Home / Advice Hub / What a UK debt collection agency can (and cannot) do with a commercial invoice

Corporate Debt · 28 August 2026

What a UK debt collection agency can (and cannot) do with a commercial invoice

What a UK debt collection agency can legally do with a commercial invoice, what is a criminal offence, and when court enforcement agents (not the agency) take over.

A UK debt collection agency instructed on a commercial invoice can demand the sum, add statutory late-payment figures where the 1998 Act applies, and get the file ready for a county court claim. It cannot seize stock, freeze a bank account, or walk into the debtor’s premises as if it were a court officer.

Debt Collection UK (a trading style of PASECOM GROUP LTD) introduces B2B files to independent partner agencies. We are not solicitors, we are not authorised by the Financial Conduct Authority, and we do not collect consumer credit. PASECOM GROUP LTD was incorporated in April 2026. Recovery is not guaranteed.

What can a debt collection agency do with a commercial invoice?

On an unpaid invoice for goods or services between businesses, a partner agency can do the work your credit-control team has already started, with more formality and a clear next step.

That usually means:

  • writing to the limited company at its registered office, and to any trading address you have given
  • setting out the invoice numbers, dates, contract or purchase order, what was supplied, and the outstanding principal
  • adding statutory interest and the fixed £40, £70 or £100 compensation where the Late Payment of Commercial Debts (Interest) Act 1998 applies
  • sending a letter before action that sets out the claim in the way the court expects
  • taking telephone and email contact that is reasonable, not a campaign of alarm
  • telling you, plainly, whether a county court claim is proportionate on the documents you have uploaded

A partner agency does not “award” the debt. The claim remains yours. If reminders have already failed, instruct a debt collection agency through the secure form on this site. We introduce the file. We do not issue proceedings.

Does a commercial invoice sit inside FCA debt-collecting rules?

Article 39F of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 makes “debt-collecting” a specified activity where someone takes steps to procure payment of a debt due under a credit agreement or a consumer hire agreement.

A typical unpaid invoice between two limited companies for goods or a service is a simple contract debt. It is not, by itself, that kind of agreement. Collecting it is not automatically the specified activity in article 39F.

That is not a free pass. If the file is actually a regulated credit agreement, or the debtor is an individual on a consumer product, collecting it without the right permission is a different matter. This site is for B2B commercial invoices. We are not FCA-authorised and we do not take consumer files.

What a debt collection agency cannot do

The criminal line is in section 40 of the Administration of Justice Act 1970. A person commits an offence if, with the object of coercing payment of a contractual debt, they:

  • harass the other with demands whose frequency, manner, occasion, threat or publicity is calculated to cause alarm, distress or humiliation
  • falsely represent that criminal proceedings lie for failure to pay
  • falsely represent themselves as authorised in some official capacity to claim or enforce payment
  • put out a document they know does not have the official character it pretends to have

Reasonable, otherwise lawful steps to secure payment, or to enforce a liability by legal process, are carved out of the harassment limb (section 40(3)). Sending a clear demand is not an offence. Pretending to be the court, a bailiff, or the police is.

An agency also cannot take control of goods. Section 63 of the Tribunals, Courts and Enforcement Act 2007 says an individual may act as an enforcement agent only if they hold a certificate, they are exempt (for example a court officer), or they act under the direction of someone who is. Knowingly or recklessly purporting to act as an enforcement agent without that authority is itself an offence (section 63(6)).

So an agency cannot:

  • enter the debtor’s warehouse or office and remove stock because you instructed them
  • clamp a vehicle, change the locks, or “attend with a van”
  • freeze a bank account
  • issue a county court judgment
  • threaten prison for an unpaid commercial invoice

Those steps, where they exist at all, belong to the court and to certified enforcement agents after a judgment. They do not start when you upload an invoice.

From invoice to enforcement: who actually has the power?

The path is sequential. Skipping it does not make the later powers appear.

1. Pre-action correspondence. Where no specific protocol applies, Practice Direction – Pre-Action Conduct and Protocols paragraph 6 expects the claimant to write with concise details of the claim: the basis, a summary of the facts, what is wanted, and if money, how the amount is calculated. The defendant should have a reasonable time to reply. Litigation is a last resort (paragraph 8). A partner agency can send that letter. Silence on the letter is not a CCJ.

2. A county court claim. GOV.UK states that you can apply to a county court to claim money you are owed by a person or business, online or by post. The court, not the agency, issues the claim. You decide whether to litigate. We do not.

3. Judgment. GOV.UK is blunt: a judgment means the court has formally decided that the money is owed. It is not a cheque. If it is ignored, you can be taken back to court.

4. A warrant of control. Only after a court has ordered payment and the defendant is in arrears can you apply for a warrant of control. HMCTS guidance states that a warrant gives court enforcement agents the authority to take goods from the defendant’s home or business to settle the debt. In the county court they can try to recover up to £5,000 on a warrant; above that you transfer the judgment to the High Court. The court cannot guarantee you will get the money. There may be nothing belonging to a company at its registered office.

That last step is enforcement. It is not what happens when a debt collection agency first writes.

How Debt Collection UK uses a partner agency

We take the instruction and get it moving. You upload the invoice, the contract, and the amount. We introduce a partner agency to collect. The partner sends the demands, keeps the file moving, and tells you if a claim is the next honest step.

We do not conduct reserved legal work. We do not hold ourselves out as High Court Enforcement Officers. Partners collect; the footer and terms say so. If you want the invoice pursued, use the secure form on the unpaid invoices page or the agency page. There is no promise that the debtor will pay.

Frequently asked questions

Can a debt collection agency take goods from my customer’s warehouse?
No. Taking control of goods is for certified or exempt enforcement agents under section 63 of the Tribunals, Courts and Enforcement Act 2007, and only after a warrant or writ of control. An agency letter is not that warrant.

Do I need an FCA-authorised agency for a limited-company invoice?
Collecting a typical commercial invoice for goods or services between limited companies is not the specified “debt-collecting” activity in article 39F, which is about credit agreements and consumer hire. This site still does not take consumer files, and we are not FCA-authorised.

Can they visit the debtor’s office?
A visit is not a right of entry. Pretending to be authorised in an official capacity to enforce payment is an offence under section 40 of the Administration of Justice Act 1970. Reasonable contact is not the same as attending with the powers of a court enforcement agent.

Can they add interest and the £40, £70 or £100?
On a qualifying late commercial debt, yes, if the 1998 Act applies and the calculation is honest. See statutory interest on late commercial debts. Adding the figures does not compel payment.

Will instructing an agency get me a CCJ automatically?
No. A CCJ is a court judgment after a claim. The agency can prepare the file and a partner can help you issue if you choose to. The court decides.

Can Debt Collection UK collect the invoice ourselves?
No. We introduce B2B files to independent partner agencies. You instruct through this site; they collect. We are not solicitors and we are not FCA-authorised.

Leave this invoice with us

1 Upload
2 We deal with it
3 You get paid
Contract or purchase order (optional)

B2B invoices only. No upload fee. 15% only if you get paid. Submissions email pete@pasecom.co.uk.