Data · Limitation periods

How long can a company chase a debt? Limitation periods for commercial debt by country

The limitation period for an unpaid B2B invoice is three years in Germany, six in England and Wales and ten in Italy and Switzerland. One table with the period, the start rule, the legal basis and a source for each country.

How long can a company chase a debt? The short answer

It depends on the law that governs the contract. For an unpaid B2B invoice the general limitation period is three years in Germany, China and South Africa, five years in the Netherlands, Spain, Hungary and Saudi Arabia, six years in England and Wales and Singapore, and ten years in Italy, Switzerland, Sweden and Mexico. Once it has run out, the debtor can raise the time limit as a defense, and you can usually no longer get a court order for payment.

The table below covers 23 countries and the United States. Each row names the legal basis and links to the source, with the date it was checked. Many countries also have shorter special periods for particular claims, such as rent, interest or professional fees. This page is general information, not legal advice.

Which country's limitation period applies

The limitation period comes from the law that governs the contract, not from the court that hears the case. In the EU, the law applicable to a contract governs "prescription and limitation of actions" (Rome I Regulation, Article 12(1)(d)). Courts in England and Wales follow the same idea: where another country's law applies, "the law of that other country relating to limitation shall apply" (Foreign Limitation Periods Act 1984, s.1(1)(a)).

Without a choice of law clause, an EU court applies the law of the seller's country to a sale of goods and the law of the service provider's country to services (Rome I, Article 4(1)(a) and (b)). An Italian supplier selling to a German buyer with no choice of law clause is therefore likely to have Italy's ten years, not Germany's three. A clear clause removes the doubt: see contract clauses for selling abroad.

Limitation periods for commercial debt by country

General limitation period for a claim to payment of a B2B invoice, as of 27 October 2026. Click a country for our guide to collecting there.

CountryLimitation period for a B2B invoiceWhen it startsLegal basisSource and date checked
Austrália6 years in New South Wales; 3 years in the Northern Territory. Each state and territory sets its own periodFrom the date the cause of action first accruedLimitation Act 1969 (NSW), s.14; Limitation Act 1981 (NT), s.12AustLII (NSW s.14), checked 21 July 2026
Áustria3 years for claims for goods, work or services supplied in a business; 30 years as the general ruleWhen the right could first have been exercisedABGB §1486 no. 1; §1478RIS, Bundeskanzleramt, checked 27 October 2026
Bélgica10 years for personal actions, including contract claimsFrom when the right of action aroseCode civil (former), art. 2262bis §1Constitutional Court, judgment 164/2014, quoting the article, checked 27 October 2026
CanadáOntario: 2 years, and never more than 15 years after the act or omission. Each province sets its own periodFrom the day the claim was discovered (Ontario)Limitations Act, 2002 (Ontario), ss. 4 and 15Ontario e-Laws, checked 27 October 2026
China3 years, with a 20-year outer limitFrom when the creditor knew or should have known that its right was harmed and who the obligor isCivil Code, art. 188gov.cn, official English text, checked 27 October 2026
Chipre6 years; 3 years for fees of lawyers, doctors, architects, engineers, contractors and other professionalsFrom the day the cause of action was completeLaw 66(I)/2012 on limitation of actionable rights, art. 7CyLaw, checked 27 October 2026
Chéquia3 years, with a 10-year objective limitFrom the day the right could first be exercisedCivil Code (Act 89/2012 Coll.), s.629e-Sbírka, checked 15 September 2026
Alemanha3 anosFrom the end of the year in which the claim arose and the creditor learned of it and of the debtorBGB §195 and §199(1)§195; §199, checked 27 October 2026
Hungria5 anosWhen the claim falls dueCivil Code (Act V of 2013), s.6:22Jogtár consolidated text, checked 27 October 2026
Índia3 anosDepends on the type of claim; for an open running account, from the close of the year in which the last item was enteredLimitation Act 1963, Schedule, Article 1India Code, checked 17 September 2026
Itália10 years; 5 years for periodic payments such as interestFrom the day the right can be enforcedCodice civile, arts. 2946, 2948 and 2935Ragioneria Generale dello Stato (art. 2946), checked 27 October 2026
Malta5 years for debts from commercial transactions, unless a shorter period applies or the debt results from a public deedFrom the day the action can be exercisedCivil Code (Cap. 16), arts. 2156(f) and 2137legislation.mt, checked 27 October 2026
México10 years, unless the Commercial Code sets a shorter period for the claimFrom the day the action could legally be broughtCódigo de Comercio, arts. 1047 and 1040Cámara de Diputados, checked 27 October 2026
Países Baixos5 years for a claim to performance of a contract; 20 years as the general ruleFrom the day after the claim fell dueBurgerlijk Wetboek, arts. 3:307(1) and 3:306wetten.overheid.nl, checked 27 October 2026
Polónia3 years for claims linked to running a business (6 years as the general rule); the period ends on the last day of a calendar yearFrom the day the claim became dueKodeks cywilny, arts. 118 and 120 §1Sejm, Dz.U. 2025 poz. 1071, checked 27 October 2026
Portugal20 years as the ordinary period; a 2-year presumption of payment applies to sales to buyers that are not merchants or do not buy for their tradeWhen the right can be exercisedCódigo Civil, arts. 309, 317 and 306(1)PGD Lisboa, checked 27 October 2026
Arábia Saudita5 years for claims within the jurisdiction of the commercial courtsFrom the date of the cause of action, unless the defendant confirms the claim or the claimant gives the court an acceptable reasonLaw of Commercial Courts, art. 24Ministry of Justice, checked 27 October 2026
Singapura6 anosFrom the date the cause of action accruedLimitation Act 1959, s.6(1)(a)Singapore Statutes Online, checked 27 October 2026
África do Sul3 anosAs soon as the debt is due, but not before the creditor knows who the debtor is and the facts of the debtPrescription Act 68 of 1969, ss. 11(d) and 12Department of Justice, checked 27 October 2026
Espanha5 years for personal actions without a special periodFrom the day performance of the obligation can be demandedCódigo Civil, arts. 1964(2) and 1969BOE, checked 27 October 2026
Suécia10 years; 3 years for claims against consumersFrom when the claim arosePreskriptionslag (1981:130), 2 §Riksdagen, checked 27 October 2026
Suíça10 years; 5 years for specific claims such as craft work, retail sales of goods and lawyers' feesWhen the claim falls dueCode of Obligations, arts. 127, 128 and 130(1)Fedlex (version of 1 October 2026), checked 27 October 2026
Reino UnidoEngland and Wales: 6 years. Scotland: 5 years (the obligation is extinguished by prescription)England and Wales: from the date the cause of action accruedLimitation Act 1980, s.5; Prescription and Limitation (Scotland) Act 1973, s.6 and Schedule 1 para. 1(g)legislation.gov.uk (s.5); legislation.gov.uk (Scotland s.6), checked 27 October 2026
Estados UnidosSet by each state; see the note below the tableUnder the UCC, when the breach occursState law; UCC §2-725 for sales of goodsCornell LII (UCC §2-725), checked 27 October 2026

United States: each state sets its own period

There is no federal limitation period for an unpaid business invoice; state law decides. For contracts for the sale of goods, the Uniform Commercial Code says an action "must be commenced within four years after the cause of action has accrued", and the parties may reduce the period "to not less than one year but may not extend it" (UCC §2-725). States adopt the UCC in their own statutes. For other contracts the period varies by state: New York, for example, allows six years for "an action upon a contractual obligation or liability, express or implied" (CPLR §213). Check the state whose law governs your contract, or see our guide to debt collection in the United States.

How to stop the clock

Every country lists the acts that restart or pause the limitation period. The debtor's acknowledgment, a part payment and court action appear almost everywhere. A reminder letter counts in some countries and not in others:

CountryWhat restarts or pauses the period
England and WalesIf the debtor acknowledges the claim or makes any payment, the right is treated as accruing again on that date (Limitation Act 1980, s.29(5)). The acknowledgment must be in writing and signed (s.30(1))
AlemanhaAn acknowledgment, for example a part payment or an interest payment, restarts it (BGB §212(1)). Serving a court payment order (Mahnbescheid) pauses it (§204(1) no. 3), and so do negotiations until one side ends them (§203)
Países BaixosA written reminder (schriftelijke aanmaning) or a written notice in which you clearly reserve your right to payment interrupts it (BW art. 3:317(1))
SuéciaInterrupted when the debtor acknowledges the claim, receives a written demand or reminder, or when you go to court; a new period then runs from that day (Preskriptionslag 5 § and 6 §)
PolóniaInterrupted by an action before a court or enforcement authority, or by the debtor acknowledging the claim; after each interruption it runs again (Kodeks cywilny, arts. 123 §1 and 124 §1)
HungriaInterrupted by the debtor acknowledging the debt, an agreed change or settlement, or court action that ends in a final decision (Civil Code, s.6:25(1))

Keep the proof: a signed acknowledgment, a bank record of the part payment or the dated reminder.

What to do before the period runs out

  1. Note the limitation date when the invoice falls due, under the law that governs the contract.
  2. Escalate on a schedule. Reminders, then a final demand: see our demand letter templates and what to do about unpaid invoices.
  3. Ask for a written acknowledgment or a payment plan. In many countries in the table, an acknowledgment restarts the period.
  4. Hand over in time for legal action. A court claim, a European payment order or enforcement abroad all take time to prepare: see enforcing a judgment abroad.
  5. Do not threaten court action you can no longer take. If a claim is time-barred and you still ask the debtor to pay, do not suggest that court action is still possible.

Interest keeps running while you wait, and you can usually add it to the claim: see late payment interest by country.

How Debitura fits

Hand over well before the limitation date. A claim that is already time-barred is not eligible for collection on Debitura. For live claims, we match your case to a vetted local partner in the debtor's country, based on the type of debtor, the claim and how partners perform on our platform, in 180 countries.

One Standard Debt Collection Agreement covers pre-legal collection of undisputed unpaid invoices in every country we serve. There is no upfront cost: you pay a success fee only when money is recovered, from 6% in Europe and 7.5% elsewhere, depending on claim size and the debtor's country (see pricing). Legal action is optional, quoted separately and only starts if you accept the quote.

See how our commercial collection agency service works, the steps in how it works, what B2B debt collection involves, and our guide to international debt collection.

Frequently asked questions

How long can a company chase a debt?

As long as the limitation period of the law that governs the contract. For a B2B invoice that is three years in Germany, China and South Africa, five years in the Netherlands, Spain and Hungary, six years in England and Wales and Singapore, and ten years in Italy, Switzerland and Sweden. The debt still exists afterwards, but the debtor can refuse to pay and a court will usually not order payment.

What is the limitation period for an unpaid invoice in the UK?

In England and Wales, six years from the date the cause of action accrued (Limitation Act 1980, s.5). In Scotland, a contractual obligation is extinguished after five years without a relevant claim or acknowledgment (Prescription and Limitation (Scotland) Act 1973, s.6).

Does sending a reminder restart the limitation period?

In some countries it does. In the Netherlands a written reminder interrupts the period, and in Sweden a written demand or reminder does too. In England and Wales and in Germany a reminder on its own is not one of the listed acts: you need the debtor's acknowledgment or a payment, or court action.

Can I still collect a time-barred debt?

The debt does not disappear, but you can usually no longer enforce it in court. In Hungary, for example, a time-barred claim cannot be enforced in court proceedings, but money the debtor pays on it cannot be claimed back (Civil Code, s.6:23). Time-barred claims are not eligible for collection on Debitura.

Which country's limitation period applies to a cross-border invoice?

The law that governs the contract. In the EU that law also governs prescription and limitation (Rome I, Article 12(1)(d)). Without a choice of law clause, a sale of goods is usually governed by the law of the seller's country.

Is the limitation period different for consumer debts?

Sometimes. In Sweden, a claim against a consumer for goods or services supplied by a business is time-barred after three years instead of ten. This page covers claims between businesses.

Can the parties change the limitation period in the contract?

It depends on the country. In Poland, limitation periods cannot be shortened or extended by agreement (Kodeks cywilny, art. 119). In Hungary, an agreement that changes the period must be in writing (Civil Code, s.6:22(3)). Under the US UCC, parties to a sale of goods may shorten the period to not less than one year.

When does the limitation period start?

It differs. In Hungary, South Africa and Switzerland it starts when the claim falls due. In Germany it starts at the end of the year in which the claim arose and the creditor knew about it. In China and in Ontario it runs from when the creditor knew or discovered the claim.

Sources

  1. EUR-Lex, Regulation (EC) No 593/2008 on the law applicable to contractual obligations (Rome I), Articles 4 and 12 (2008). eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008R0593
  2. legislation.gov.uk, Foreign Limitation Periods Act 1984, section 1 (1984). www.legislation.gov.uk/ukpga/1984/16/section/1
  3. AustLII (NSW s.14), Australia: Limitation Act 1969 (NSW), s.14; Limitation Act 1981 (NT), s.12 (2026). classic.austlii.edu.au/au/legis/nsw/consol_act/la1969133/s14.html
  4. RIS, Bundeskanzleramt, Austria: ABGB §1486 no. 1; §1478 (2026). www.ris.bka.gv.at/NormDokument.wxe?Abfrage=Bundesnormen&Gesetzesnummer
  5. Constitutional Court, judgment 164/2014, quoting the article, Belgium: Code civil (former), art. 2262bis §1 (2026). fr.const-court.be/public/f/2014/2014-164f.pdf
  6. Ontario e-Laws, Canada: Limitations Act, 2002 (Ontario), ss. 4 and 15 (2026). www.ontario.ca/laws/statute/02l24
  7. gov.cn, official English text, China: Civil Code, art. 188 (2026). english.www.gov.cn/archive/lawsregulations/202012/31/content_WS5fedad9
  8. CyLaw, Cyprus: Law 66(I)/2012 on limitation of actionable rights, art. 7 (2026). www.cylaw.org/nomoi/enop/non-ind/2012_1_66/full.html
  9. e-Sbírka, Czechia: Civil Code (Act 89/2012 Coll.), s.629 (2026). www.e-sbirka.cz/sb/2012/89
  10. §195, Germany: BGB §195 and §199(1) (2026). www.gesetze-im-internet.de/bgb/__195.html
  11. §199, Germany: BGB §195 and §199(1) (2026). www.gesetze-im-internet.de/bgb/__199.html
  12. Jogtár consolidated text, Hungary: Civil Code (Act V of 2013), s.6:22 (2026). net.jogtar.hu/jogszabaly?docid=a1300005.tv
  13. India Code, India: Limitation Act 1963, Schedule, Article 1 (2026). upload.indiacode.nic.in/schedulefile?aid=AC_CEN_3_20_00005_196336_1517
  14. Ragioneria Generale dello Stato (art. 2946), Italy: Codice civile, arts. 2946, 2948 and 2935 (2026). www.rgs.mef.gov.it/_Documenti/VERSIONE-I/CIRCOLARI/2017/27/Codice_Civi
  15. legislation.mt, Malta: Civil Code (Cap. 16), arts. 2156(f) and 2137 (2026). legislation.mt/getpdf/69c3abbb1b75750ef87a6312
  16. Cámara de Diputados, Mexico: Código de Comercio, arts. 1047 and 1040 (2026). www.diputados.gob.mx/LeyesBiblio/pdf/CCom.pdf
  17. wetten.overheid.nl, Netherlands: Burgerlijk Wetboek, arts. 3:307(1) and 3:306 (2026). wetten.overheid.nl/BWBR0005291/
  18. Sejm, Dz.U. 2025 poz. 1071, Poland: Kodeks cywilny, arts. 118 and 120 §1 (2026). api.sejm.gov.pl/eli/acts/DU/2025/1071/text.pdf
  19. PGD Lisboa, Portugal: Código Civil, arts. 309, 317 and 306(1) (2026). www.pgdlisboa.pt/leis/lei_mostra_articulado.php?nid=775&tabela=leis&ar
  20. Ministry of Justice, Saudi Arabia: Law of Commercial Courts, art. 24 (2026). www.moj.gov.sa/Documents/Regulations/pdf/En/96.pdf
  21. Singapore Statutes Online, Singapore: Limitation Act 1959, s.6(1)(a) (2026). sso.agc.gov.sg/Act/LA1959
  22. Department of Justice, South Africa: Prescription Act 68 of 1969, ss. 11(d) and 12 (2026). justice.gov.za/legislation/acts/1969-068.pdf
  23. BOE, Spain: Código Civil, arts. 1964(2) and 1969 (2026). www.boe.es/buscar/act.php?id=BOE-A-1889-4763
  24. Riksdagen, Sweden: Preskriptionslag (1981:130), 2 § (2026). www.riksdagen.se/sv/dokument-och-lagar/dokument/svensk-forfattningssam
  25. Fedlex (version of 1 October 2026), Switzerland: Code of Obligations, arts. 127, 128 and 130(1) (2026). www.fedlex.admin.ch/eli/cc/27/317_321_377/de
  26. legislation.gov.uk (s.5), United Kingdom: Limitation Act 1980, s.5; Prescription and Limitation (Scotland) Act 1973, s.6 and Schedule 1 para. 1(g) (2026). www.legislation.gov.uk/ukpga/1980/58/section/5
  27. legislation.gov.uk (Scotland s.6), United Kingdom: Limitation Act 1980, s.5; Prescription and Limitation (Scotland) Act 1973, s.6 and Schedule 1 para. 1(g) (2026). www.legislation.gov.uk/ukpga/1973/52/section/6
  28. Legal Information Institute, Cornell Law School, Uniform Commercial Code §2-725, Statute of limitations in contracts for sale (2026). www.law.cornell.edu/ucc/2/2-725
  29. New York State Senate, New York CPLR §213, Actions to be commenced within six years (2026). www.nysenate.gov/legislation/laws/CVP/213
  30. legislation.gov.uk, Limitation Act 1980, section 29 (fresh accrual on acknowledgment or part payment) (1980). www.legislation.gov.uk/ukpga/1980/58/section/29
  31. legislation.gov.uk, Limitation Act 1980, section 30 (formal provisions for acknowledgments) (1980). www.legislation.gov.uk/ukpga/1980/58/section/30
  32. gesetze-im-internet.de, BGB §212 Neubeginn der Verjährung (2026). www.gesetze-im-internet.de/bgb/__212.html
  33. gesetze-im-internet.de, BGB §204 Hemmung der Verjährung durch Rechtsverfolgung (2026). www.gesetze-im-internet.de/bgb/__204.html
  34. gesetze-im-internet.de, BGB §203 Hemmung der Verjährung bei Verhandlungen (2026). www.gesetze-im-internet.de/bgb/__203.html

Reviewed by the Debitura team, October 2026.