The article discusses the problematic aspect of voluntary submission to criminal liability by the accused. In the course of the analysis, an attempt was made to solve the issue regarding the necessity of directly admitting guilt by the accused while applying the institution specified in Article 387 of the Criminal Code. It was noticed that in the legal discourse conducted so far, there have been views that have drawn incorrect conclusions regarding the theses presented by common courts and the Supreme Court, which were replicated in further case-law and publications. The author tries to demonstrate that there is no prerequisite for the accused to use this consensual procedure upon articulating their “admission of guilt,” as the mere submission of the relevant application implies a statement of committing the alleged prohibited act by the accused.