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Tunisia

Briefing document & Podcast: E-Invoicing & E-Reporting in Tunisia

11 hours ago
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SUMMARY

1. Executive Summary:

Tunisia has been a pioneer in e-invoicing in the Arab world, beginning in 2016. The system, based on a Continuous Transaction Control (CTC) model, initially focused on B2G transactions by large enterprises but has expanded significantly over time. The most recent expansion, effective January 1, 2026, brings nearly all B2B service transactions under the mandate. The system is managed through the national platform “El Fatoora” (TTN), requiring real-time clearance of invoices. Non-compliance is subject to financial penalties and potential criminal charges in cases of fraud. While the 2026 expansion initially had no grace period, authorities have signaled a “soft landing” approach, especially for SMEs, allowing for a more flexible initial implementation.

2. Key Themes and Developments:

  • Phased Implementation: Tunisia has gradually rolled out e-invoicing, starting with a narrow scope and expanding over time.
    • “Tunisia pioneered e-invoicing early and has gradually broadened its scope over the past decade.”
    • 2016: Mandatory for B2G invoices by large taxpayers (DGE).
    • 2018: Expanded to B2B sales of pharmaceuticals and hydrocarbons.
    • 2026: Expanded to virtually all service transactions subject to VAT.
  • Continuous Transaction Control (CTC): Tunisia uses a CTC model, requiring real-time clearance of invoices through the TTN platform before they are issued to customers.
    • “The national platform “El Fatoora” (run by Tunisie TradeNet, TTN) was launched under a continuous transaction control (CTC) model.”
    • “Invoice data must be sent to the authorities essentially at the time of issuance. The rule is that an invoice must be cleared through the TTN system before being issued to the customer.”
  • Strict Enforcement and Penalties: Penalties for non-compliance have been introduced and are being enforced.
    • “Finance Law 2025 (Article 71, enacted end of 2024) introduced a penalty regime for non-compliance, effective mid-2025.”
    • Fines range from TND 100 to TND 500 per paper invoice issued when an e-invoice is required, and TND 250 to TND 10,000 for non-compliant e-invoices.
    • Transporting goods without a compliant e-invoice (or equivalent) can result in a fine of 20% of the goods’ value (minimum TND 500).
    • “Furthermore, Tunisian law also provides for criminal penalties in cases of serious tax fraud via invoicing.”
  • Scope of Transactions: The mandate primarily covers domestic taxable B2B and B2G transactions.
    • “The e-invoicing mandate in Tunisia primarily targets domestic taxable transactions (sales subject to Tunisian VAT), with an emphasis on B2B and B2G deals.”
    • B2C transactions are not yet subject to mandatory e-invoicing.
    • Export sales do fall under the mandate if the issuer is an obligated taxpayer.
    • Import transactions are not covered by the mandate.
  • Taxable Persons in Scope: The obligation applies to VAT-registered entities in Tunisia, regardless of whether they are locally established or foreign companies with a Tunisian VAT number.
    • “If a foreign or non-established company is registered for VAT in Tunisia (e.g. via a local branch or fiscal representative) and engages in the transactions covered (such as providing services locally), it is subject to the same e-invoicing requirements as a locally established business.”
  • Data Requirements: E-invoices must adhere to a specific format (Tunisian Electronic Invoice Format – TEIF), an XML-based schema.
    • “Tunisia uses the Tunisian Electronic Invoice Format (TEIF), an XML-based format defined by the tax authorities.”
    • “A qualified electronic signature of the issuer (the supplier) to guarantee the invoice’s integrity and origin.”
    • A unique identifier/reference number from TTN.
    • A QR code (“visible electronic seal”).
  • Archiving: TTN handles the official archiving of e-invoices, relieving businesses of the need to maintain paper copies.
    • “The government-designated operator (TTN) is responsible for the official storage of all e-invoices in the system.”
    • “Businesses using the e-invoicing system are relieved from the need to keep paper archives of invoices.”
    • Invoices must be retained for at least 10 years.
  • No Pre-Filled VAT Returns: The e-invoicing system does not currently provide pre-filled VAT returns. Taxpayers are still responsible for compiling and filing their VAT declarations.
    • “As of the latest updates, Tunisia does not offer pre-filled (pre-populated) VAT returns based on the e-invoicing data.”
  • “Soft Landing” for 2026 Expansion: Although the 2026 expansion took effect on January 1, authorities have signaled a flexible approach, especially for smaller companies.
    • “However, in response to concerns (especially from SMEs) that the January 2026 deadline was tight, officials signaled a “soft landing” approach. In mid-January 2026 the Finance Ministry announced it would relax immediate enforcement for smaller companies, implying a more flexible, phased implementation even though the legal effective date remains 1 Jan 2026.”

3. Implementation Timeline:

  • 2016: E-invoicing becomes law (Finance Law 2016), mandatory for B2G (large enterprises).
  • 2018: Mandate expands to B2B for pharmaceuticals and hydrocarbons (Finance Law 2018).
  • Late 2024: Finance Law 2025 introduces penalties for non-compliance.
  • January 1, 2025: Fines for technical non-compliance (data omissions) come into force.
  • July 1, 2025: Strict enforcement begins; fines for issuing paper invoices when e-invoicing is required.
  • January 1, 2026: Mandate expands to all service transactions subject to VAT (Finance Law 2026). Soft landing approach signalled for smaller companies.

4. Key Regulations and Guidance:

  • Finance Laws: 2016, 2018, 2025, and 2026.
  • Government Decree 2016-1066 (August 15, 2016): Technical details for e-invoicing and archiving.
  • Tax Administration Guidance: Administrative Memorandum No. 10/2025.
  • TTN Documentation: XML schemas, integration guides.

5. Action Items/Recommendations:

  • Businesses operating in Tunisia, particularly those in the service sector, must ensure they are compliant with the e-invoicing mandate.
  • Companies should register with TTN (“El Fatoora”) and obtain the necessary digital certificates.
  • Review and adapt accounting and ERP systems to generate invoices in the required TEIF XML format.
  • Monitor official communications from the Ministry of Finance and the tax authority for updates and clarifications, particularly regarding the “soft landing” implementation for the 2026 expansion.
  • Consult with tax advisors to ensure full compliance and understand the specific requirements for your business.

6. Resources:

  • Tunisie TradeNet (TTN): [elfatoora.tn (example)]
  • Ministry of Finance (Tax Directorate)
  • Official Gazette of Tunisia
  • Accounting and tax advisory firms (KPMG, Deloitte, etc.)

INDEPTH ANALYSIS

Implementation Timeline & Phased Rollout – Tunisia pioneered e-invoicing early and has gradually broadened its scope over the past decade:

  • 2016: E-invoicing becomes law (Finance Law 2016), making Tunisia the first Arab country to mandate electronic invoicing. The national platform “El Fatoora” (run by Tunisie TradeNet, TTN) was launched under a continuous transaction control (CTC) model. Initially, the mandate applied to B2G invoices by large taxpayers and certain large private-sector companies, meaning that companies under the Large Enterprises Directorate (DGE) had to issue e-invoices when billing government entities. This gave e-invoices the same legal status as paper invoices (per Finance Law 2016, Article 22). Other businesses could opt in voluntarily at this stage. [edicomgroup.com]
  • 2018: The scope expanded to specific high-impact B2B sectors. Finance Law 2018 (Article 46) made e-invoicing mandatory for sales of pharmaceuticals and of hydrocarbons between professionals (business-to-business), excluding retail sales. Outside these categories, e-invoicing remained voluntary. [jibaya.tn]
  • 2020–2024: The e-invoicing system remained operational but compliance was uneven due to lack of penalties. In late 2024, the government moved to strengthen enforcement. Finance Law 2025 (Article 71, enacted end of 2024) introduced a penalty regime for non-compliance, effective mid-2025. Authorities gave companies a grace period until July 1, 2025 to comply without fines. This phased approach allowed affected businesses (large enterprises and those in pharma/fuel sectors) time to register on the TTN platform and adapt, before penalties started. [edicomgroup.com]
  • July 1, 2025: Strict enforcement began. From this date, companies obligated to e-invoice could be fined for issuing paper invoices or otherwise violating e-invoice requirements. (Details on penalties are provided below.) Earlier, on Jan 1, 2025, fines for technical non-compliance (omitting mandatory data in an e-invoice) had already come into force, while July 1, 2025 marked the start of fines for not using e-invoicing at all when required. This reflects a deliberate phased enforcement: first ensuring e-invoices meet content requirements, then punishing failure to use the system. [edicomgroup.com], [en.african…anager.com] [kpmg.com]
  • 2025–2026 Expansion: The Finance Law 2026 (Law No. 17 of 2025, Article 53) massively broadened the mandate. Effective January 1, 2026, all service transactions subject to VAT must be e-invoiced through the TTN system. In other words, the obligation, previously focused on goods (pharma/fuel) and B2G, now extends to virtually the entire service sector. This expansion is a major step in Tunisia’s digital tax reform, aiming for near-universal e-invoicing to improve compliance and transparency. Over 380,000 service providers (from large firms to liberal professions like lawyers, doctors, engineers, etc.) are affected by this change. Unless new extensions are passed, the law requires full compliance from day one, i.e. January 1, 2026. [lucapacioli.com.tn], [sovos.com] [lucapacioli.com.tn], [lucapacioli.com.tn] [sovos.com]
  • Grace Period / Transition: No formal grace period was written into the 2026 expansion – the law imposed the service-sector mandate immediately, with penalties applicable right away. However, in response to concerns (especially from SMEs) that the January 2026 deadline was tight, officials signaled a “soft landing” approach. In mid-January 2026 the Finance Ministry announced it would relax immediate enforcement for smaller companies, implying a more flexible, phased implementation even though the legal effective date remains 1 Jan 2026. This suggests that while the mandate is in force, authorities may initially extend deadlines, hold off on penalties, or offer support to businesses not yet ready – effectively a de facto grace period to prevent disruption. (Large companies, however, are expected to comply without delay.) Businesses are still urged to accelerate compliance, as the law is active even if penalties for some may be temporarily deferred. [sovos.com] [archyde.com], [archyde.com] [archyde.com]
Scope of Transactions – Domestic vs. Cross-Border: The e-invoicing mandate in Tunisia primarily targets domestic taxable transactions (sales subject to Tunisian VAT), with an emphasis on B2B and B2G deals:
  • Domestic B2G: All invoices to public sector entities (the State, local authorities, public institutions and companies) must be electronic when issued by in-scope taxpayers. This has been mandatory for DGE-registered large companies since 2016 and continues to hold. [en.african…anager.com]
  • Domestic B2B: All business-to-business transactions in regulated sectors (currently goods like fuel and medicine, and now services) require e-invoicing. Before 2026, the mandate covered mainly the sale of goods in specific industries (wholesale pharma and fuel) between VAT-registered businesses. As of 2026, the mandate extends to all B2B services as well. This means any service provided by a VAT-registered business in Tunisia to another entity must be invoiced through the electronic system, regardless of the industry (covering everything from consulting and IT services to transportation, hospitality, etc.). With these changes, Tunisia’s e-invoicing is moving toward comprehensive coverage of domestic B2B trade. Notably, B2C (business-to-consumer) invoices are not yet subject to mandatory e-invoicing – the law does not currently force electronic invoices for retail or consumer sales, though businesses may opt in. [en.african…anager.com] [sovos.com], [sovos.com] [sovos.com]
  • Cross-Border Transactions: Export sales (invoices issued by Tunisian suppliers to foreign customers) appear to fall under the e-invoicing framework as well, if the issuer is an obligated taxpayer. Tunisia’s system is described as covering “all taxable transactions, including exports”. In practice, a company that must e-invoice its domestic sales is expected to also channel its export invoices through the TTN platform. (Exports are zero-rated for VAT but still require an invoice, which can be electronic.) Import transactions, on the other hand, are outside the scope – invoices issued by foreign suppliers to a Tunisian buyer are not something a Tunisian company issues, so the mandate does not apply to those foreign-issued invoices. Such import documentation would still be handled via customs/VAT reporting rather than the domestic e-invoice system. In summary, the mandate covers invoices issued by Tunisian VAT-registered suppliers, whether the buyer is domestic or abroad, but does not directly cover invoices coming from non-Tunisian sellers. [digtechs.com]
Taxable Persons in Scope (Established vs. Non-Established): The obligation is tied to being a VAT-registered person in Tunisia performing in-scope transactions, rather than the business’s nationality. Initially it applied to “large enterprises” under the DGE (which are typically resident companies or local branches of multinationals). Now the scope has widened to include virtually all VAT-registered businesses in the services sector as well as those in designated goods sectors. The law itself does not explicitly exempt non-resident entities: if a foreign or non-established company is registered for VAT in Tunisia (e.g. via a local branch or fiscal representative) and engages in the transactions covered (such as providing services locally), it is subject to the same e-invoicing requirements as a locally established business. In other words, any business legally required to charge Tunisian VAT on a sale (and falling under the categories mandated by law) must use the electronic system, regardless of whether the business is Tunisian or a foreign company with a Tunisian VAT number. There is no separate treatment in the mandate for non-established taxable persons. (Non-established companies without a Tunisian VAT registration would not be issuing Tunisian VAT invoices at all, so they are not relevant to the mandate.) [edicomgroup.com] [sovos.com], [sovos.com] [sovos.com]
Data Requirements – Content of E-Invoices: An electronic invoice in Tunisia must contain all the information normally required on a tax invoice by law, plus additional data specific to the electronic system:
  • Standard Invoice Details: The e-invoice must include all the mandatory fields that a paper invoice would. This means names, addresses, and tax identification numbers of the seller and buyer, invoice date and number, a description of the goods or services, quantities, prices, applicable VAT rates and amounts, total amount, etc., just as stipulated by the VAT Code for any invoice. In essence, nothing that is required on a paper invoice can be omitted from the electronic version. [sovos.com]
  • Electronic Specifics: Beyond the usual fields, Tunisian e-invoices must incorporate certain elements to ensure authenticity and traceability in the TTN system. Notably:
    • A qualified electronic signature of the issuer (the supplier) to guarantee the invoice’s integrity and origin. Businesses must obtain a digital certificate from the National Digital Certification Agency (ANCE/TunTrust) for this purpose. [sovos.com]
    • A unique identifier/reference number assigned by the authorized platform (TTN) upon invoice submission. This unique ID is effectively the government registration number for that invoice. [sovos.com]
    • A “visible electronic seal” (QR code) on each invoice. TTN attaches a QR code (containing a cryptographic stamp) once the invoice is validated. This code, printed on any copy, allows auditors or customers to verify quickly that the invoice was indeed registered and approved by the platform. [lucapacioli.com.tn] [edicomgroup.com], [lucapacioli.com.tn]
    • Structured data format: The invoice data must be structured according to the official schema. Tunisia uses the Tunisian Electronic Invoice Format (TEIF), an XML-based format defined by the tax authorities. This ensures all required data fields are present in a machine-readable way. [edicomgroup.com], [lucapacioli.com.tn]
In summary, a compliant e-invoice file is an XML invoice (TEIF schema) containing all tax invoice details plus the digital signatures and unique codes. For user-friendliness, businesses often generate a human-readable PDF copy of the invoice that includes the QR code and key details; however, the authoritative record is the electronic XML data registered with TTN. (Tunisia allows a PDF/A-3 format with embedded XML as well, which combines human-readable and machine-readable versions.) [edicomgroup.com] [digtechs.com]
Format and Transmission Method: Tunisia’s e-invoicing operates on a clearance model – invoices are transmitted to the government platform in real-time for validation. Key points:
  • Accepted Formats: The TTN platform accepts invoices in the specified XML format (TEIF). Many companies’ software will produce an XML and submit it via web services or SFTP to TTN. The XML can be accompanied by a PDF representation if needed (the PDF/A-3 with embedded XML approach is supported), but it’s the structured data that is critical. Once uploaded, TTN applies the necessary controls (signatures, ID, etc.). Each invoice, once approved, is stored in the system and considered issued. The supplier can then deliver a copy (PDF or printed) to the buyer for their records or use. [lucapacioli.com.tn], [lucapacioli.com.tn] [digtechs.com]
  • Real-Time Clearance (Submission Deadlines): Invoice data must be sent to the authorities essentially at the time of issuance. The rule is that an invoice must be cleared through the TTN system before being issued to the customer. In practice this means as soon as an invoice is created, the seller transmits it to TTN via the online portal or API. TTN validates it and returns the registered invoice (with the unique ID and QR code). Only then can the invoice be considered legally issued and delivered to the buyer. There is no grace period (delay) for transmitting the invoice data – it’s effectively immediate. The system is continuous and transactional, so each invoice is reported in real-time to the tax authority. This is unlike a periodic reporting system; here the reporting is invoice-by-invoice, instantly. [openenvoy.com] [edicomgroup.com], [openenvoy.com]
  • E-Reporting of Other Transactions: Because Tunisia’s model is a clearance model covering each invoice in scope, there is no separate periodic “e-reporting” for those invoices – the submission to TTN is the reporting. For transactions that are not yet mandated to be e-invoiced (for example, B2C sales by a small retailer or an invoice from a foreign supplier), at present there is no real-time e-reporting requirement in place. Those out-of-scope invoices are simply handled through normal accounting and declared in the periodic VAT returns as usual. In other words, Tunisia has not (as of early 2026) introduced a distinct e-reporting system for transactions that fall outside the e-invoicing mandate. All focus has been on expanding the scope of mandatory e-invoices rather than requiring separate electronic reports for other invoices. Data transmission timeline: For in-scope invoices, the timeline is immediate (clearance upon issuance). There is no “X days after invoice issuance” rule – compliance requires instantaneous reporting. In the future, if the mandate expands to all invoices, effectively all B2B and B2C transactions would be covered by real-time clearance, obviating the need for a separate e-reporting mechanism.
Deadlines for Data Submission: As noted, the due date to transmit an invoice’s data is essentially the moment of issuance. The invoice must be lodged with TTN and approved before or at the same time as delivering it to the customer. There isn’t a buffered period (like 24 or 48 hours delay) given in the regulations; the system is designed for immediate integration. Therefore, compliant taxpayers integrate their billing systems with TTN so that whenever an invoice is generated, a request is automatically sent to TTN. Once TTN returns the validated invoice (usually within seconds), that invoice is officially recorded with the tax authority and can be sent to the buyer. If TTN were to be temporarily unavailable, one would likely have to issue once it’s back up; the law does not specify an offline fallback timeline, so in practice real-time submission is expected. This contrasts with some countries that allow reporting within X days – Tunisia’s CTC model is stricter, aiming for real-time control. [openenvoy.com]
Penalties for Non-Compliance: Tunisian law imposes significant penalties for failing to comply with e-invoicing requirements, as reinforced by the 2025 Finance Law and related regulations. Key penalties include: [en.african…anager.com]
  • Issuing Paper Instead of E-Invoice (when required): A fine of TND 100 to 500 per invoice will be levied for each invoice that a taxpayer was obligated to issue electronically but instead issued on paper. This fine is capped – the total fines for paper invoices can’t exceed TND 50,000 per year. (This penalty became enforceable from 1 July 2025, after the initial grace period.) [en.african…anager.com]
  • Non-Compliant E-Invoice: A fine of TND 250 to 10,000 is imposed for issuing an electronic invoice that does not meet the mandatory content or format requirements. For example, if an e-invoice is missing required fields or wasn’t processed through the authorized system correctly, this penalty applies. Each infraction (each instance of non-compliance) triggers a fine in that range, regardless of how many invoices were involved in that incident. Repeat offenses can lead to higher fines (and as noted, starting 2025 these deficiencies have been penalized). [en.african…anager.com]
  • Missing E-Invoice During Transport of Goods: To enforce compliance during goods shipment, any person transporting goods without a copy of the corresponding electronic invoice (or official equivalent document) faces a fine of 20% of the goods’ value (minimum TND 500). In practice, even though invoices are electronic, transporters are expected to carry a printed or digital copy showing the TTN validation (or proper delivery notes). If goods subject to e-invoice obligations are found in transit without proof of an e-invoice, this hefty penalty applies. [en.african…anager.com]
These are administrative financial penalties. They can quickly add up (especially the per-invoice fines), so businesses face a strong incentive to comply. In addition to fines, non-compliance can have other consequences: companies not using e-invoicing where required may be subject to tax audits or increased scrutiny by the authorities, and they risk exclusion from public procurement (government tenders) if they don’t adhere to invoicing rules. [lucapacioli.com.tn]
Furthermore, Tunisian law also provides for criminal penalties in cases of serious tax fraud via invoicing. According to the Finance Law 2025 and the tax procedures code, actions like intentionally issuing fake invoices, falsifying amounts, or using the system to hide sales can trigger criminal charges. The sanctions can include imprisonment (from 16 days up to 3 years) and additional fines ranging from TND 1,000 up to TND 50,000 for egregious violations. These criminal penalties target willful misconduct (e.g. invoice forgery or fraud), complementing the administrative fines for more procedural non-compliance. [kpmg.com]
Required Format of E-Invoices / E-Reports: The mandated format for e-invoices is the Tunisian Electronic Invoice Format (TEIF), which is an XML schema defined by the tax authority. All invoices must be generated in this structured XML format so that they can be automatically processed by TTN. In practice, businesses either use certified invoicing software or adapt their ERP systems to output invoices according to TEIF. The XML file contains all invoice data in a standardized way. As mentioned, often a PDF copy with embedded XML (PDF/A-3) is used – this allows the invoice to be human-readable while carrying the XML inside. TTN will accept either a pure XML upload or a PDF with the XML embedded, as long as it conforms to the schema. [edicomgroup.com] [digtechs.com]
For e-reporting, since Tunisia’s approach is invoice-centric (CTC), there isn’t a separate e-reporting format distinct from the e-invoice itself. The “report” to the authorities is essentially the XML invoice data sent through TTN. There is no separate summary report format (such as SAF-T or similar periodic reporting format) implemented for invoice data on a regular basis – the continuous transmission of each invoice in XML is the reporting mechanism.
Transmission to Authorities & Timing (E-Reporting Process): Under the TTN system, data transmission is automatic and immediate. When an invoice is issued, it is transmitted via web services or secure FTP to TTN (the government platform). TTN then validates and signs it, and forwards the data to the tax authorities in real time. In fact, TTN by design instantly registers each valid invoice with the Ministry of Finance and even sends a copy of each e-invoice to the tax administration’s systems. Thus, the tax authority receives the invoice information essentially concurrently with the invoice being finalized. There is no need for the taxpayer to separately “report” the invoice later; it’s handled by the platform. [lucapacioli.com.tn] [edicomgroup.com]
If we speak of “e-reporting” in the sense of reporting transactions not covered by e-invoicing: currently Tunisia has no parallel e-reporting obligation for transactions like B2C or imports. Some countries plan a dual system (e-invoicing for B2B, e-reporting for other sales), but Tunisia has not formally introduced that. The focus is on expanding the e-invoice requirement to eventually cover most transactions. So at present, if an invoice is not required to be electronic, the business just keeps it in paper/electronic form internally and reports the sale via the normal VAT return. All required data for mandated transactions is transmitted through the TTN platform. The timeline for such data transmission is effectively immediate – there is no buffer such as “X days after issuance” for sending invoice data to the authorities; compliance means the data is with the authorities at the time of issuance. [openenvoy.com]
Archiving Requirements & Retention Period: Tunisia’s regulations require proper archiving of electronic invoices to ensure their integrity over time:
  • Centralized Archiving by TTN: The government-designated operator (TTN) is responsible for the official storage of all e-invoices in the system. According to Decree 2016-1066 and related rules, TTN handles the registration and archiving of electronic invoices “in accordance with applicable legislation”. Every e-invoice that passes through the platform is stored on TTN’s servers. The platform systematically provides a copy of each invoice to the Ministry of Finance’s databases as well, so the tax authority has its archive too. TTN can also provide, on request, a copy of any stored invoice to the issuer or the buyer if needed (e.g. if a company loses its local copy, TTN can re-issue the archived invoice). In effect, TTN acts as a trusted third-party archive. [kpmg.com]
  • Obligation for Businesses: Businesses using the e-invoicing system are relieved from the need to keep paper archives of invoices. The law explicitly states that users of e-invoices are exempt from retaining a paper copy, since the authoritative record is the electronic one in TTN’s archive. However, they should be able to reference the TTN record (each invoice’s unique ID) if needed. Companies typically will keep digital copies of the XML/PDF invoices in their own systems as well, but the legal requirement to maintain an archive is satisfied by TTN’s retention. [kpmg.com], [kpmg.com]
  • Retention Period: For VAT and accounting purposes, invoices must be retained for at least 10 years in Tunisia. Tunisian law (e.g. the Code of Commerce and tax code) sets a 10-year minimum retention for accounting documents, including invoices. This applies equally to electronic invoices – the data must remain accessible for ten years. TTN’s archiving is expected to meet this requirement. (In practice, businesses will want to ensure they have access to their invoices for that period, whether via TTN or their own backups.) The OpenEnvoy summary suggests a minimum of 5 years for tax audit purposes, but the Ministry of Finance officially requires a decade of preservation for all financial records. Therefore, companies should plan for a 10-year retention of e-invoice data (which TTN and the tax authority will also be doing). It’s important to note that electronic archives must maintain invoices in their original signed format to be valid – TTN’s archive fulfills this by storing the signed XML with its digital signatures and timestamps intact. [finances.gov.tn] [openenvoy.com]
  • Audit and Access: During a VAT audit or inspection, tax authorities can directly access the TTN-stored invoices by their unique IDs, but businesses should also be able to present legible copies if requested. Typically, presenting the PDF copy with the TTN QR code and reference is acceptable, since it can be cross-checked against the TTN record. Because the system ensures authenticity, auditors can rely on the TTN data as the source of truth.
Pre-Filled VAT Returns: As of the latest updates, Tunisia does not offer pre-filled (pre-populated) VAT returns based on the e-invoicing data. The introduction of e-invoicing is aimed at improving compliance and control, but the VAT return filing process remains the taxpayer’s responsibility. Companies must still compile their VAT declarations (periodic tax returns) from their records and submit them in the normal way; the tax authority is not yet providing a pre-completed VAT form using invoice data. There has been no announcement of pre-filled VAT returns in connection with the e-invoicing rollout – the reforms have focused on invoice-level reporting and enforcement, not on automating the return itself. In short, no prefilled VAT returns are in place at this time (and none are explicitly planned in the current framework). Taxpayers should continue to prepare and file their VAT returns as before, ensuring the figures reconcile with the e-invoices they have issued or received. The rich data from e-invoicing could allow the tax administration to cross-check returns more thoroughly, but it is not yet used to actually fill out a taxpayer’s VAT form for them.
Official Resources and References: Tunisia’s e-invoicing regime is grounded in formal legislation and guidance. Key references include:
  • Finance Laws: Article 22 of Finance Law 2016 (establishing legal equivalence of e-invoices), Article 46 of Finance Law 2018 (extending mandate to pharma/hydrocarbons), Article 71 of Finance Law 2025 (penalty provisions), and Article 53 of Finance Law 2026 (extension to services). These laws define the scope and obligations. For example, Finance Law 2026 amends Article 18 of the VAT Code to require e-invoices for services. [lucapacioli.com.tn], [en.african…anager.com] [kpmg.com]
  • Government Decree 2016-1066 (15 Aug 2016): This decree details the technical conditions for issuing and archiving e-invoices, and it officially designates Tunisie TradeNet (TTN) as the authorized platform operator. It covers requirements like the need for digital certificates, the archiving process, etc. [edicomgroup.com]
  • Tax Administration Guidance: The tax authority (Direction Générale des Impôts, DGI) has issued notes and memoranda. Administrative Memorandum No. 10/2025 (June 2025) explained the new penalty regime introduced by Article 71 of Finance Law 2025. This memo (available via the Ministry’s Jibaya portal) outlines compliance expectations and phased enforcement of penalties. The DGI also released an official notice reminding taxpayers of the July 1, 2025 deadline, listing who is obligated (DGE companies for public sector transactions, and pro-to-pro sales of medicine/fuel) and urging enrollment with TTN to avoid sanctions. [sovos.com] [jibaya.tn], [jibaya.tn]
  • TTN / El Fatoora Documentation: Tunisie TradeNet provides technical documentation (XML schemas, integration guides) and support for taxpayers joining the platform. TTN’s website (e.g. elfatoora.tn) and materials from the Ministry of Finance offer practical guidance on how to subscribe to the platform, steps to obtain digital certificates, etc.
  • Official Press Releases: The Ministry of Finance’s communications (such as the January 2026 press release noted in media) can shed light on implementation adjustments and government support measures. While not legal texts, these indicate the regulatory stance and any transitional relief being offered. [archyde.com]
For further details, businesses should consult the Ministry of Finance (Tax Directorate) resources and the actual laws and decrees published in the Official Gazette of Tunisia. Many accounting firms and tax advisors (KPMG, Deloitte, local experts) have also published summaries and newsletters (as cited above) which interpret these official sources. It’s advisable for companies to review the latest Finance Law provisions and DGI communiqués to ensure full compliance with the current requirements of Tunisia’s e-invoicing and e-reporting regime. [kpmg.com], [sovos.com]
  • Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
  • Join the LinkedIn Group on ”VAT in the Digital Age” (VIDA), click HERE

 

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