How to Collect an International Debt: The Creditor Playbook

To collect an international B2B debt, follow six sequential phases: verify the claim is valid and within the debtor’s local limitation period; send a formal demand in the debtor’s legal language through the locally recognised statutory channel; instruct a licensed local partner in the debtor’s country; conduct a 30 to 45-day amicable recovery phase; file the appropriate payment order or civil action if amicable recovery fails; and enforce the enforceable title through the local bailiff. The governing framework in the EU is Brussels I Recast (Regulation 1215/2012) — a judgment from any EU member state court is directly enforceable in all other member states without any recognition procedure. Globally, the New York Convention 1958 covers 172 states for enforcement of arbitral awards. The most urgent operational fact for any creditor starting this process: limitation periods vary dramatically — Germany closes at 3 years, Spain at 5, France at 5, Italy at 10, Canada at 2 — and a time-barred claim is unenforceable regardless of how strong the underlying documentation is.

Your debtor is in Frankfurt. The invoice is 120 days past due. Emails are ignored. Your domestic lawyer has politely explained they cannot act outside your jurisdiction. You are now choosing between writing off EUR 95,000 or instructing someone who can actually do something in Germany. What this article gives you is the exact sequence of actions between that choice and recovered funds — starting with the verification step that determines whether the file is worth pursuing in the first place.

6 phasesCollection process

172 statesNY Convention enforcement

Brussels IEU auto-enforcement 27 states

How do you collect an international debt?

Phase 1: Verify the claim and check the limitation period. Germany: 3 years from end of the year the invoice fell due (§195 BGB, Jahresultimo §199 BGB). Spain: 5 years from invoice due date (Art.1964 CC, Law 42/2015). France: 5 years (Art.2224 Code civil). Italy: 10 years (Art.2946 c.c.). England and Wales: 6 years (§5 Limitation Act 1980). UAE: 10 years commercial (Art.95 Commercial Transactions Law). Canada Ontario: 2 years from discovery. If the claim is close to the limitation, the first action — even before a demand — is to interrupt the clock by filing a court claim or instructing a local partner to send a demand.

Phase 2: Formal demand in the debtor’s legal language. Germany: registered post, Einschreiben mit Rückschein, citing BGB §288 interest (base rate + 9pp B2B). Spain: burofax via Correos, citing Ley 3/2004 (ECB+8pp + EUR 40 per invoice). Italy: raccomandata con ricevuta di ritorno or PEC certified email. France: lettre recommandée avec accusé de réception (LRAR). UAE: Arabic formal demand letter via registered post or notary. UK: Letter Before Action under the Pre-Action Protocol for Debt Claims.

3 yrsGermany §195 BGBJahresultimo — resets 31 Dec

5 yrsSpain Art.1964 CCLaw 42/2015 — was 15yr

6 yrsUK §5 Limitation ActEngland and Wales

10 yrsItaly Art.2946 c.c.Restarts on each interruption

2 yrsCanada OntarioLimitations Act 2002 — shortest G7

What are the payment order procedures across major jurisdictions?

Phase 5: File the correct payment order for the debtor’s jurisdiction. Germany: Mahnverfahren under ZPO §§688-703d. Electronic filing, approximately €36 court fee, debtor has 14 days to oppose, enforceable in 4 to 6 weeks if uncontested. Italy: decreto ingiuntivo under CPC Arts.633-656, 30 to 60 days, 40-day opposition window. Spain: proceso monitorio under LEC Arts.812-818, no monetary ceiling since Law 37/2011, 20-day debtor response window. France: injonction de payer under CPC Arts.1405-1425, 4 to 8 weeks. EU cross-border: European Order for Payment under Regulation 1896/2006, no ceiling, standardised Form A, 30-day debtor opposition window, directly enforceable across all 27 EU member states. UAE: Article 62 payment order under Federal Decree-Law 42/2022. UK: statutory demand under Insolvency Act 1986 §123 (for uncontested claims ≥ £750, 21-day opposition window).

Collection process

1

Limitation check + formal demand

Verify claim against debtor jurisdiction limitation period. If clear: formal demand in local language via correct statutory channel. Cite statutory interest + fixed compensation. Interrupt limitation clock immediately.

2

Licensed local partner + amicable phase

Route to FENCA/BDIU/ACA-certified local partner in debtor country. 30–45 day amicable phase in local language. 70–80% of undisputed files resolve here without legal action.

3

Payment order + bailiff enforcement

Mahnverfahren (DE), decreto ingiuntivo (IT), monitorio (ES), EOP (EU cross-border), Art.62 (UAE), statutory demand (UK). Enforceable title → local bailiff → bank account attachment in days.

How does Brussels I Recast enable EU enforcement without exequatur?

Brussels I Recast — Regulation (EU) 1215/2012 — abolished the exequatur procedure for EU member state judgments on 10 January 2015. A final judgment from a German court is directly enforceable in France, Spain, Italy, Poland, or any other EU member state without any recognition procedure in the destination country. The creditor presents a certified copy of the judgment and the Article 53 certificate to the competent enforcement authority in the destination member state. The local bailiff executes directly.

The European Account Preservation Order (EAPO, Regulation 655/2014) goes further: it allows a creditor to freeze bank accounts across EU member states before a judgment is even obtained, preventing asset dissipation during proceedings. A French creditor with a French judgment against an Italian manufacturer can instruct an Italian ufficiale giudiziario directly. The practical implication: a creditor can enforce simultaneously in multiple EU member states under the same title.

You know the debt is real. What you need now is someone on the ground in the right jurisdiction who can make it cost the debtor more to ignore it than to pay it. Contact Cosmopolite for a free case assessment. No win, no fee.