County Court Money Claims: Bundle Preparation for Debt and Payment Disputes

Last updated: March 2026

Quick Answer

A county court money claim bundle is the organised set of documents you present at a hearing when pursuing — or defending — a claim for money owed. Whether the dispute involves an unpaid invoice, a loan that was never repaid, or a contractual payment that went missing, the bundle should include particulars of claim, defence, witness statements, contracts, invoices, bank statements, and correspondence. For claims allocated to the fast track or multi-track, CPR Part 39 and Practice Direction 39A set out the bundle requirements. Small claims have fewer formal rules, but a well-prepared bundle still matters.

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How Money Claims Work in the County Court

Money claims — sometimes called "debt claims" or "payment disputes" — are among the most common types of civil litigation in England and Wales. They cover everything from a tradesperson chasing an unpaid invoice to a business recovering a six-figure contractual debt.

The process begins when the claimant issues a claim, either online through Money Claims Online (MCOL) or by filing an N1 claim form at court. The defendant then has 14 days to respond — by admitting the claim, filing a defence, or acknowledging service (which extends the deadline for a defence to 28 days).

Track Allocation

Once a defence is filed, the court allocates the claim to one of three tracks:

The track determines not just the procedural rules but also the costs regime. On the small claims track, costs recovery is severely limited. On the fast track and multi-track, the losing party may be ordered to pay the winner's reasonable costs.

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Particulars of Claim: The Foundation of Your Case

The particulars of claim set out the factual and legal basis for your money claim. They must be clear, concise, and contain enough detail for the defendant to understand what is being alleged.

What Your Particulars Should Include

1. The parties — who is suing whom, and in what capacity
2. The basis of the claim — contract, debt, unjust enrichment, or other legal basis
3. The facts — what happened, in chronological order
4. The amount claimed — broken down into the principal debt, interest, and any other sums
5. Interest calculation — the statutory or contractual basis for interest and how it has been calculated
6. The remedy sought — what you want the court to order

Interest on Money Claims

You are entitled to claim interest on a debt, and failing to do so is leaving money on the table. The two main bases are:

Your bundle should include a clear interest calculation showing the start date, rate, daily accrual, and total interest claimed to the date of the hearing.

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The Defence: Understanding the Other Side's Case

Once you receive the defendant's defence, read it carefully. It will tell you which parts of your claim the defendant admits, which parts they deny, and what positive case they are running.

Common Defences to Money Claims

Understanding the defence is essential because it tells you which issues are in dispute and what evidence you need to include in your bundle to address them.

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Judgment in Default: When No Defence Is Filed

If the defendant fails to file a defence within the deadline, you can apply for judgment in default. This is effectively a win without a hearing — the court enters judgment for the amount claimed.

How to Obtain Default Judgment

For a specified sum (a fixed amount of money), you can request default judgment online or by filing form N225. The court will enter judgment for:

• The amount claimed
• Interest to the date of judgment
• Fixed costs (as set out in CPR Part 45)
• The court fee

Default judgment does not require a hearing or a bundle. However, if the defendant subsequently applies to set aside the judgment, you may need to prepare a bundle for the set-aside hearing.

When Default Judgment Is Not Available

Default judgment is not available where:

• The claim is for an unspecified sum (the court must assess the amount at a hearing)
• The defendant has acknowledged service and the time for filing a defence has not yet expired
• The claim is against the Crown
• Certain specialist proceedings apply

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Preparing Your Money Claim Bundle

If the claim proceeds to a hearing, you will need to prepare a bundle. The claimant is usually responsible for preparing the bundle, though the defendant may contribute documents.

Bundle Contents for Money Claims

Formatting Requirements

For fast track and multi-track cases, CPR Practice Direction 39A paragraph 3 sets out the bundle requirements:

• The bundle should be paginated consecutively throughout
• Each page should be numbered in the bottom right-hand corner
• An index should appear at the front, listing each document with its page number
• Documents should be arranged in chronological order
• Only relevant documents should be included — bundles must not contain unnecessary material
• Duplicate documents should be removed
• The bundle should be filed at court not less than 3 days (fast track) or 7 days (multi-track) before the hearing

The Letter Before Action

Before issuing a money claim, the Pre-Action Protocol for Debt Claims requires the claimant to send a Letter Before Action (LBA). This letter should give the debtor at least 30 days to respond. Your bundle should include:

• A copy of the LBA you sent
• Proof of posting or delivery
• Any response from the debtor
• Evidence that you complied with the Pre-Action Protocol

Failure to follow the Pre-Action Protocol can result in costs penalties, even if you win the case.

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Practical Tips for Money Claim Bundles

1. Tell a Clear Story

Your bundle should tell the story of the dispute from beginning to end. A District Judge reading the bundle for the first time should be able to understand what happened, why money is owed, and why it has not been paid — all without needing to hear oral evidence.

2. Include a Chronology

For anything beyond the simplest claim, include a chronology at the front of the bundle. List the key dates and events in a table format:

3. Cross-Reference Everything

Your witness statement should refer to specific page numbers in the bundle. For example: "I refer to the signed contract at page [B/12]" or "The invoice is at page [C/45]." This makes it easy for the judge to follow your evidence.

4. Keep It Proportionate

A money claim for £5,000 does not need a 300-page bundle. Include only documents that are directly relevant to the issues in dispute. Quality matters more than quantity.

5. Include Proof of the Debt

This sounds obvious, but it is the most common failing. If you are claiming for an unpaid invoice, include:

• The contract or agreement
• Evidence that you performed your obligations (delivery note, completion certificate, etc.)
• The invoice itself
• Evidence that the invoice was received
• Bank statements showing that payment was not received

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Using BundleCreator for Money Claims

Preparing a professional bundle for a money claim — with consecutive pagination, an index, and proper formatting — is straightforward with BundleCreator.

BundleCreator lets you:

• Upload contracts, invoices, bank statements, and correspondence
• Organise documents into sections that tell a clear, chronological story
• Apply automatic consecutive pagination across the entire bundle
• Generate a hyperlinked index for easy navigation
• Add PDF bookmarks for each document
• Export a court-ready electronic bundle that meets CPR requirements

For sole traders, small businesses, and anyone chasing a debt without legal representation, BundleCreator turns hours of manual formatting into minutes of focused preparation.

Create your money claim bundle with BundleCreator →

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Frequently Asked Questions

How much does it cost to issue a money claim?

Court fees depend on the amount claimed. As at March 2026, fees range from £35 (claims up to £300) to £10,000 (claims of £200,001 or more). Claims issued online through MCOL attract a small discount. Fee remission is available for those on low incomes.

How long does a county court money claim take?

From issuing the claim to receiving a judgment, the timeline varies considerably. If the defendant does not file a defence, default judgment can be obtained within 4-6 weeks. If the case is defended and goes to a hearing, expect 6-12 months or longer, depending on the court's listing capacity and the track allocation.

What is the limitation period for money claims?

For claims based on a simple contract (including most invoices and agreements), the limitation period is 6 years from the date the cause of action accrued — typically the date payment was due. For claims under deed, the period is 12 years. After the limitation period expires, the claim is time-barred.

Can I claim solicitor's costs if I win?

On the small claims track, costs recovery is limited to the court fee, travel expenses, and a small sum for loss of earnings. On the fast track, you can recover fixed costs under CPR Part 45. On the multi-track, costs are assessed on a standard or indemnity basis and can be substantial.

What if the defendant cannot pay?

Obtaining a judgment is one thing; enforcing it is another. If the defendant has no assets, a judgment may be of limited practical value. Before issuing a claim, consider whether the defendant is likely to be able to pay. Enforcement options include warrants of control (bailiffs), third-party debt orders, attachment of earnings, and charging orders.

Do I need to send a Letter Before Action?

Yes. The Pre-Action Protocol for Debt Claims requires a Letter Before Action giving the debtor at least 30 days to respond. Failure to comply with the protocol can result in costs penalties and delay.

Can I issue a money claim against someone outside England and Wales?

Jurisdiction for money claims against parties outside England and Wales depends on the contract terms, the location of the defendant, and whether international treaties or regulations apply. If the defendant is within the UK but outside England and Wales, different rules may apply. Take advice on jurisdiction before issuing.

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This article is provided for general informational purposes only and does not constitute legal advice. The law and procedure described applies to England and Wales. If you are unsure about your specific situation, seek independent legal advice.