Regulatory updates - Tunisia

On December 12, 2025, the Finance Law for 2026 was published. Among numerous provisions, it includes an amendment to the VAT Code expanding the scope of mandatory electronic invoicing. This change aligns with Tunisia's ongoing tax reform and digital transformation efforts to improve efficiency in tax administration.

Previously, e-invoicing was already mandatory for:

• Business-to-Government (B2G) transactions with the State, local authorities, and public entities conducted by enterprises under the scope of the Large Enterprises Directorate; and
• Sales of medicines and fuels between professionals, excluding retailers.

The VAT Code amendment now extends the e-invoicing requirement to include service provision operations.

Further clarification and implementation guidance are expected to be published by the authorities. Businesses operating in Tunisia, along with their tax advisors, should assess how these changes affect their business models and ensure they meet the new compliance requirements.

The Finance Law 2026 is effective from January 1, 2026. 

On October 14, 2025, the draft 2026 Finance Law was published, proposing an extension of the e‑invoicing scope by mandating compliance for service transactions.

Service transactions added to existing mandate scope

This extension follows Administrative Note No. 10/2025 issued earlier this year, which introduced penalties for non‑compliance. Today, the Tunisian e‑invoicing mandate already requires all B2G transactions, as well as fuels and pharmaceutical transactions, to be reported to the centralized government platform.

Timeline

If adopted, the amendment would enter into force starting January 1, 2026.

Tunisia began implementing its electronic invoicing system nearly a decade ago, following the enactment of the Finance Law of 2016 and decree No. 2016-1066 (p. 171) of August 15, 2016. Initially focusing on large taxpayers, the obligations now extend to encompass public sector transactions (B2G) as well as high-volume transactions in medicines and fuel.

Who is in the scope?

The following taxpayers are in the scope of the Tunisian e-invoicing mandate:

• Large businesses: businesses under the Large Enterprises Directorate for transactions carried out with the State, local authorities, and public establishments and companies;
• B2G transactions: transactions carried out with the state, local authorities and public institutions;
• B2B transactions of medicines and fuels: sales of medicines and fuel between professionals, with the exception of retailers.

How do taxpayers comply with the mandate?

Taxpayers in scope must take several actions to comply with the Tunisian e-invoicing obligation:

1. Taxpayers must submit a declaration for e-invoicing: before issuing e-invoices, taxpayers are required to file a declaration with the Tunisian Tax Authority;
2. Issue invoices to the central e-invoicing platform: the central e-invoicing infrastructure, the "El Fatoora" system, will be managed by Tunisia Trade Net (TTN). Taxpayers must send their invoices in XML format compliant with the definitions set out by TTN, VAT requirements, and include an electronic signature;
3. TTN validates and reports invoice data: TTN validates and distributes all invoices to the Tunisian Ministry of Finance, and the invoice receives a unique identification code upon receipt;
4. TTN archives and forwards invoices: Tunisia Tradenet archives the e-invoice and may issue a copy to the recipient or the issuer upon request;
5. Paper copies are allowed for buyer exchange: issuers are authorized to deliver a paper copy to the buyer, provided it is clearly marked as a copy and includes the necessary information to verify the validity of the e-invoice.

Penalties

The Tunisian Code of Tax Duties and Procedures has been amended to define non-compliance by any taxpayer in scope. Starting July 1, 2025, the following penalties will apply:

• Failure to issue e-invoices compliant with mandatory specifications may result in fines ranging from 250 to 50,000 TND;
• Continued issuance of paper invoices may result in fines ranging from 100 to 500 TND for each invoice, capped at 50,000 TND.

Stay tuned with Pagero to receive the latest information as Tunisia continues its roll-out of the e-invoicing obligation.