Electronic invoicing is one of the key pillars of the modernization of the Tunisian tax system. After an initial phase mainly targeting certain sales transactions, the legislator has taken a further step with the Finance Law for the year 2026, extending the scope of electronic invoicing to service provision activities.
This development, introduced by Article 53 of Law No. 17 of 12 December 2025, imposes new obligations on the professionals concerned and requires adequate preparation.
1. Reminder of the Previous Legal Framework
Until 31 December 2025, Tunisian tax legislation required VAT-registered taxpayers who are not subject to the lump-sum regime to issue an invoice for the transactions they carry out. Such invoices had to include a number of mandatory details, in particular the identification of the parties, a description of the transaction, the price excluding VAT, and the amount of VAT.
The legislation already allowed the use of electronic invoices, but their use was mandatory only in specific cases, notably:
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transactions carried out with the State, local authorities, and public establishments;
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certain business-to-business transactions, such as the sale of medicines and fuel between professionals (excluding retailers).
The technical electronic invoicing system is operated via the national platform managed by Tunisie TradeNet, in accordance with Government Decree No. 1066 of 2016.
2. Extension of Electronic Invoicing to Service Provision
As part of the ongoing process to gradually generalize electronic invoicing, Article 53 of the Finance Law for 2026 provides for the extension of its scope to service provision transactions, effective from 1 January 2026.
The following are now concerned:
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natural and legal persons providing services, whether as a main or secondary activity;
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including service providers subject to the non-commercial profits (BNC) regime, who were traditionally required to issue fee notes (notes d’honoraires).
Accordingly, fee notes are assimilated to invoices and are subject to the same electronic invoicing obligations, in line with existing tax regulations.
It should be noted that these service providers remain subject to:
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the obligation to file a declaration of existence,
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the invoicing rules set out in the VAT Code,
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as well as record-keeping and tax compliance requirements.
3. Services Excluded from the Scope of Electronic Invoicing
Certain transactions remain excluded from the scope of electronic invoicing. These include in particular:
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documents that may replace invoices in sectors with specific characteristics (contracts, account statements, debit/credit notes, etc.);
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services directly linked to the core activity of goods sellers, except where such services are declared as a secondary activity (e.g. transport or installation ancillary to a sale).
These exclusions aim to take into account professional practices and operational constraints specific to certain sectors.
4. Penalties for Non-Compliance
Failure to comply with electronic invoicing obligations exposes the offender to tax penalties provided for under Article 71 of the Finance Law for 2025, including:
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a fine ranging between TND 100 and TND 500 per invoice issued in paper form in violation of the electronic invoicing requirement;
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with an overall cap set at TND 50,000.
The same penalties apply to electronic invoices issued without the mandatory required information.
5. Entry into Force and Transitional Measures
These new provisions apply as from 1 January 2026, on a progressive basis, in parallel with the development of the dedicated information systems.
On a transitional basis, service providers who have initiated the process of joining the electronic invoicing system but have not yet completed all technical formalities may continue to issue paper invoices in accordance with the applicable legislation, until their full integration into the network.
However, service providers who are legally required to join the system must submit an application for enrollment with the authorized entity.
Conclusion
The extension of electronic invoicing to service providers represents a major milestone in the digitalization of the Tunisian tax environment. It requires the professionals concerned to undertake technical and organizational preparation to ensure compliance and avoid penalties.
Businesses and service providers are therefore strongly encouraged to seek the assistance of their chartered accountant to assess their situation, adapt their internal procedures, and secure a smooth transition to electronic invoicing.