What is the difference between an administrator-led insolvency plan (continental Europe) and a US Chapter 11?

a debtor-initiated procedure aimed at restructuring rather than liquidation. An appointed insolvency administrator runs the process (not the debtor's management). It requires a majority of creditors within each class plus a majority of the classes; a cram-down is possible. A 'debtor-in-possession'-style option (self-administration) can let the debtor's management stay on. Reforms over the past decade have moved the regime closer to Chapter 11.

debtor-in-possession (DIP) — management stays in office. The automatic stay protects against creditor actions. A developed DIP-financing market provides new money with super-senior status. A plan of reorganization is voted by class; cram-down via the best-interests test.