UK “schemes of arrangement” are “outside” the scope of the European Regulation on Insolvency Proceedings. What does “outside” actually mean?

However, the new text retains the system of Annexes according to which Member States must bring to the Commission’s notice those proceedings they deem included in ERIP bis, to those not thus notified, the European text shall not apply. Such derogation means, among other things, that the excluded proceedings may not benefit from the automatic recognition system provided for in art. 19 ERIP bis («1. Any judgment opening insolvency proceedings handed down by a court of a Member State which has jurisdiction pursuant to Article 3 shall be recognised in all other Member States from the moment that it becomes effective in the State of the opening of proceedings. […]»)…