The Tunisian Ministry of Finance has published General Memorandum No. 10 of 2025, explaining Article 71 of Law No. 48 of 2024 (Finance Law for 2025). The Memorandum outlines new penalties and enforcement measures designed to strengthen compliance with Tunisia’s Continuous Transaction Control (CTC) electronic invoicing system, which was established in 2016 and is managed by Tunisia Trade Net (TTN).
Electronic invoicing is currently mandatory for:
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Transactions with the state, local communities, public institutions, and public enterprises by businesses (B2G) under the jurisdiction of the Large Enterprises Administration
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B2B transactions for medicines and fuels between professionals (excluding retailers)
The system requires electronic invoices to contain the same mandatory information as paper invoices, including transaction details, tax identification numbers, and VAT information. E-invoices must include electronic signatures and a unique reference assigned by TTN.
Key Changes
The new provisions introduce stronger penalties to ensure compliance with electronic invoicing obligations:
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Stricter Penalties: Fines of 100-500 dinars (€30-150) per paper invoice issued when electronic invoicing is required (maximum 50,000 dinars/€15,000)
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E-Invoice Compliance: Fines of 250-10,000 dinars (€75-3,000) for electronic invoices missing mandatory information
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Transportation Requirements: Fine of 20% of transported goods value (minimum 500 dinars/€150) for goods not accompanied by paper copies of electronic invoices
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System Harmonization: Alignment of electronic and paper invoicing systems by adopting the same documentation for goods transportation
These penalties will apply to violations related to electronic invoices without mandatory information from 1 January 2025, and to other violations from 1 July 2025.
The General Memorandum indicates that these measures are designed to further support compliance with the existing electronic invoicing system in Tunisia. Through targeted penalties and system harmonization, Tunisian authorities are focusing on strengthening the implementation of the current framework to ensure higher levels of adherence among businesses already subject to these requirements.
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