, particularly where New York forum-selection clauses would otherwise invite holdout litigation.

France: conciliation → accelerated safeguard → implementation (and why speed was the point). Public reporting describes a mid-2023 agreement-in-principle with creditors and investors as a turning point. Casino said it reached an agreement in principle on a restructuring involving a €1.2 billion equity injection led by Daniel Křetínský, with a roadmap that contemplated a binding lock-up in September 2023, the opening of accelerated safeguard proceedings in October 2023, and completion in the first quarter of 2024. Casino’s investor-relations timeline provides the core procedural milestones: the court opened accelerated safeguard proceedings on October 25, 2023, creditor classes voted in mid-January 2024, the plans were approved on February 26, 2024, and the restructuring was implemented at the end of March 2024.

Key Timeline

IFR Awards coverage characterizes the transaction as a landmark because France’s accelerated safeguard legislation can produce much faster restructurings that are less vulnerable to prolonged litigation, which is a meaningful contrast to the timing profile of many U.S. retail chapter 11 cases. In a situation where store disposals and competitive dynamics can erode value quickly, speed is not merely a procedural preference; it can be a strategic necessity.

Investor consortium and recapitalization economics: who controlled Casino after the restructuring and what the headline terms were. Reporting on the transaction emphasized both the scale of the debt reduction and the governance shift away from the historical holding-company control structure. IFR Awards described the financial restructuring as a roughly €8.2 billion deal featuring a €4.9 billion debt-for-equity swap and a €1.2 billion new equity injection by an investor consortium. ESM Magazine described the investor group as including EP Equity Investment III (Daniel Křetínský), Fimalac, and Attestor, with the EU authorization for the consortium to take control reported in early January 2024.

The “control” implication is explicit in the reported post-transaction ownership: ESM Magazine reported that the consortium would hold 53.7% of Casino’s share capital, with existing shareholders diluted to around 0.3% in the recapitalization mechanics described. A separate report framed the deal as ending the multi-decade era of Jean-Charles Naouri’s control through the Rallye holding company structure as part of the end of an era. Retail Detail later reported a post-closing stake of 52.1% for the Křetínský consortium in connection with the management transition described at closing, which practitioners should treat as a post-implementation measurement that may reflect subsequent transactions, rounding differences, or the specific reference point used in that reporting.

Deal Terms and Store Disposals

From a restructuring-architecture perspective, Casino is an example of a balance-sheet recapitalization paired with a business model shrink and reconfiguration. The equity injection and debt conversion reset leverage, but the operational steps—store divestitures, franchise conversion, and workforce changes—were the real delivery mechanism for stabilizing a food retail platform facing competitive and pricing pressure.

Key professionals: a cross-border advisor stack built for implementation risk. Large cross-border restructurings often turn on execution details—intercreditor alignments, documentation mechanics across governing-law regimes, and regulatory approvals that can become gating items. Casino’s process reflects that reality. Industry coverage highlights a multi-jurisdiction advisor mix that is typical of transactions where the core plan is French, but the documentation perimeter includes New York law instruments and global clearing infrastructure. Awards coverage identified Rothschild & Co as a key advisor to Casino and highlighted how the restructuring moved from proposal to closing over roughly nine months, from July 2023 to March 2024. Reporting on the chapter 15 recognition effort referenced major international firms involved across the transaction, including Freshfields, Latham & Watkins, and Weil Gotshal & Manges.

The U.S. docket also shows the “last mile” of a chapter 15 implementation: bankruptcy filings identify Weil Gotshal & Manges LLP as U.S. counsel on the chapter 15 recognition motion and related relief requests . Bankruptcy filings also identify Kroll Restructuring Administration LLC as the noticing agent tasked with disseminating recognition materials through the channels that actually reach holders and intermediaries, including institutional and clearing-system distribution pathways . In a transaction that required multiple layers of regulatory and court approvals (including EU competition/foreign investment reviews referenced in reporting), this combination of financial restructuring advisors, cross-border legal counsel, and a sophisticated noticing infrastructure reflects a core lesson: for New York law-governed debt instruments, “plan approval” is only half the battle; the other half is getting the right parties comfortable enough to execute cancellations, releases, and documentation changes without triggering litigation or operational disruption.

Operational restructuring: store disposals, competition approvals, franchising shift, and workforce impacts. Casino’s restructuring narrative cannot be told without the store disposal program. In early 2024, reporting described a multi-party agreement for the acquisition of approximately 287–288 Casino stores by Auchan, Intermarché/Les Mousquetaires, and Carrefour, with enterprise value reported around €1.3–€1.35 billion (excluding real estate and before inventory sale), and with negotiations described as compressed into roughly six weeks. The French Competition Authority later reported granting derogations allowing certain takeovers to proceed before the completion of full competition review, referencing notifications for Intermarché, Auchan, and Carrefour and a total set of 323 notified stores.

In April 2024, Casino announced the first tranche of transfers: 121 stores (including supermarkets and hypermarkets) at an enterprise value of €698 million, with subsequent tranches scheduled for later in 2024 and with protections for employees assigned to transferred stores (including continuation of key collective agreement provisions for 15 months) described in the release.

The 2024 operating results release provides additional “scale” context: Casino reported that 366 hypermarket/supermarket stores were sold with disposal proceeds of €1.773 billion, alongside a broader transformation in which 768 convenience outlets were closed (with the company reporting that most were franchisee-operated), 95 stores were converted to franchises, and 3,230 job positions were eliminated. Retail Detail separately framed the workforce/footprint shift as a reduction from approximately 56,000 to 28,000 employees and a strategic focus narrowing toward the Monoprix format in the Paris region.

These operational steps were the “value-preservation” side of the recapitalization. Asset disposals can stabilize liquidity and reduce operational complexity, but they also create second-order consequences: competition approvals, transfer timing, employee protection covenants, and the risk that the remaining platform becomes structurally smaller and more concentrated. In Casino’s case, the scope of disposals and closures suggests the restructuring was designed not simply to reduce debt but to redraw the business into a narrower, more defensible format mix.

Store transfers and regulatory constraints: why competition derogations and labor protections mattered. The store disposal program sat at the intersection of three constraints: (i) competition law approvals, (ii) labor protections and collective agreements, and (iii) the speed at which transfers must occur to preserve value. The French Competition Authority’s decision to grant derogations allowing takeovers to proceed before final competition analysis underscores the “speed vs. process” tension in a retail restructuring: delayed approvals can strand stores in limbo, erode supplier confidence, and raise labor and inventory risks, while rapid transfers can change local market structures and therefore require careful regulatory management.

Labor and employee-transfer protections were also visible in public disclosures. Casino’s store-disposal press release for the first tranche emphasized that buyers committed to take over employment contracts of employees assigned to the transferred stores and described protections including a 15-month period maintaining certain collective agreement provisions. At the same time, reporting around the investor consortium and store sale negotiations described significant union concern and strike threats tied to fears of “dismantling” the group and the employment impact of selling hundreds of hypermarkets and supermarkets. Even where capital structure terms are settled, a retail restructuring’s success can turn on whether store transfers are executed quickly enough to prevent customer/supplier disruption while satisfying regulatory and labor requirements—especially in a food retail business where local market share and continuity of operations are central to value.

Corporate-group consequences: end of Rallye control, leadership transition, and holding-company unwind. The restructuring was widely framed as ending the long control arc of Jean-Charles Naouri, who had controlled Casino through the Rallye holding company structure. Background on Naouri’s control history and reporting framing the transition as the end of an era were both part of the narrative around the change in control. In late March 2024, a post-closing report described a management transition at Casino, with Jean-Charles Naouri resigning, Laurent Pietraszewski becoming chairman, and Philippe Palazzi becoming CEO.

The holding-company unwind is also documented in market announcements. Rallye disclosed that the Commercial Court of Paris ordered the liquidation/winding-up of Rallye and related holding companies (Foncière Euris, Finatis, and Euris) in April 2024, and that listed instruments were expected to be delisted. The operating-company recapitalization proceeded alongside holding-company liquidations that crystallized losses for legacy equity and structurally subordinated creditors.

U.S. chapter 15 mechanics: notice, recognition, injunctions, and the path to closure. The U.S. docket progressed quickly, consistent with a recognition-first posture. Bankruptcy filings describe a scheduling/notice order entered on February 16, 2024 that set an evidentiary recognition hearing for March 21, 2024 and established objection and reply deadlines, with Kroll Restructuring Administration LLC identified as the noticing agent . The U.S. court entered the recognition order on March 14, 2024 (before the scheduled evidentiary hearing date), and bankruptcy filings describe the recognition order as granting foreign main recognition and extending relief under section 1520(a), including the application of the automatic stay under section 362 to the debtors and their U.S.-territorial property . The recognition order also included the injunctive and implementation-directed provisions discussed above, designed to prevent actions inconsistent with the French plans and to facilitate the cancellation/termination mechanics for New York law-governed instruments .

What the recognition order did in practice for New York law documentation. A recognition order can be narrowly procedural (a COMI finding plus automatic-stay-like effects), or it can be drafted to solve the execution problems that arise when a foreign restructuring must be implemented through New York law debt documentation and the intermediaries that administer that documentation. Casino’s recognition order is described in bankruptcy filings as including both broad injunctive relief and targeted implementation directives aimed at preventing disruption of the French plan’s treatment of specific New York law instruments.

At a high level, bankruptcy filings describe four layers of relief that mattered for the New York law perimeter:

The implementation direction component is where chapter 15 becomes operationally meaningful. Bankruptcy filings describe the recognition order as directing Citibank—identified in the record in various agent/trustee capacities for the Quatrim and high-yield bonds, and as security agent in the term loan structure—to carry out cancellation and termination steps for guarantees, security, and indenture obligations . In cross-border restructurings, that kind of directive can be decisive: it is not enough for a foreign plan to say a bond guarantee is released if the contractual agent that administers the guarantee package is exposed to conflicting claims or to forum-selection litigation. The chapter 15 order provides a U.S. court instruction that intermediaries can rely on to implement the plan’s intended documentation outcome without becoming a litigation target themselves.

The scheduling/notice order is a complementary “plumbing” document. Bankruptcy filings describe the court setting objection deadlines and describing how notice would be disseminated to institutional infrastructure—including distribution through clearing systems and agents—rather than relying solely on direct service to end holders . The noticing order also contemplated publication notice in The New York Times . The notice procedures described in filings reflect the use of clearing systems, global custodians, and publication notice to reach cross-border debt holder populations.

The closing motion is also instructive because it highlights how chapter 15 cases often wind down: after recognition is granted and the foreign restructuring becomes effective, the case can be closed once it is “fully administered” in the chapter 15 sense (i.e., no outstanding contested matters). Bankruptcy filings describe the foreign representative seeking closure because the restructuring effective date occurred and there was no longer a reason for the U.S. case to remain open . The motion also described that key restructuring implementation steps were completed in late March 2024 and requested cancellation of a later-scheduled status conference .

The timeline from petition to closure shows chapter 15 operating as a court-administered “enforcement wrapper” for a foreign plan that needs to operate on U.S.-connected rights and documentation. The chapter 15 docket is therefore less about creditor negotiation and more about getting the right recognition findings, notice record, and injunctive/implementation relief on the docket quickly enough to eliminate the incentive for opportunistic U.S. enforcement actions while the foreign restructuring is being implemented.

Post-restructuring performance: what the 2024 results said, and how later commentary framed the next risk layer. Casino’s 2024 full-year results release provides a view into the “after” picture: the company reported a consolidated net loss of €295 million (improving from a much larger 2023 loss), net sales of €8.474 billion, and adjusted EBITDA of €576 million. It also reported net debt reduced to €1.203 billion, with restructuring-related debt reduction of €4.978 billion, and liquidity reserves described as approximately €1.5 billion.

Those disclosures help separate the “capital structure reset” from the “operating outcome.” The reported debt reduction is substantial, but the reported EBITDA decline and ongoing net loss illustrate the central challenge of grocery and convenience retail: even after de-leveraging, the business must generate stable cash flow while competing on price, traffic, and supply chain effectiveness. Casino’s disclosures also show a transformation that extends beyond financing terms into store network redesign and brand positioning.

Separately, Casino’s restructuring timeline highlights that the equity mechanics continued after implementation. The company reported launching a reverse share split on April 24, 2024 and completing a 1-for-10 reverse share split on June 14, 2024. The same timeline also references capital increases reserved for secured creditors, noteholders, holders of deeply subordinated notes, the investor consortium, and employee savings plan participants. For stakeholders assessing post-restructuring governance and dilution, those kinds of follow-on equity steps can be as important as the initial recapitalization headlines.

Later industry commentary suggests that the post-restructuring path remained challenging. In 2025, K2 Partners argued that a “second restructuring” risk had emerged less than two years after the first, citing operating losses, covenant pressure metrics, and continued leverage concerns, while also reiterating the headline 2024 restructuring terms and debt reduction figures K2 Partners. That commentary framed the post-transaction period as still dependent on operating performance, profitability, and cash generation after the balance-sheet reset and store disposals.

Frequently Asked Questions

What is Casino’s U.S. bankruptcy case, and why was it filed?

Casino’s U.S. case is a chapter 15 recognition proceeding filed in the Southern District of New York in February 2024 to obtain U.S. recognition and enforcement of French accelerated safeguard proceedings and restructuring steps that affected New York law debt. It was not a U.S. operating reorganization under chapter 11.

What foreign proceeding was recognized in the U.S. chapter 15 case?

The U.S. chapter 15 case sought recognition of French accelerated safeguard proceedings in Paris, overseen by the Commercial Court of Paris, as reflected in the company’s restructuring timeline and described in bankruptcy filings.

When did the U.S. court grant recognition and when did the chapter 15 case close? Bankruptcy filings describe the U.S. court entering a recognition order on March 14, 2024 and closing the chapter 15 cases by order entered June 4, 2024 .

How much New York law-governed debt was in scope, and why did that matter?

Industry coverage described approximately €1.5 billion of New York law-governed debt in the recognition perimeter. The chapter 15 proceeding matters because New York law documentation can be enforced in New York courts and is administered through agent/trustee structures; recognition and related injunctive relief can prevent inconsistent enforcement actions and enable implementation steps for the documentation .

What were the headline financial terms of Casino’s French restructuring?

The restructuring was widely described as featuring a €4.9 billion debt-for-equity swap and a €1.2 billion new equity injection, with deal value characterized around €8.2 billion.

Who led the investor consortium and what ownership stake did it receive?

Reporting described the investor group as led by Daniel Křetínský (through EP Equity Investment), with participation from Fimalac and Attestor, and described the consortium as receiving a post-transaction stake around 53.7% (with other reporting later describing ~52.1% post-closing).

How many stores were sold or transferred, and to which buyers?

Public reporting described a multi-buyer program involving Auchan, Intermarché/Les Mousquetaires, and Carrefour covering approximately 287–288 stores. Casino also disclosed a first tranche of 121 stores, and the company later reported that 366 hypermarket/supermarket stores were sold during 2024.

What happened to the Rallye holding-company structure after the restructuring?

Rallye disclosed that the Commercial Court of Paris ordered the winding-up/liquidation of Rallye and related holding companies in April 2024, with delisting expected.

Who was the claims or noticing agent in Casino’s U.S. chapter 15 case?

Bankruptcy filings describe Kroll Restructuring Administration LLC serving as noticing agent in the U.S. chapter 15 proceeding.

For more analysis of bankruptcy cases and restructuring developments, explore the ElevenFlo blog.