Statute of Limitations on Debt in Tennessee

Tennessee gives creditors six years to sue on most consumer debt, under the catch-all rule for “actions on contracts not otherwise expressly provided for.” A sale of goods can carry four years instead, and a judgment lasts ten years and can be renewed. Tennessee also has no statute saying what restarts the clock. That rule comes from the courts, and it is broad: a voluntary payment, or even an informal promise to pay, can keep a debt alive for another full period.

About our source for this state: the official Tennessee Code is published online through LexisNexis, and its site blocked our access with a captcha, which we did not try to get around. Every statutory figure on this page is instead taken from opinions of the Tennessee Supreme Court and Court of Appeals, published by the Tennessee Administrative Office of the Courts, that quote or apply the code. That is a secondary source for the statute text, so we cite the opinion behind each figure.

The deadlines, and where each one comes from

What is being collectedDeadline to file suitStatute
Actions on contracts not otherwise expressly provided for (most loans, accounts, and card agreements)6 yearsT.C.A. § 28-3-109(a)(3), as quoted in Benz-Elliott (Tenn. 2015) and Younger Family Trust (Tenn. Ct. App. 2025)
Breach of a contract for the sale of goods4 yearsT.C.A. § 47-2-725, as applied in Thomas v. Ken Smith Auto Parts (Tenn. Ct. App. 2023)
Enforcing a Tennessee judgment10 years, renewable under Tenn. R. Civ. P. 69.04T.C.A. § 28-3-110(a)(2), as applied in Wolfe v. Pugh (Tenn. Ct. App. 2026)

In Benz-Elliott v. Barrett Enterprises, No. M2013-00270-SC-R11-CV (Tenn. Jan. 23, 2015), the Tennessee Supreme Court held that a breach of contract claim “is governed by the six-year statute of limitations applicable to ‘[a]ctions on contracts not otherwise expressly provided for.’ Tenn. Code Ann. § 28-3-109(a)(3).” The Court of Appeals quoted the same section in Younger Family Irrevocable Trust v. Ross, No. E2024-01338-COA-R3-CV (Nov. 12, 2025): actions on contracts not otherwise expressly provided for “shall be commenced within six (6) years after the cause of action accrued.”

Courts apply that six-year rule to ordinary debts. In Price v. Hershberger (Tenn. Ct. App. Apr. 18, 2023) the court said that “a breach of contract action, such as the one at bar, is subject to a statutory, 6-year statute of limitations,” and in Deutsche Bank National Trust Co. v. Lee, No. M2018-01479-COA-R3-CV (June 13, 2019), it applied six years to a promissory note, noting that “Chapter 28 of the Tennessee Code does not otherwise expressly provide for actions regarding promissory notes.”

Six years or four? The goods question

The four-year rule in T.C.A. § 47-2-725 is part of Tennessee’s version of the Uniform Commercial Code and covers contracts for the sale of goods. In Thomas v. Ken Smith Auto Parts, No. E2022-00591-COA-R3-CV (Mar. 21, 2023), a business open account for auto parts was treated under “the applicable four-year statute of limitations found at Tenn. Code Ann. § 47-2-725,” and the parties agreed on appeal that four years applied.

What this means in practice: for a credit card, personal loan, or medical bill, the opinions we read point to six years. For a store account where you bought goods on credit from the seller itself, a four-year argument may exist. None of the opinions we read decides which rule applies to a consumer credit card, so we mark that as unresolved rather than guess.

What restarts the clock in Tennessee: the courts decide

The opinions we read cite no Tennessee statute on payments or acknowledgments. The rule is case law, and it is generous to creditors. In Thomas, the Court of Appeals quoted the Tennessee Supreme Court’s decision in Graves v. Sawyer, 588 S.W.2d 542 (Tenn. 1979):

[I]n the absence of evidence to the contrary, we hold that such a payment is an acknowledgment of the debt and implies a promise of payment which operates to keep the debt alive for the statutory period from that time.

The same opinion quoted the court’s earlier decision in Ingram v. Earthman, 993 S.W.2d 611 (Tenn. Ct. App. 1998): a defendant “may revive a plaintiff’s remedy that had been barred by the running of a statute of limitations either by expressly promising to pay the debt or by acknowledging the debt and expressing a willingness to pay it,” and the willingness to pay “may be implied from the defendant’s words or acts.”

In Thomas itself, the debtor’s statement that he would take care of the balance was treated as “a distinct and unconditional promise to pay,” even though it was “stated informally,” and it restarted the four-year period. The opinions we read do not require the promise to be in writing.

That is the reason to be careful in Tennessee. A small “good faith” payment, or telling a collector on the phone that you will pay, can be treated as restarting the clock. Whether it does in a particular case depends on the facts, and Tennessee courts have said the effect of a payment “depends, of course, upon the circumstances in which the payment is made.”

Judgments last a long time

If a creditor wins, the clock changes completely. In Wolfe v. Pugh, No. E2026-00043-COA-R3-CV (Sept. 30, 2026), the Court of Appeals explained that “a judgment creditor generally has ten years from the entry of a domestic judgment to seek to enforce it, Tenn. Code Ann. § 28-3-110(a)(2),” and that under Tennessee Rule of Civil Procedure 69.04 an unsatisfied judgment can be extended “for another ten years,” with the procedure repeatable “within any additional ten-year period.”

How often Tennessee consumers report collection problems

Tennessee consumers filed 5,627 debt collection complaints with the Consumer Financial Protection Bureau in the 12 months ending October 7, 2026, which is 1.8% of the 316,737 filed nationwide and ranks 19th among reporting states.

Of those, 901, or 16% of the Tennessee total, were categorized as a collector taking or threatening to take negative or legal action, against 25% nationally.

These are raw complaint counts, not rates. They are not adjusted for population, and a complaint is an allegation the CFPB has published, not a finding that a company broke the law. The figures refresh weekly from the CFPB’s public database.

If you are sued on a debt you believe is too old

The statute of limitations is an affirmative defense in Tennessee; the Deutsche Bank opinion cites Tennessee Rule of Civil Procedure 8.03 for that and notes that the burden of proof “rests on the party who raises the defense.” A person who does not respond to a collection suit can lose by default, and the resulting judgment can last decades.

Two Tennessee-specific things to check: whether the creditor claims a payment or a promise restarted the clock, and when; and whether the debt is a sale of goods that might fall under the four-year rule. Court deadlines are short, so this is a point at which speaking with a Tennessee attorney or a legal aid organization is worth the call.

How Tennessee compares

The same question gets a different answer a state line away. These are the closest comparisons to Tennessee:

  • Kentucky: next door, five to fifteen years depending on the writing and its date
  • North Carolina: next door, three years, and debt buyers cannot sue on expired debt
  • Georgia: next door, six years on a signed writing and four on an open account

The full comparison table covers every state we have published.

Sources and verification

The official Tennessee Code Annotated is published online by LexisNexis on behalf of the State. Its site required a captcha, which we did not bypass, so we did not read the code text directly. Statutory figures on this page come from these opinions, all retrieved from the Tennessee Administrative Office of the Courts website: Benz-Elliott v. Barrett Enterprises, LP, No. M2013-00270-SC-R11-CV (Tenn. Jan. 23, 2015); Edward Jackson Younger Family Irrevocable Trust v. Ross, No. E2024-01338-COA-R3-CV (Tenn. Ct. App. Nov. 12, 2025); Thomas v. Ken Smith Auto Parts, No. E2022-00591-COA-R3-CV (Tenn. Ct. App. Mar. 21, 2023); Price v. Hershberger (Tenn. Ct. App. Apr. 18, 2023); Deutsche Bank National Trust Co. v. Lee, No. M2018-01479-COA-R3-CV (Tenn. Ct. App. June 13, 2019); and Wolfe v. Pugh, No. E2026-00043-COA-R3-CV (Tenn. Ct. App. Sept. 30, 2026). Quotations of Graves v. Sawyer and Ingram v. Earthman are as they appear in Thomas. Opinions retrieved October 2, 2026. We will replace these with direct quotations of the code if we can read the official text. Complaint data: CFPB Consumer Complaint Database, filtered to the Debt collection product and the Tennessee state field over a rolling 12-month window, re-queried weekly by this site. Our data sources and update policy lists every figure on this site that refreshes automatically and how often.

This page explains what Tennessee courts have said about the statutes. It is general information, not legal advice. Because we did not read the official code directly, we have not described Tennessee’s rules on absence from the state or debts from other states, and we do not say which deadline applies to a consumer credit card.

Frequently asked questions

What is the statute of limitations on debt in Tennessee?

Six years for actions on contracts not otherwise expressly provided for, under T.C.A. § 28-3-109(a)(3), as the Tennessee Supreme Court applied it in Benz-Elliott v. Barrett Enterprises (2015). A contract for the sale of goods can carry four years under T.C.A. § 47-2-725.

Does a payment restart the statute of limitations in Tennessee?

Tennessee courts have held that it can. The Tennessee Supreme Court in Graves v. Sawyer (1979) said a voluntary, unconditional payment, absent evidence to the contrary, is an acknowledgment of the debt that keeps it alive for the statutory period from that time. An express promise to pay can do the same.

Does a promise to pay have to be in writing in Tennessee?

The opinions we read do not require it. In Thomas v. Ken Smith Auto Parts (2023), an informally stated promise to take care of the balance was treated as an unconditional promise that restarted the limitations period.

How long does a Tennessee judgment last?

Ten years under T.C.A. § 28-3-110(a)(2), and an unsatisfied judgment can be extended for another ten years under Tennessee Rule of Civil Procedure 69.04, with the procedure repeatable.