1. What Has Changed – and What Is Proposed
1.1 Service transactions added to the mandate
The draft 2026 Finance Law expands Tunisia’s e-Invoicing regime by bringing service transactions into scope alongside existing covered flows.
1.2 Timing and legislative status
The draft was published on 14 October 2025. If adopted, the new coverage would take effect on 1 January 2026. Until publication in the official journal, treat this as proposed.
2. Current E-Invoicing Status (Before the Draft Takes Effect)
2.1 Transactions already covered
- B2G: All transactions involving state and local public entities.
- High-volume B2B: Medicines and fuels between professionals (retail excluded).
2.2 Who is already in scope
- Large businesses overseen by the Large Enterprises Directorate when transacting with public bodies.
- Professional sellers in the medicines and fuel supply chains for B2B flows.
3. Platform and Process (Centralized Clearance)
3.1 Enrollment and onboarding
Taxpayers file the e-invoicing declaration and onboard to the national platform known as El Fatoora, operated via Tunisie TradeNet (TTN).
3.2 Format and signatures
Invoices are issued in XML according to TTN’s definitions and carry an electronic signature from the issuer to ensure authenticity and integrity.
3.3 Submission, validation, and archiving
Signed XML invoices are transmitted to TTN for registration and validation. Each invoice receives a unique identification code, is archived centrally, and the data is made available to the Ministry of Finance.
3.4 Exchange with buyers
Issuers may provide a paper copy to the buyer when needed, provided it’s clearly marked as a copy and includes the information required to verify the e-invoice.
4. Controls and Auditability
4.1 Integrity and traceability
The signature at issuance anchors authenticity, and TTN validations reinforce data quality. The platform’s unique reference enables end-to-end audit trails from issuance through retrieval.
4.2 Reconciliation readiness
Structured XML supports consistent totals, taxes, and identifiers, simplifying reconciliation across ERP, the platform, and statutory reporting.
5. Penalties and Enforcement
5.1 Paper invoices where e-invoicing is mandatory
Fines range from TND 100 to TND 500 per invoice, capped at TND 50,000.
5.2 Non-compliant e-invoices
Fines start at TND 250 and can rise up to TND 50,000 when technical or content requirements are not met.
5.3 Effective date for penalties
The penalty framework has applied since 1 July 2025 for taxpayers already within the mandate.
6. Readiness Plan for Service Providers (Go-Live: 1 Jan 2026)
6.1 Governance and setup
- Complete platform declaration and onboarding.
- Arrange certificate lifecycle management for e-signatures.
- Assign owners for exception handling.
6.2 Data and validation
- Map ERP fields to the XML schema (buyers, VAT IDs, item tax treatment, totals).
- Run pre-submission checks for mandatory mentions and arithmetic consistency.
6.3 Connectivity and monitoring
- Build API/web-service integration to TTN.
- Capture acknowledgments and store the unique identification code back in ERP.
- Track rejections and remediate within defined cut-offs.
6.4 Evidence and retention
- Retain original signed XML and transmission logs.
- Ensure fast retrieval from the state archive and provide compliant buyer copies when requested.
7. Timeline at a Glance (Subject to Enactment)
- 14 Oct 2025: Draft Finance Law 2026 published, proposing service coverage.
- 1 Jul 2025: Penalties in force for taxpayers already covered.
- 1 Jan 2026: Service transactions become mandatorily e-invoiced if the draft is approved.
