Tunisia's government released its 2026 Finance Bill on October 14, 2025, proposing to expand mandatory electronic invoicing requirements to cover all services alongside existing goods transactions, with the changes taking effect January 1, 2026.

Article 56 of the bill amends Section III, Paragraph II, Subparagraph 5 of Article 18 of the VAT Code to require e-invoices for all service provision. The current regime mandates e-invoicing for business-to-government transactions by large enterprises registered with Tunisia's tax authority, plus business-to-business transactions involving pharmaceuticals and fuels.

The expansion follows Tunisia's establishment of a comprehensive penalty framework through Administrative Note 10/2025 issued in June 2025. Financial penalties range from 100-500 TND per paper invoice for transactions subject to e-invoicing requirements, with caps at 50,000 TND, while missing mandatory e-invoice fields incur 250-10,000 TND per invoice. Criminal penalties for serious violations including fake invoices or fictitious transactions carry 16 days to three years imprisonment and fines between 1,000-50,000 TND.

The penalty regime implemented in phases, with sanctions for missing mandatory e-invoice fields effective from January 1, 2025, and penalties for issuing paper invoices or transporting goods without e-invoice copies taking effect from July 1, 2025. Upon parliamentary approval, the tax administration is expected to issue additional technical regulations clarifying implementation requirements for the expanded mandate.

Context

The proposed expansion represents a significant step in Tunisia's digital tax transformation strategy, moving from sector-specific e-invoicing to comprehensive coverage of both goods and services. This aligns with broader regional trends toward mandatory e-invoicing systems and reflects Tunisia's commitment to enhancing tax compliance, transparency, and administrative efficiency through digital infrastructure.