Why signing a document titled "Acknowledgment of Obligations" does not automatically mean an acknowledgment of debt

The District Court in Brno recently dismissed a lawsuit filed by an accounting entrepreneur who sought payment of over 122,000 CZK for accounting services rendered. The case clearly demonstrates the importance of correctly drafting legal documents and why the mere title of a document is insufficient to produce the intended legal effects.

The plaintiff had a long-standing collaboration with the defendant entrepreneur, for whom she managed accounting, processed payroll, and prepared tax returns. When the client encountered financial difficulties and stopped paying invoices, she attempted to secure her receivables with a written document. In October 2018, she presented him with a document titled "Acknowledgement of Debts", which contained a list of all outstanding invoices for the years 2016 to 2018. The client signed the document without reservation and affixed the company stamp.

The problem arose when the plaintiff filed the lawsuit in August 2025 – almost seven years after the oldest invoices were issued. She relied on the signed document constituting a valid acknowledgement of debt under the Civil Code, which would extend the statute of limitations to ten years. However, the court did not rule in her favor.

What the Court Found Fault With in the Document's Wording

The key issue was that the document did not contain any explicit declaration of the debtor's will, by which he would acknowledge the debts as to their reason and amount. Instead, it merely contained the creditor's request for approval of the liabilities and a list of invoices. The court evaluated the client's signature below the text as a mere approval of accounting data, not as a qualified acknowledgement of debt.

The court emphasized a fundamental rule: a legal act is always assessed by its actual content, not by the document's title. Therefore, the fact that the document was titled "Acknowledgement of Debts" had no legal significance, as its content did not clearly and unequivocally indicate the debtor's intention to acknowledge his debt.

An acknowledgement of debt under Section 2053 of the Civil Code is, in fact, an obligatorily causal legal act. This means that the economic reason for the obligation must be evident from it – a mere reference to invoice numbers without further explanation is insufficient if the document does not simultaneously demonstrate a clear will of the debtor to acknowledge the debt. Furthermore, the law requires a written form, which precludes inferring acknowledgement from oral statements or implied conduct, such as booking invoices.

Practical Lessons for Entrepreneurs

The ruling provides important conclusions for practical application. If you, as a creditor, wish to secure your receivables through an acknowledgement of debt, the document must contain an explicit declaration by the debtor, that they acknowledge a specific debt to a specific creditor. It is not enough for the creditor to compile a list of receivables and for the debtor merely to sign it – the text must unequivocally show that the debtor actively expresses the will to acknowledge their debt.

A correctly formulated acknowledgement of debt should include, for example, the following wording: "I hereby acknowledge my debt to company XY in the amount of 122,718.50 CZK arising from accounting services rendered according to invoices no. ... and I undertake to pay it by..." The difference compared to a mere inventory of liabilities is fundamental – it is an active expression of the debtor's will, not a passive agreement with an accounting overview.

The plaintiff also argued in the proceedings that the defendant had claimed VAT deductions from the invoices in question with the tax office, thereby effectively acknowledging their validity. However, the court rejected this argument, stating that it was hearing a private law dispute and tax aspects were not relevant for assessing the matter. Even repeated verbal assurances from the debtor about the existence of the debt could not substitute for the missing written form of acknowledgment.

As a result of the incorrectly drafted document, the plaintiff was left with only the general three-year statute of limitations. Since the oldest invoices were issued in 2016 and the lawsuit was not filed until August 2025, the court found that the claims were time-barred. The defendant's objection of time-barring was not contrary to good morals, as the plaintiff had sufficient time to assert her right.

This case serves as a warning to all entrepreneurs who rely on informal or imprecisely drafted documents. In the field of contract law, it holds true that the form and content of a legal act determine its effects. Even a seemingly clear document with an unambiguous title can be interpreted by the court entirely differently than its author intended. Investing in quality legal drafting of documents therefore pays off much more than subsequent years of litigation with an uncertain outcome.

Source: District Court in Brno, file no. 117 C 202/2025-45