Ardagh Packaging Finance PLC

Event Publicly Available Information:

The Eligible Market Participant who submitted the DC Question has requested that the EMEA DC consider whether a Restructuring Credit Event has occurred with respect to the Reference Entity?

Sep 29 Press Release
Aug 13 Press Release
Transaction Support Agreement


External Review	This DC Question is subject to External Review. The administrative meeting among the External Reviewers and the Advocates was held on Monday 24 November 2025. The Submission Deadline for Written Materials was 10:00p.m. London time on Tuesday 2 December 2025. The next step in the External Review process is the Oral Argument, which will be heard on Tuesday 9 December 2025. The External Review Panel will deliver their Decision and written summary to the DC Secretary by no later than 5:00 p.m. London time on Tuesday 16 December 2025, following which it will be published on the DC website.

Written Materials	The following briefs were submitted in advance of the Submission Deadline in connection with the Ardagh Packaging Finance PLC External Review process: Statement of Facts with respect to the Reviewable Questions agreed by the Advocates for the ‘‘No’’ Position and the ‘‘Yes’’ Position Hyperlinks to Exhibits to the Statement of Facts agreed by the Advocates for the ‘‘No’’ Position and the ‘‘Yes’’ Position Brief in support of the ‘‘Yes’’ answer to the Reviewable Questions submitted by the Advocates for the ‘‘Yes’’ Position Hyperlinks to Exhibits for the Brief in support of the ‘‘Yes’’ answer to the Reviewable Questions submitted by the Advocates for the ‘‘Yes’’ Position Brief in support of the ‘‘No’’ answer to the Reviewable Questions submitted by the Advocates for the ‘‘No’’ Position Hyperlinks to Exhibits for the Brief in support of the ‘‘No’’ answer to the Reviewable Questions submitted by the Advocates for the ‘‘No’’ Position Brief in support of the ‘‘Yes’’ answer to the Reviewable Question submitted by an ISDA Member Brief in support of the ‘‘Yes’’ answer to the Reviewable Question submitted by an ISDA Member Brief in support of the ‘‘Yes’’ answer to the Reviewable Question submitted by an ISDA Member Brief in support of the ‘‘No” answer to the Reviewable Question submitted by an ISDA Member

Oral Argument	An Oral Argument will be heard on Tuesday 9 December 2025. The External Review Panel have agreed that the Advocate for each Presented Position will be allocated an aggregate of two hours in which to present their arguments.

DC Meetings Information	The EMEA DC held meetings on this DC Question on: 8 October 2025 10 October 2025 14 October 2025 16 October 2025 20 October 2025 22 October 2025 24 October 2025 28 October 2025 30 October 2025 3 November 2025 4 November 2025 5 November 2025 6 November 2025 10 November 2025 12 November 2025 13 November 2025 14 November 2025 17 November 2025 18 November 2025 21 November 2025 1 December 2025 2 December 2025 5 December 2025

Upcoming DC Meetings
This Event
- Ardagh Packaging Finance PLC December 8, 2025 2:00 PM (GMT)
All Meetings
- NFE FINANCING LLC December 8, 2025 11:00 AM (EST)
- Ardagh Packaging Finance PLC December 8, 2025 2:00 PM (GMT)
Additional Information

Issue Number:

2025100602

Submitted by:

General Interest Question

Category:

Credit Event

Coverage Election:

2014 Definitions

Status:

External Review

Outcome:

None
Procedural History
- External Review
  
  The Submission Deadline has now passed and the briefs have been published on the webpage.
  12/03/2025 05:00am EST
- External Review
  
  DC Decision
  11/25/2025 07:45am EST
- External Review
  
  The administrative meeting of the External Review Panel was held on 24 November 2025. Updates have been added to the webpage.
  11/24/2025 02:20pm EST
- External Review
  
  EMEA DC Meeting Statement 21 November 2025
  The EMEA DC met on 21 November and re-confirmed the appointment of Adrian Beltrami KC, Timothy Howe KC and Stephen Robins KC as the panel members for the External Review on Ardagh Packaging Finance PLC.
  ISDA Members (as defined in the DC Rules) may submit Written Materials in support of either the “Yes” or “No” positions to External Reviewers via the DC Secretary. The deadline for submission of Written Materials is 10:00 p.m. London time on Tuesday 2 December 2025. Note that the Written Materials are subject to prescribed parameters under Section 4.5(c) of the DC Rules. ISDA Members looking to make submissions should ensure that any submissions comply with those requirements. In particular, please note that each ISDA Member submitting information to the DC Secretary shall be deemed to represent and warrant that such information has been disclosed and can be made public without violating any law, agreement or understanding regarding the confidentiality of such information and each DC Party may rely on such representation. ISDA Members should note that (i) there is no need to submit as supporting exhibits the press releases or the transaction support agreement cited on the DC website for this issue as these are expected to form part of the advocates’ submissions in any event, and (ii) any exhibits must be public documents. The EMEA DC did not consider that the consent solicitation statement which is referred to in the press releases of Ardagh Group SA was a public document at the time of the vote on the relevant DC Questions.
  The administrative meeting among the External Reviewers and the Advocates will be held on Monday 24 November 2025.
  Further details of the External Review process, including the date of the oral argument (if any), will be published in due course.
  DC Decision
  11/21/2025 02:15pm EST
- External Review
  
  EMEA DC Meeting Statement – 19 November 2025
  As noted in its statement of 18 November 2025, the EMEA DC has not yet resolved Q1 – Q4 in respect of Ardagh Packaging Finance PLC. These will be resolved by the External Review Panel process and the timetable for that process will be published as soon as practicable. As a result, the resolution of the event that constitutes the Restructuring Credit Event and the formal Resolution of the various DC Questions in respect of Ardagh Packaging Finance PLC will occur once the External Review Panel process has been completed. In respect of both Qs 1 - 4 and Q6, a “DC Credit Event Announcement” has not occurred.
  DC Decision
  11/19/2025 03:05pm EST
- External Review
  
  EMEA DC Meeting Statement – 19 November 2025
  The EMEA DC met on 17 and 18 November 2025 to discuss Ardagh Packaging Finance PLC. The relevant DC Questions relating to whether or not a Restructuring Credit Event has occurred in respect of Ardagh Packaging Finance plc are as follows:
  - 2025100602 (Q1) raised on 7 October 2025;
  - 2025102701 (Q2) raised on 27 October 2025;
  - 2025102901 (Q3 raised on 29 October 2025;
  - 2025110501 (Q4) raised on 5 November 2025; and
  - 2025111301 (Q6) raised on 13 November 2025.
  The EMEA DC has previously voted on Qs 1-4 and has been unable to reach a Supermajority triggering the External Review Process. Pursuant to DC Rule 4.6(c), when making their decision the External Review Panel is only permitted to consider information that was available to the Convened DC prior to the relevant binding vote of the DC that triggered the External Review process in respect of a DC Question. If additional information becomes publicly available that may be relevant to the resolution of a DC Question, the External Review Panel is only permitted to consider such additional information if the question has either (i) first been withdrawn and re-voted on by the relevant DC; or (ii) sent back to the DC by the External Review Panel themselves and then re-voted on.
  As noted in the meeting statement of 14 November 2025, the EMEA DC considered that the announcements by the Ardagh group of 12 November 2025 provided further detail as to the manner in which the recapitalisation transaction was completed. The EMEA DC considered that this was relevant to the resolutions of Q3 and Q4 and withdrew them on 14 November 2025. Following further deliberation, the EMEA DC also concluded that such information contributes to the broader factual matrix and therefore may be relevant to the resolutions of Q1 and Q2. The EMEA DC also noted that the External Review Panel could also reach this conclusion independently of the EMEA DC and could in the future send Q1 and Q2 back to the EMEA DC at a later date (thus further delaying the process of resolving all DC Questions). Accordingly, the EMEA DC also withdrew Q1 and Q2. Having withdrawn Q1-4, the EMEA DC held a binding vote on each of them and was not able to reach a Supermajority in any case. Accordingly, the External Review process is triggered in respect of each of these DC Questions. As the EMEA DC has completed the process of withdrawing the DC Questions and re-voting on each of them, the External Review Panel will now be able to consider all public information that is submitted to them in relation to the DC Questions when reaching their decision and the risk of a delay arising due to the External Review Panel sending the DC Questions back to the DC has been mitigated against.
  The External Review process will therefore continue in respect of Q1-4.
  The EMEA DC also considered the additional Q6 which was raised on 13 November 2025 following the announcements made by the Ardagh group on such date. The EMEA DC had regard to DC Rule 2.4(d) which provides that “A Convened DC may not commence deliberations in respect of a DC Question until a separate but related DC Question completes External Review.” However, the EMEA DC considered that Q6 is not related to the substance of Q1-4 being resolved in the External Review such that DC Rule 2.4(d) is not engaged. This is because the considerations that resulted in the EMEA DC being unable to reach a Supermajority on Q1-4 and which will be determined by the External Review were not relevant to the resolution of Q6. In addition, at the point the binding vote was held on Q6, all the DC Questions had already been withdrawn from External Review. Note that the resolution by the EMEA DC of Q6 is without prejudice to the resolution of each of Q1-4. On this basis, the EMEA DC determined (i) a Restructuring Credit Event had occurred with respect to Ardagh Packaging Finance PLC no later than 12 November 2025; and (ii) in respect of Q6, 13 November 2025 was the date on which the DC Secretary first effectively received both a request to convene the Committee and Publicly Available Information that satisfied the requirements of Section 2.1(b) (such that 13 November 2025 was the Credit Event Resolution Request Date). The date on which the Credit Event occurred will not be determined until Q1-4 has been resolved in the External Review process.
  The EMEA DC has not yet made any determination in respect of Q5 (Issue number 2025110502) and has extended the deadline for holding a binding vote on Q5. The EMEA DC is focused on resolving Q1-4 as soon as practicable and will provide a further update on the timetable for the External Review process in due course.
  DC Decision
  11/19/2025 12:05pm EST
- External Review
  
  EMEA DC Meeting Statement 14 November 2025
  The EMEA DC met on 12, 13 and 14 November 2025 to discuss the External Review process in respect of Ardagh Packaging Finance PLC.
  The EMEA DC is aware of the announcements published by the Ardagh group on 12 November 2025. The EMEA DC notes that these announcements provide further detail as to the manner in which the recapitalisation transaction was completed.
  Given these announcements, the EMEA DC Resolved to withdraw Q3, Q4 and Q5 (DC Issues 2025102901, 2025110501 and 2025110102) from External Review for further consideration by the EMEA DC in accordance with DC Rule 4.6(a).
  The EMEA DC is meeting again on 17 November 2025 to continue discussions. At this time, the EMEA DC has not withdrawn Q1 or Q2 and so the External Review process will continue in relation to Q1 and Q2. Details of the timeline, including the Submission Deadline, will be published in due course.
  DC Decision
  11/14/2025 10:45am EST
- External Review
  
  EMEA DC Meeting Statement 10 November 2025
  The EMEA DC met on 10 November 2025 to discuss the next steps for the External Review process in relation to Ardagh Packaging Finance PLC (Issue numbers 2025100602, 2025102701, 2025102901, 2025110501 and 2025110502) and agreed to meet again on 12 November 2025 to continue its discussions.
  11/10/2025 10:55am EST
- External Review
  
  EMEA DC Meeting Statement – 7 November 2025
  The EMEA DC held a binding vote on the DC Issues for Q1-4 and did not reach a Supermajority on any DC Issue. As such, each DC Question has been referred to External Review. For reasons of efficiency, the EMEA DC also Resolved to send Q5 (2025110502) to External Review so that all matters could be considered and resolved in one process in as timely a manner as possible.
  Further updates will be provided in due course.
  DC Decision
  11/07/2025 03:45am EST
- DC Deliberating
  
  EMEA DC Meeting Statement 5 November 2025
  The EMEA DC met on 5 November 2025 to discuss the DC Questions in relation to Ardagh Packaging Finance PLC (Issue numbers 2025100602, 2025102701 and 20252901) and agreed to meet again on 6 November 2025 to continue its discussions.
  11/05/2025 10:35am EST
- DC Deliberating
  
  EMEA DC Meeting Statement 5 November 2025
  The EMEA DC met on 4 November 2025 to further discuss how best to address each of the current DC Questions relating to Ardagh Packaging Finance PLC in as efficient a manner as possible.
  The Majority of the EMEA DC has Resolved to withdraw the first DC Question (Q1) (Issue number: 2025100602) from External Review in order to permit deliberation of the question together with Q2 (Issue number: 2025102701) and Q3 (Issue number: 2025102901) and, if necessary, a single External Review process for all three DC Questions relating to whether a Restructuring Credit Event has occurred in respect of Ardagh Packaging Finance PLC. After further consideration of the matters set out in the EMEA DC Statement of 31 October 2025 and with the objective of providing the market with timely determinations, the Majority of the EMEA DC concluded that whilst the additional information submitted with Q2 and Q3 relates to facts that occurred after Q1 was raised, the purpose of the withdrawal power in DC Rule 4.6(a) is to ensure that the EMEA DC and the External Review Panel have the ability to consider all of the facts relating to a Reviewable Question and the additional information is relevant to the manner and most efficient process for resolution of the DC Question (also applying the spirit of DC Rule 4.3(d) which refers to the grouping of multiple Reviewable Questions for purposes of efficiency); and more broadly to the overall substantive resolution of the relevant DC Question – being whether a Restructuring Credit Event occurred in respect of Ardagh Packaging Finance PLC, and if so, when. The remaining Members of the EMEA DC did not vote in favour of withdrawing the question for the reasons previously set out in the EMEA DC Meeting Statement of 31 October 2025, including, inter alia, that "the withdrawal power was not presently applicable to Q1".
  The EMEA DC will provide a further update in due course on its deliberations of each of DC Questions 1-3 following the withdrawal noted above. The EMEA DC is meeting again on 5 November 2025 to continue discussions.
  DC Decision
  11/05/2025 05:10am EST
- External Review
  
  EMEA DC Meeting Statement 4 November 2025
  Since the EMEA DC held a binding vote on DC Issue 2025100602 and triggered the External Review process, the EMEA DC has been engaging with potential External Review Panel members to appoint them to the panel, such that the External Review can be resolved in a timely manner. The EMEA DC is now able to appoint the External Review Panel. Following such appointment, the referral to the External Review Panel is now effective for the purposes of Section 4 of the DC Rules.
  ISDA Members (as defined in the DC Rules) may submit Written Materials in support of either the “Yes” or “No” positions to External Reviewers via the DC Secretary. The deadline for submission of Written Materials is Tuesday 11 November 2025. Note that the Written Materials are subject to prescribed parameters under Section 4.5(c) of the DC Rules. ISDA Members looking to make submissions should ensure that any submissions comply with those requirements. In particular, please note that each ISDA Member submitting information to the DC Secretary shall be deemed to represent and warrant that such information has been disclosed and can be made public without violating any law, agreement or understanding regarding the confidentiality of such information and each DC Party may rely on such representation. ISDA Members should note that (i) there is no need to submit as supporting exhibits the press releases or the transaction support agreement cited on the DC website for this issue as these are expected to form part of the advocates’ submissions in any event, and (ii) the EMEA DC does not consider that the consent solicitation statement which is referred to in the press releases of Ardagh Group SA constitutes public information, and as such it may not be submitted as an exhibit in any Written Materials, nor used as part of a supporting argument.
  Further details of the External Review process, including the timetable, will be published in due course.
  DC Decision
  DC Secretary’s contact details
  11/04/2025 09:50am EST
- External Review
  
  EMEA DC Meeting Statement – 31 October 2025
  The EMEA DC met on 30 October 2025 to discuss the External Review in respect of Ardagh Packaging Finance PLC, following the Restructuring Credit Event DC Question raised on 7 October 2025 (Issue number: 2025100602) (Q1). The EMEA DC has previously held a binding vote on Q1 and did not Resolve it by Supermajority, thus triggering the External Review process in respect of Q1.
  Two further Restructuring Credit Event DC Questions have since been raised in relation to the Reference Entity, on 27 October 2025 (Issue number: 2025102701) (Q2) and 29 October 2025 (Issue number: 2025102901) (Q3). Each of Q2 and Q3 has been accepted by the EMEA DC for deliberation in accordance with DC Rule 2.2.
  Pursuant to DC Rule 2.4(d) the Convened DC may not commence deliberations in respect of a DC Question until a separate but related DC Question completes External Review. The EMEA DC considered this DC Rule and concluded that Q1 was a related DC Question in respect of each of Q2 and Q3 for the purposes of DC Rule 2.4(d). The EMEA DC reached this conclusion because each of the DC Questions Q2 and Q3 relates to whether or not related events have triggered a Restructuring Credit Event in respect of the same Reference Entity as Q1.
  Therefore, the EMEA DC noted that in order for the EMEA DC to commence deliberations on Q2 and Q3, it would require that the EMEA DC either dismiss Q1 or withdraw Q1 from External Review. The EMEA DC did not consider it would be appropriate to dismiss Q1 at this time.
  In relation to the power under DC Rule 4.6(a) to withdraw Q1 from the External Review process, the EMEA DC noted that this would apply where new information exists that is relevant to the resolution of Q1 and such information was not available to the EMEA DC on or prior to the binding vote for Q1. In its deliberations on Q1, the EMEA DC considered the factual matrix which applied as of the time the DC Question was raised. Whilst the EMEA DC noted that additional announcements had been made by the Reference Entity prompting Q2 and Q3, the EMEA DC concluded that these announcements related to underlying facts which occurred only after the point in time as of which Q1 would be determined as of and therefore the announcements did not constitute new information relevant to the resolution of Q1. Accordingly, on the basis of DC Rule 4.6(a), the EMEA DC considered that the withdrawal power was not presently applicable to Q1.
  The EMEA DC noted that in due course each of Q2 and Q3 would similarly be considered by the EMEA DC by reference to the factual matrix which applied as of the time the relevant DC Question was raised, taking into account the information pertaining to such factual matrix that is available to the EMEA DC at the time of the relevant binding vote. Deliberations in respect of Q2 and Q3 will only commence once the restrictions in DC Rule 2.4(d) are no longer applicable. The EMEA DC will provide a further update on the relevant pages of the DC website once the EMEA DC commences deliberations in respect of Q2 and Q3.
  The EMEA DC notes that timely resolution of DC Questions is important and is working to complete the External Review process in respect of Q1 as soon as practicable.
  DC Decision
  10/31/2025 06:35am EDT
- External Review
  
  EMEA DC Meeting Statement - 28 October 2025
  The EMEA DC met on 28 October 2025 to continue discussions as to the External Review in respect of Ardagh Packaging Finance PLC. The EMEA DC intends to appoint the External Review Panel as soon as practicable and is aiming to do so in the course of the week commencing 3 November 2025.
  10/28/2025 11:15am EDT
- External Review
  
  EMEA DC Meeting Statement - 24 October 2025
  The EMEA DC met on 24 October 2025 to continue discussions as to the External Review in respect of Ardagh Packaging Finance PLC, and in particular in relation to the appointment of the External Review Panel.
  The EMEA DC agreed to meet again on 28 October 2025 to continue its deliberations.
  10/24/2025 10:20am EDT
- External Review
  
  EMEA DC Meeting Statement – 23 October 2025
  The EMEA DC met on 22 October 2025 to commence discussions as to the External Review in respect of Ardagh Packaging Finance PLC.
  While the EMEA DC does not intend to publish a detailed meeting statement following the DC Decision dated 21 October 2025, please note that written briefs will be published on the DC website in due course in connection with the External Review process.
  The Reviewable Question is “Has a Restructuring Credit Event occurred with respect to Ardagh Packaging Finance PLC?”. The potential answers are “Yes” and “No”. The timetable for the External Review will be published in due course following the appointment of the External Review Panel. Note that in accordance with the DC Rules, the timetable can be varied by the EMEA DC as necessary. The Submission Deadline will be published in due course.
  The EMEA DC is currently contacting potential External Review Panel members and will reconvene in due course.
  DC Decision
  10/23/2025 10:20am EDT
- External Review
  
  DC Decision
  The EMEA DC held a binding vote on the Restructuring Credit Event DC Question. As there was no Supermajority, the External Review process in Section 4 of the DC Rules is triggered in respect of the Restructuring DC Question. The EMEA DC will meet again tomorrow to discuss next steps on the External Review.
  10/21/2025 09:00am EDT
- Ongoing
  
  DC Decision
  10/20/2025 10:00am EDT
- Ongoing
  
  EMEA DC Meeting Statement 16 October 2025
  The EMEA DC met on 16 October 2025 to discuss the DC Question in relation to Ardagh Packaging Finance PLC.
  The EMEA DC agreed to meet again on 20 October 2025 to continue its deliberations.
  10/16/2025 11:00am EDT
- Ongoing
  
  EMEA DC Meeting Statement 14 October 2025
  The EMEA DC met on 14 October 2025 to discuss the DC Question in relation to Ardagh Packaging Finance PLC.
  The EMEA DC agreed to meet again on 16 October 2025 to continue its deliberations.
  DC Decision
  10/14/2025 04:10pm EDT
- Ongoing
  
  DC Decision
  10/13/2025 02:40pm EDT
- Ongoing
  
  EMEA DC Meeting Statement 10 October 2025
  The EMEA DC met on 10 October 2025 to discuss the DC Question in relation to Ardagh Packaging Finance PLC.
  The EMEA DC agreed to meet again on 14 October 2025 to continue its deliberations. [Note: updated from 13 October for the US public holiday]
  10/10/2025 03:40pm EDT
- Ongoing
  
  EMEA DC Meeting Statement 8 October 2025
  The EMEA DC met on 8 October 2025 to commence its deliberations in relation to Ardagh Packaging Finance PLC.
  The EMEA DC agreed to meet again on 10 October 2025 to continue its deliberations.
  10/08/2025 10:30am EDT
- Request Accepted by DC
  
  10/07/2025 10:40am EDT
- Pending DC Consent
  
  10/07/2025 04:20am EDT