A registered letter feels like it stops time. You pay for the stamp, you keep the receipt, somebody signs for it on the other side. Surely the law notices.
In Paris, Berlin and London, it doesn't. The same envelope that restarts the limitation clock in Madrid does nothing at all in Lyon, and most finance teams find this out the way nobody wants to: from the debtor's lawyer.
Auld Lang Sign: a one-minute case file
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Dublin, New Year's Eve, 23:58. Cormac Doyle, owner of Doyle Taverns, raises a pint. At midnight, a €184,000 invoice turns three.
Three weeks earlier. Hannelore Brandt, finance director at Brandt Kältetechnik in Hamburg, keeps the beer cold in 900 pubs. Doyle Taverns has owed her €184,000 since March 2023. Every December she sends a registered reminder, and she is sure it stops the clock. Her chairman asks why a letter would stop a clock. She can't explain it. Under German law, it doesn't.
Uwe from the warehouse offers to drive to Dublin and take the coolers back. They are full of Guinness. So Hannelore calls Orla Quinlan, a local collector in Dublin, with twenty-one days left.
Orla checks whose clock it is: the seller is in Hamburg and the contract chose no other law, so German law applies, with a three-year period that started at the end of 2023 and runs out at midnight on 31 December 2026. She checks what stops it: reminder letters do nothing; genuine negotiations and a court claim pause it; a written acknowledgment restarts it. She gives Cormac two options: sign an eight-month payment plan today, or face a court claim filed before the deadline, with interest at nine points over the base rate, and costs. On 30 December, he signs.
At midnight, Cormac toasts the statute of limitations. Orla reminds him that he signed a new clock the day before. On 2 January the first €23,000 arrives, on time. In February, Cormac opens pub number twelve and asks for coolers. Payment upfront.
Lesson: a reminder is a letter. A signature is a new clock.
A Collecty film. © Collecty, www.cllcty.com. Reproduction without permission is not allowed. All characters and companies are fictional. General information, not legal advice.
A small test before you read on
Pick the oldest unpaid invoice on your overseas ledger. Now explain, out loud and in order, three things: which country's limitation clock applies to it, on what date that clock started, and what you have done since that legally stopped it.
Most people who run credit for a living answer the first question with confidence and stall somewhere in the second. Psychologists call this the illusion of explanatory depth: we feel we understand familiar mechanisms until someone asks us to explain them step by step. Invoices are familiar. Limitation law is a mechanism.
Whose clock is it?
Not the debtor's, necessarily. In the EU and the UK, the limitation period is governed by the law that governs the contract. If your contract doesn't choose a law, a sale of goods is usually governed by the law of the seller's country, and a service contract by the law of the provider's country.
So a Hamburg supplier selling to a pub group in Dublin is usually running on a German clock, even if the case ends up in an Irish court. A Spanish seller whose customer is in France is usually running on a Spanish one. This is the question most people skip, and it decides every answer after it.
When did it start?
Usually on the day payment fell due. Germany is the exception worth remembering: the standard three-year period starts at the end of the year in which the claim arose. An invoice due in March 2023 doesn't expire in March 2026. It expires at midnight on 31 December 2026.
If you have German-law invoices from 2023 still open, that date is closer than it looks.
What actually stops it?
Here the countries stop agreeing with each other.
| Contract law | Typical period for an unpaid invoice | Does a written demand stop the clock? | What does |
|---|---|---|---|
| England and Wales | 6 years from the due date | No | A signed written acknowledgment or a part payment restarts it; issuing a claim stops it |
| Germany | 3 years from the end of the year it fell due | No | Genuine negotiations pause it; an acknowledgment or part payment restarts it; a court claim or payment order pauses it |
| France | 5 years between businesses | No, not even by registered letter | The debtor's acknowledgment restarts it; a court claim interrupts it |
| Spain | 5 years | Yes: a documented demand (typically a burofax) restarts it | Also court claims and acknowledgment |
| Italy | 10 years for a one-off sale | Yes: a formal written demand restarts it | Also court claims and acknowledgment |
| Netherlands | 5 years | Yes: a written demand or clear reservation of rights restarts it | Also court claims and acknowledgment |
The same letter, from the same printer, is legally decisive under Spanish law and legally decorative under French law.
"But we were negotiating"
German law pauses the clock while genuine negotiations are underway and lets it run again once they stall. Courts look at whether both sides were actually engaging with the claim, not whether you kept writing. A debtor who replies "we're looking into it" twice a year may not have negotiated at all. English law has no pause of this kind.
The move that works nearly everywhere
A written acknowledgment of the debt, signed by the debtor, or a part payment. In every system in the table, one of those restarts or protects the clock. That's why a signed payment plan is more than a cash-flow arrangement: it is also a new starting date.
The other move that works everywhere is filing: a court claim, or an application for a payment order. It costs more, and it has to be filed in time, not drafted in time.
What to do this week
Sort your overseas ledger by governing law, not by debtor country. For each invoice more than two years old, write down when its clock started and the last thing that legally stopped it. Not the last thing you sent. If the honest answer to the second question is "a reminder", read the table again.
If you'd like a second pair of eyes on the clock for your oldest overseas invoices, Collecty's local collectors check limitation dates as the first step of every case. Tell us about the invoice.