title: Tunisia Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/tunisia/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # Tunisia TN schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 60 sourced findings · 142 sources in the cumulative register 14 Modules baseline.modules[] 60 Findings modules[].findings[] 20 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) No modules moved this cycle. ## Jurisdiction brief ###### Latest update · 11 October 2026 #### Lead Signal The Banque Centrale de Tunisie published Circulaire n2026-10 on 25 September 2026, abrogating and replacing the prior payment-institution regulation (Circulaire n2018-16 of 31 December 2018) for the first time in eight years. The new circular enters into force three months after publication, placing its effective date around 25 December 2026, and introduces a materially tightened governance regime for Tunisia's licensed payment establishments: a mandatory board-level audit and risk committee, an annual cybersecurity audit certified by the national cybersecurity agency (ANCS), and tightened controls over agent networks and commercial partnerships. This is the most significant regulatory development in Tunisia's payments sector since the 2018 framework was introduced, and it arrives alongside parallel conduct-side changes strengthening client-fund protection, remote and digital onboarding rules, open-API security requirements, and customer-information duties. The licensing foundation beneath this overhaul remains Loi n2016-48 of 11 July 2016 on banks and financial institutions, whose Article 20 creates the etablissement de paiement licence category, Article 32 sets a TND 5,000,000 minimum paid-up capital requirement, Article 30 gives the licensing commission four months to decide an application, and Article 21 requires client funds to be deposited at a bank. As at late September 2026, seven payment establishments hold a BCT agrement under this framework. Circulaire n2026-10 operates within and around this statutory base, tightening the operational and governance expectations placed on licence-holders rather than altering the licensing statute itself. #### Other Developments **National mobile-payment standard adopted.** The BCT's Bulletin des Paiements N17, covering the first half of 2026, confirms adoption of TunPay as the national mobile-payment label, intended to become the sector's unifying standard. The same bulletin reports active point-of-sale terminals reaching 45,600, a 5.7 percent increase, alongside 25.3 million proximity transactions, an 18.8 percent increase, indicating continued growth in domestic card-and-mobile acceptance infrastructure independent of the regulatory overhaul. **A thin funding environment for payments fintech.** Tunisian payments fintech Konnect Networks secured a multi-investor strategic round, led by Attijariwafa Ventures and including Visa, Plug and Play, Renew Capital and Digital Africa Ventures, though the amount was not publicly disclosed. This sits against a broader context in which Tunisia recorded only around three funding transactions worth approximately $300,000 in aggregate across the first half of 2026, the lowest total in its North Africa peer set, suggesting the Konnect round is a comparatively significant event for a market with otherwise limited venture activity. #### Cross-Monitor Connections The governance and cybersecurity-audit obligations introduced by Circulaire n2026-10 overlap with financial-integrity-relevant control requirements being tightened in parallel by the Banque Centrale de Tunisie across other regulated sectors this period, though the payment-institution circular itself is framed as a prudential and conduct measure rather than an AML/CFT instrument. Readers tracking Tunisia's financial-integrity trajectory separately should note the BCT's broader pattern of circular-driven tightening across multiple regulated populations in the same window. #### Outlook Circulaire n2026-10's roughly 25 December 2026 effective date is the key date to track: payment establishments have a three-month window from the 25 September 2026 publication to bring board governance, cybersecurity-audit arrangements and agent-oversight controls into compliance. Given that no primary BCT or JORT text for the circular has yet been directly retrieved, with all findings currently resting on secondary press reporting, confirmation of the precise compliance mechanics against the primary text would sharpen the picture materially as the effective date approaches. _2 earlier updates not shown here._ ###### Standing brief · as of 23 August 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal Tunisia's payment-institution licensing pipeline produced this cycle's clearest signal: the Banque Centrale de Tunisie's Committee of Approvals granted OFT Tunisie, a subsidiary of Ooredoo FinTech International, a definitive payment-institution licence on 29 January 2026, published in the Journal Officiel de la République Tunisienne (JORT) no. 65/2026, under Articles 10, 20, 24, 25, 27 and 30 of Law n°2016-48. Separate reporting places the JORT publication as no. 29 of 14 March 2026, and a six-month operational launch window applies from notification. The licence brings Tunisia's roster of licensed payment service providers to sixteen, a market that, per a March 2026 explainer, has already seen payment-institution transaction volumes via smartphone rise 81 per cent and transferred fund value rise 59 per cent under the framework set by BCT Note n°16 of 2018. #### Other Developments **Ooredoo's wallet product precedes its own licence.** Ooredoo Fintech Tunisie separately obtained BCT authorisation, reported 17 February 2026, to launch "walletii by Ooredoo," a digital wallet product that reached market ahead of OFT Tunisie's own definitive payment-institution licence being granted in the same corporate family. The sequencing, product authorisation preceding the parent entity's own definitive licence, is itself notable for market entrants structuring telco-backed payment offerings in Tunisia. **Sector-wide transaction growth.** The 81 per cent rise in smartphone-channel transaction volumes and 59 per cent rise in transferred fund value, reported in the same March 2026 explainer on Tunisia's payment-institution sector, indicates the sixteen-provider market is scaling meaningfully under its existing BCT Note n°16 framework, independent of the OFT Tunisie licence itself. #### Cross-Monitor Connections The draft Code des Changes reform discussed under this brief's W12 correspondent-banking coverage has AML/CTF and digital-asset dimensions tracked separately by the Financial Integrity Monitor (D7, D1 for the standing AML/CTF regime and sanctions picture) and by the Crypto Monitor (stablecoin_regime and related modules) under their own subscribed slots; this brief's treatment is confined to the settlement-access and correspondent-banking reading of the same instrument. #### Outlook Two forward markers matter. First, OFT Tunisie must commence payment-institution operations within its six-month launch window from notification, placing an operational deadline in 2026-Q3. Second, the draft Code des Changes remains targeted for a vote before the Assembly's 2026 summer recess, with the Finance and Budget Committee actively engaged following CONECT's forty-one proposed amendments; passage would replace the 1976 exchange-control law with a twelve-title, ninety-one-article code bearing directly on cross-border settlement and correspondent-banking access. Both markers would materially firm up Tunisia's licensing and correspondent-banking picture if they land as currently scheduled. trust tier: ai_unverified _Standing brief, as of 4 July 2026._ #### Regulatory Status Tunisia's payments-regulatory architecture is anchored in Law No. 2016-48 and its implementing BCT Circular n°2018-16, which together establish payment institutions as a distinct, non-bank licensed category with tiered accounts, ring-fenced safeguarding, and a dedicated consumer-protection mechanism. Market access is expanding: the BCT granted OFT Tunisie a final payment-institution licence on 29 January 2026, taking the licensed PSP roster to sixteen providers as of March 2026. Digital-money policy remains bifurcated — a strict 2018 criminal-law ban on unauthorised crypto-asset activity persists in force, even as a draft Code des Changes and a draft licensing bill signal a gradual, multi-year move toward a declared-but-restricted regime targeted, on current unconfirmed drafts, for 2026-2028; no live CBDC exists, and the BCT has previously denied reports of an operating 'e-dinar' pilot. Operational resilience rests on a layered structure combining BCT payment-systems oversight, Circular 2018-16 security obligations, and the national Decree-Law 2023-17 cybersecurity framework. Card-scheme dependency on Visa and Mastercard is now a live sovereignty debate alongside SMT's own restructuring review. Corridor dynamics are dominated by outbound diaspora remittances of roughly $2.3 billion a year under capital controls, offset partially by 2024 PAPSS accession and ISO 20022 migration. Correspondent-banking relationships show measurable de-risking pressure per EBRD/BIS-referenced data, again partially mitigated by PAPSS. Consumer protection and AML/CFT frameworks are both structurally mature: the former lacking a dedicated APP-fraud reimbursement rule, the latter anchored in CTAF's FIU role and Tunisia's clean FATF standing since October 2019. Commercial activity this cycle centres on regulatory market entry (OFT Tunisie) and product standardisation (TUNPAY) rather than disclosed private investment. #### Outlook The principal near-term markers are OFT Tunisie's operational start, expected within six months of its January 2026 notification (into the third quarter of 2026), and the progress — or lack of it — of the draft Code des Changes and crypto licensing bill toward enactment. Tunisia's overall regulatory trajectory across the monitored modules is liberalising on market access and corridor integration while remaining restrictive on crypto-asset use and constrained by external correspondent-banking pressure; risk level is assessed as elevated given this mixed but generally expanding profile. trust tier: ai_unverified ###### Latest update · 11 October 2026 #### Regulatory Status Tunisia's payments regulatory environment is undergoing its most significant update since 2018. The Banque Centrale de Tunisie published Circulaire n2026-10 on 25 September 2026, abrogating and replacing Circulaire n2018-16 and entering into force roughly three months later, around 25 December 2026. The new circular tightens governance (mandatory board audit and risk committee), introduces a mandatory ANCS-certified annual cybersecurity audit, tightens agent and commercial-partnership oversight, and strengthens client-fund protection, digital onboarding, open-API security, and customer-information duties. This sits atop the unchanged statutory licensing foundation in Loi n2016-48 of 11 July 2016, under which seven payment establishments currently hold a BCT agrement, subject to a TND 5,000,000 minimum capital requirement and client-fund segregation at a bank under Article 21. Separately, the BCT confirmed adoption of TunPay as a national mobile-payment interoperability standard, alongside continued growth in payment-acceptance infrastructure: point-of-sale terminals up 5.7 percent to 45,600 and proximity transactions up 18.8 percent to 25.3 million in the first half of 2026. On the commercial side, Tunisian fintech Konnect Networks secured an undisclosed strategic funding round led by Attijariwafa Ventures with Visa's participation, a notable transaction set against a broader Tunisian fintech funding market that raised only around $300,000 across three deals in H1 2026, the lowest in its North Africa peer group. #### Outlook The roughly 25 December 2026 effective date for Circulaire n2026-10 is the key compliance marker for Tunisia's licensed payment establishments. No primary BCT or JORT text has yet been directly retrieved for the circular, so confirmation against the primary instrument would sharpen the picture of exact transitional arrangements as the deadline approaches. The TunPay standardisation initiative and continued acceptance-infrastructure growth suggest a market that is expanding steadily even as its regulatory governance bar rises, while the Konnect funding round may indicate renewed, if still limited, investor interest in Tunisia's payments fintech sector. _2 earlier updates not shown here._ ###### Standing brief · as of 23 August 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status Tunisia's payments regulatory picture this cycle is defined by simultaneous movement in payment-institution licensing and in the foundational cross-border exchange-control framework. The Banque Centrale de Tunisie granted OFT Tunisie, an Ooredoo FinTech International subsidiary, a definitive payment-institution licence under Law n°2016-48, bringing the licensed-provider count to sixteen and coinciding with separately reported sector-wide transaction growth of 81 per cent by volume and 59 per cent by value under BCT Note n°16 of 2018. In the same period, Ooredoo's wallet product, "walletii by Ooredoo," reached authorised launch ahead of its parent entity's own definitive licence. Running alongside this activity, a more structurally significant reform is under active parliamentary consideration: proposition de loi n°2025/115, a draft Code des Changes that would replace the 1976 exchange-control law wholesale, is with the Assembly's Finance and Budget Committee following CONECT's forty-one proposed amendments, with a vote targeted before the 2026 summer recess. #### Outlook Three Tunisia-specific markers carry into the next cycle: OFT Tunisie's six-month operational launch window, expiring in 2026-Q3; the Code des Changes vote timeline, targeted for before the summer 2026 recess; and continued sector-wide transaction-volume reporting that would confirm whether this cycle's growth figures represent a sustained trend. 14 of 14 modules Signal Density Selections OR within a group, AND across groups. Press / to search. ### W1a Licensing, Authorisation & Market Access Confirmed confirmed 2026-07-04 The BCT replaced its 2018 payment-institution framework (Circular 2018-16) with Circular 2026-10 (25 Sept 2026), introducing tighter governance, cyber-audit, digital-KYC and branch-network standards, with a 3-month transition to full compliance (~25 Dec 2026). Underlying licensing law remains Loi n°2016-48. Horizon · 2026-Q3 (±quarter) OFT Tunisie operational start deadline (six months from licence notification)_in_force_pending · TT2_ Standing sub-brief · as of 23 August 2026 226 words · last cycle 2026-10-11 #### Licensing, Authorisation & Market Access Tunisia's payment-institution licensing regime, anchored in Law n°2016-48, registered a concrete authorisation event this cycle: the Banque Centrale de Tunisie's Committee of Approvals granted OFT Tunisie, the Tunisian payment-institution subsidiary of Ooredoo FinTech International, a definitive payment-institution licence. Reporting places the grant on 29 January 2026 with publication in the Journal Officiel de la République Tunisienne (JORT) no. 65/2026, citing Articles 10, 20, 24, 25, 27 and 30 of Law n°2016-48 as the statutory basis; a separate account places the JORT reference as no. 29 of 14 March 2026. Both accounts agree that a six-month operational launch window runs from the date of notification, meaning OFT Tunisie's actual market entry is a 2026-Q3 event to confirm rather than a fact already established. This is squarely a non-bank payment-institution and e-money-institution (PI/EMI) authorisation rather than a bank licence, illustrative of a broader pattern in the Tunisian market of telecom-affiliated entrants using the PI/EMI licensing track. With OFT Tunisie's grant, the market now counts sixteen licensed payment service providers, a figure multiple press accounts corroborate independently. #### Outlook The immediate marker to track is whether OFT Tunisie commences payment-institution operations within its six-month window from notification, an event expected in 2026-Q3. A second-order question is whether the JORT-reference discrepancy between the two reported accounts reflects two distinct publications, an amendment, or a reporting error. Periodic update · new data 2026-10-11 #### Licensing, Authorisation & Market Access Tunisia's payment-institution licensing regime rests on Loi n2016-48 of 11 July 2016 on banks and financial institutions, which created a dedicated etablissement de paiement licence category under Article 20. The statute sets a TND 5,000,000 minimum paid-up capital requirement under Article 32, requires applicants to be organised as a societe anonyme with a Tunisia-registered office under Article 31, and gives the licensing commission (commission d'agrement) four months to decide a complete application under Article 30, with an application left incomplete for three months deemed to lapse under Article 28. As at late September 2026, seven payment establishments hold a BCT agrement under this framework, indicating a modestly sized but established licensed population operating within a statute that has not itself changed. What has changed, materially, is the BCT's implementing circular layer governing how licensed establishments must operate. Circulaire n2026-10, published 25 September 2026, abrogates and replaces Circulaire n2018-16 of 31 December 2018, representing the first comprehensive update to the operational rulebook in eight years. The new circular enters into force three months after publication, meaning licensed and prospective payment establishments face an effective compliance date around 25 December 2026. Among its market-access-relevant provisions, the circular tightens controls on agents and commercial partnerships, which is directly relevant to any payment establishment relying on an agent network to extend its distribution reach beyond its own licensed footprint -- a model common among Tunisia's smaller payment establishments given the capital and infrastructure costs of direct market coverage. The circular also introduces a mandatory board-level audit and risk committee and a mandatory annual cybersecurity audit certified by the national cybersecurity agency (ANCS). Both are governance preconditions that sit logically adjacent to, though are distinct from, the initial licensing test: they represent an ongoing supervisory expectation layered onto the Article 20 licence rather than a change to the licence-grant criteria themselves. For firms currently holding or seeking a BCT agrement, the practical effect is a materially higher ongoing compliance burden than existed under the 2018 framework, even though the underlying statutory licensing gateway in Loi n2016-48 is unchanged. The timing is notable: the circular was issued as a BCT-level implementing instrument rather than through legislative amendment, which is consistent with Tunisia's regulatory practice of using central-bank circulars to update operational expectations within a stable statutory frame. This gives the BCT flexibility to update governance and cybersecurity requirements relatively quickly relative to statutory amendment, but it also means the market-access bar (capital, legal form, licensing-commission timeline) established by the 2016 law remains the primary determinant of whether a firm can enter the market at all, while the circular determines how demanding it is to remain in good standing once licensed. #### Outlook The approximately 25 December 2026 effective date is the operative deadline for the seven currently licensed payment establishments, and for any firm with a pending application, to bring board governance structures and cybersecurity-audit arrangements into line with the new circular. No primary BCT or JORT text for Circulaire n2026-10 has yet been directly retrieved, with current findings resting on secondary press reporting corroborated across at least two outlets; confirming the precise compliance mechanics and any transitional provisions against the primary text would materially sharpen the picture as the effective date approaches. Given the circular replaces an eight-year-old framework, it is plausible that further detailed guidance or FAQs could follow from the BCT ahead of the compliance deadline, which would be the next concrete marker to watch for market participants assessing their readiness. **2 earlier distinct update(s)** Periodic update · new data 2026-10-04 #### Licensing, Authorisation & Market Access Banque Centrale de Tunisie Circular 2026-10, published 25 September 2026 and confirmed on the regulator's own site, repeals and replaces Circular 2018-16, the prior instrument governing payment-institution activity and operation. This is a confirmed, structural reset of the operating rulebook for licensed payment institutions, corroborated by multiple independent Tunisian press outlets describing the same substantive changes. The underlying licensing law itself, Loi n°2016-48, is unchanged by this circular: the TND 5,000,000 paid-up capital requirement under Article 32 and the four-month decision window for the licensing commission under Article 30 both remain the standing baseline this cycle, alongside a corporate tax rate of 20% plus a 4% sector contribution that took effect from 1 January 2026. What changes under the new circular, on probable-tier reporting corroborating the T1-confirmed fact of its existence and date, is governance: payment institutions must establish a board-level audit-and-risk committee. This raises the bar for internal organisational structure required to hold and operate a payment-institution licence, without altering the capital or authorisation-timeline thresholds that govern market entry itself. The distinction matters for market-access analysis: a new entrant's path to licensure under Loi n°2016-48 is unaffected, but an incumbent or new licensee's post-authorisation governance obligations have been tightened materially. The compliance transition runs three months from the circular's 25 September 2026 publication date, placing the effective deadline at approximately 25 December 2026. This is the operative date against which licensed institutions, and prospective licensees completing authorisation during the transition window, should assess their governance-structure conformity. #### Outlook The near-term marker is the ~25 December 2026 compliance deadline for the new governance structure. A primary-text retrieval of Circular 2026-10 directly from the BCT would move the audit-and-risk-committee requirement, and any other granular governance provisions, from probable to confirmed status; absent that, the finding rests on convergent secondary Tunisian press reporting. No change to the capital or licensing-timeline thresholds under Loi n°2016-48 has been identified, and none is expected from this instrument given its administrative-circular character. Periodic update · new data 2026-09-21 #### Licensing, Authorisation & Market Access Tunisia's payment-institution licensing pipeline showed concrete activity this cycle under the standing Law 2016-48 / BCT Circular 2018-16 framework. The Banque Centrale de Tunisie granted OFT Tunisie a final payment-institution licence on 29 January 2026, a confirmed, primary-sourced licensing grant. This sits within a broader roster expansion that reached sixteen licensed mobile-wallet-capable providers by March 2026, the same population later targeted by the TUNPAY standardisation mandate discussed under Operational Resilience. Separately, Ooredoo Fintech received BCT regulatory approval on 23 February 2026 to launch its walletii digital wallet, in partnership with QNB Group and Monétique. This approval sits at the boundary between licensing and product authorisation — it is a market-access decision by the regulator specific to a named product launch, distinguishing it from OFT Tunisie's standalone institutional licence grant. The non-bank/non-bank-PI-EMI distinction is relevant here: both OFT Tunisie and Ooredoo Fintech's walletii product sit within the nonbank payment-institution/e-money-institution category rather than the traditional bank-PSP channel, consistent with the broader pattern of Tunisia's mobile-payments growth being driven substantially by non-bank entrants rather than incumbent banks. #### Outlook Given the pace of licensing activity this cycle and the 31 percent transaction-value growth reported separately in the Operational Resilience module, further payment-institution licence grants and product-specific approvals should be expected in the coming cycle. The sixteen-provider roster is itself a moving baseline against which future growth should be measured. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (6)** 1. T1 [https://www.fgdb.gov.tn/storage/79/Loi-n%C2%B0-2016-48-du-11-juillet-2016.pdf](https://www.fgdb.gov.tn/storage/79/Loi-n%C2%B0-2016-48-du-11-juillet-2016.pdf) retrieved 2026-07-04 2. T1 [https://www.bct.gov.tn/bct/siteprod/documents/Cir_2018_16_fr.pdf](https://www.bct.gov.tn/bct/siteprod/documents/Cir_2018_16_fr.pdf) retrieved 2026-07-04 3. T2 [https://ctici.org.tn/les-mesures-phares-de-la-nouvelle-loi-bancaire.html](https://ctici.org.tn/les-mesures-phares-de-la-nouvelle-loi-bancaire.html) retrieved 2026-07-04 4. T2 [https://managers.tn/2026/03/16/la-banque-centrale-accorde-une-nouvelle-licence-definitive-detablissement-de-paiement/](https://managers.tn/2026/03/16/la-banque-centrale-accorde-une-nouvelle-licence-definitive-detablissement-de-paiement/) 5. T2 [https://africanmanager.com/oft-tunisie-obtient-lagrement-definitif-de-la-bct-en-tant-quetablissement-de-paiement/](https://africanmanager.com/oft-tunisie-obtient-lagrement-definitif-de-la-bct-en-tant-quetablissement-de-paiement/) retrieved 2026-07-04 6. T1 [https://fintech.bct.gov.tn/en/node](https://fintech.bct.gov.tn/en/node) retrieved 2026-07-04 ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-07-04 Payment institutions' conduct, safeguarding and consumer-protection obligations are set out in BCT Circular 2018-16, which mandates professional liability insurance/bank guarantee cover, tiered payment-account ceilings, a ring-fenced 'compte global' held with a depositary bank, and a dedicated consumer-protection mechanism, alongside a pre-existing banking-mediation regime. Standing sub-brief · as of 4 August 2026 113 words · last cycle 2026-10-04 #### Conduct, Safeguarding & Financial Promotions BCT convened over 60 participants for a high-level dialogue on user protection, transparency, and inclusion in digital financial services on 8 April 2026, as part of a needs-assessment mission. The dialogue sits on the conduct side of the bank-PSP/non-bank-PI distinction that runs through this module: BCT's stated agenda covers user protection, transparency, and inclusion across the market's licensed providers without yet distinguishing bank-affiliated from non-bank/telecom-affiliated obligations. The initiative has not yet taken rule form. #### Outlook Whether this dialogue converts into a published consumer-protection framework, and how any resulting rules treat bank-affiliated versus non-bank/telecom-affiliated providers, is the open question for next cycle; no rule text exists yet to assess. Periodic update · new data 2026-10-04 #### Conduct, Safeguarding & Financial Promotions Alongside the licensing and governance reset, Circular No. 2026-10 introduces new conduct-facing requirements for payment institutions: remote-onboarding standards built around facial-recognition liveness verification, new complaint-handling obligations, and defined notice periods that payment institutions must observe when changing their branch networks. This is assessed as a probable, tightening development sourced to the same 25 September 2026 circular that reset the licensing baseline, and it moves in the same direction: institutions face materially tighter conduct and customer-facing process requirements alongside the prudential reset. No separate safeguarding-of-funds instrument distinct from the general circular provisions is evidenced this cycle. #### Outlook As the circular approaches its expected in-force date around late December 2026, payment institutions will need onboarding and complaint-handling processes reworked to the new standard, with facial-recognition liveness checks representing the most operationally significant single change to customer-facing processes in this cycle. **Sources and findings (5)** 1. T1 [https://www.bct.gov.tn/bct/siteprod/documents/Cir_2018_16_fr.pdf](https://www.bct.gov.tn/bct/siteprod/documents/Cir_2018_16_fr.pdf) retrieved 2026-07-04 2. T2 [https://www.ilboursa.com/marches/les-nouvelles-regles-regissant-lactivite-et-le-fonctionnement-des-etablissements-de-paiement_15621](https://www.ilboursa.com/marches/les-nouvelles-regles-regissant-lactivite-et-le-fonctionnement-des-etablissements-de-paiement_15621) retrieved 2026-07-04 3. T1 [https://www.bct.gov.tn/bct/siteprod/documents/Cir_2018_16_fr.pdf](https://www.bct.gov.tn/bct/siteprod/documents/Cir_2018_16_fr.pdf) retrieved 2026-07-04 4. T2 [https://www.bt.com.tn/mediateur](https://www.bt.com.tn/mediateur) retrieved 2026-07-04 5. T3 [https://www.spendnode.io/crypto-cards/country/tunisia/](https://www.spendnode.io/crypto-cards/country/tunisia/) retrieved 2026-07-04 ### W2 Stablecoins & Digital Money Probable confirmed 2026-07-04 Tunisia maintains one of the strictest crypto-asset postures in the region: a 2018 BCT directive under currency-control law criminalises unauthorised virtual-currency trading, mining and payments (up to five years' imprisonment), while a draft Code des Changes and parliamentary discussions signal a possible future shift toward a declared-but-restricted or licensed regime. No live CBDC exists; a 2019 reported 'e-dinar'/CBDC launch was denied by the BCT itself. Horizon · 2026 (±year) Draft Code des Changes crypto-asset definition and declared-asset regime_proposed · TT2_ Horizon · 2027 (±year) Draft virtual-asset licensing regime -- pilot exchanges expected_proposed · TT3_ Horizon · 2028 (±year) Draft virtual-asset framework -- full retail access targeted_proposed · TT3_ Standing sub-brief · as of 4 July 2026 270 words · last cycle 2026-07-04 #### Stablecoins & Digital Money Tunisia maintains one of the region's most restrictive crypto-asset postures. A 2018 BCT directive criminalises unauthorised virtual-currency trading, mining and payments, with penalties of up to five years' imprisonment, a stance framed by sources as a currency-control and capital-flight measure rather than a payments-conduct rule as such. A draft BCT Code des Changes now under consideration would introduce Tunisia's first statutory definition of 'crypto-assets' and would permit residents to hold declared holdings, while retaining a ban on their use as a means of payment or exchange for goods and services — a liberalisation confined to holding rights rather than transactional use. A separate draft crypto licensing bill would decriminalise possession and establish a licensing regime, with a virtual-asset framework reportedly targeted for 2026, pilot exchanges by 2027, and full retail access by 2028; these remain draft/pending instruments with no enactment date confirmed this sweep. On central bank digital currency, no live CBDC exists in Tunisia. The BCT itself denied November 2019 media reports that an 'e-dinar' test had been launched via Universa's blockchain platform, stating at the time that any CBDC work remained at the consideration stage; no more recent BCT statement on CBDC plans was identified in this sweep. #### Outlook The draft Code des Changes and the draft licensing bill together describe a gradual, multi-year path from outright prohibition toward a declared-but-restricted crypto-asset regime, with markers at 2026 (framework), 2027 (pilot exchanges) and 2028 (full retail access); none of these dates are enacted commitments, and the current criminal-law ban remains in force in the interim. No confirmed CBDC roadmap beyond the consideration stage has surfaced. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T3 [https://www.lightspark.com/knowledge/is-crypto-legal-in-tunisia](https://www.lightspark.com/knowledge/is-crypto-legal-in-tunisia) retrieved 2026-07-04 2. T3 [https://aixelles.net/risques-juridiques-des-cryptomonnaies-en-tunisie-guide-complet](https://aixelles.net/risques-juridiques-des-cryptomonnaies-en-tunisie-guide-complet) retrieved 2026-07-04 3. T2 [https://africanmanager.com/change-crypto-monnaie-et-paypal-la-bct-propose-une-liberte-surveillee/](https://africanmanager.com/change-crypto-monnaie-et-paypal-la-bct-propose-une-liberte-surveillee/) retrieved 2026-07-04 4. T3 [https://www.spendnode.io/crypto-cards/country/tunisia/](https://www.spendnode.io/crypto-cards/country/tunisia/) retrieved 2026-07-04 5. T2 [https://www.ledgerinsights.com/universa-clarifies-tunisia-e-dinar-digital-currency/](https://www.ledgerinsights.com/universa-clarifies-tunisia-e-dinar-digital-currency/) retrieved 2026-07-04 ### W3 Operational Resilience & Critical Infrastructure limited signal Confirmed confirmed 2026-07-04 Circular 2026-10 introduces a mandatory annual cyber audit certified by ANCS for all licensed payment institutions, alongside strengthened remote/digital-onboarding identification (including facial-recognition client-presence checks), effective three months after the 25 September 2026 publication date. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open this jurisdiction's page on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/tunisia/) Standing sub-brief · as of 4 July 2026 159 words · last cycle 2026-10-04 #### Operational Resilience & Critical Infrastructure The Banque Centrale de Tunisie is mandated to secure the good operation, stability, soundness and efficiency of national payment systems through a dedicated payment-systems oversight structure. At the payment-institution level, Article 9 of BCT Circular n°2018-16 requires operational security devices ensuring full transaction traceability, mandates penetration and security testing, and obliges immediate notification to the BCT of measures taken following any incident. This sector-specific regime sits within a broader national cybersecurity framework: Decree-Law No. 2023-17 of 11 March 2023 establishes a national cybersecurity audit framework, risk-analysis methodologies and ICT supply-chain controls administered by Tunisia's National Cybersecurity Agency. #### Outlook The combination of BCT-level oversight, circular-level security and incident-reporting obligations, and the national cybersecurity decree-law gives Tunisia a layered operational-resilience baseline comparable in structure, if not in codified granularity, to frameworks such as the EU's DORA. No new resilience-specific rulemaking or incident disclosure was identified this sweep; this module remains stable pending any future event-driven update. Periodic update · new data 2026-10-04 #### Operational Resilience & Critical Infrastructure Circular 2026-10 introduces two operational-resilience requirements for Tunisia's licensed payment institutions, both reported at a probable tier against the confirmed fact of the circular's publication and repeal effect. First, an annual cybersecurity audit certified by ANCS, the national cybersecurity agency, becomes mandatory, establishing a recurring, externally certified technical-assurance cadence rather than leaving audit frequency to institutional discretion. Second, digital client onboarding must incorporate facial-recognition presence verification, tightening the identity-assurance layer for remote account opening specifically. Both requirements are corroborated across more than one Tunisian press outlet describing the same circular content, though neither has yet been confirmed against a retrieved primary text of the circular itself. Read together, they represent a coordinated uplift in the technical-assurance baseline expected of payment institutions: a periodic, externally certified audit regime paired with a stronger biometric check at the point of digital onboarding. This is the kind of paired governance-plus-technology move that raises the operational floor for the sector as a whole rather than responding to any single disclosed incident. The three-month transition window to approximately 25 December 2026 applies here as elsewhere in the circular: institutions must have the first ANCS-certified audit cycle arranged, and facial-recognition onboarding implemented, within that period. #### Outlook Watch for ANCS to publish or clarify the certification standard referenced by the circular, which would be the next concrete step in operationalising this requirement. Confirmation of the circular's primary text would also resolve whether the facial-recognition requirement applies to all digital onboarding or only to a defined subset of account types, a distinction not resolved by the secondary reporting available this cycle. **1 earlier distinct update(s)** Periodic update · new data 2026-09-21 #### Operational Resilience & Critical Infrastructure The defining infrastructure development this cycle is BCT Note/Circular N°2026-132 of 5 May 2026, which makes the TUNPAY label compulsory for all sixteen licensed mobile-wallet issuers. This is a confirmed, primary-sourced regulatory mandate signed by the BCT Governor, and it represents a structural standardisation move across Tunisia's mobile-payments ecosystem: rather than leaving wallet branding and, implicitly, underlying interoperability arrangements to individual issuers, the BCT has imposed a unified label requirement across the entire licensed population. This mandate arrives against a backdrop of rapid market growth: mobile-payment transaction value rose 31 percent in 2025 to 1,375 million Tunisian dinars, per BCT Bulletin No. 15. The scale and pace of that growth is a plausible driver for the timing of the standardisation mandate — a market growing this quickly creates stronger incentives for interoperability infrastructure, and stronger risks from fragmentation, than a flat market would. The TUNPAY mandate's coordination with the broader national mobile-payments switch (SMT) suggests the BCT is treating unified branding as one component of a larger critical-infrastructure consolidation effort for mobile payments, though the evidence reaching this cycle does not extend to describing the technical architecture of that switch in detail. #### Outlook The key operational question for the coming cycle is implementation: whether all sixteen licensed mobile-wallet issuers achieve compliant TUNPAY branding and whether the underlying interoperability the mandate implies materialises in practice, or whether the mandate faces friction from issuers with existing distinct brand identities. Continued transaction-value growth at anything close to the 31 percent 2025 rate would further increase the stakes of getting this standardisation right. **Sources and findings (4)** 1. T1 [https://www.bct.gov.tn/bct/siteprod/documents/fiche35_a.pdf](https://www.bct.gov.tn/bct/siteprod/documents/fiche35_a.pdf) retrieved 2026-07-04 2. T1 [https://www.bct.gov.tn/bct/siteprod/documents/Cir_2018_16_fr.pdf](https://www.bct.gov.tn/bct/siteprod/documents/Cir_2018_16_fr.pdf) retrieved 2026-07-04 3. T2 [https://ncsi.ega.ee/country/tn/](https://ncsi.ega.ee/country/tn/) retrieved 2026-07-04 4. T1 [https://www.bct.gov.tn/bct/siteprod/documents/Cir_2018_16_fr.pdf](https://www.bct.gov.tn/bct/siteprod/documents/Cir_2018_16_fr.pdf) retrieved 2026-07-04 ### W4 Scheme & Network Compliance Probable confirmed 2026-07-04 Card-scheme rails in Tunisia run through Société Monétique Tunisie (SMT), the national interbank card switch (also referenced as STICPAY), overlaid by international Visa/Mastercard network participation for cross-border cards; a public debate on interchange-fee sovereignty versus Visa/Mastercard has emerged in 2026 alongside SMT's own restructuring. Standing sub-brief · as of 4 July 2026 161 words · last cycle 2026-07-04 #### Scheme & Network Compliance Société Monétique Tunisie (operating as STICPAY) runs the national interbank card switch handling domestic processing and settlement, but the majority of Tunisian card transactions still rely on Visa and Mastercard rails, generating outbound interchange fees against a card base of 5.875 million cards as of the first quarter of 2026. That dependency has become a live policy question: SMT and the BCT are examining a restructuring of the national monetics network and alternatives intended to reduce reliance on the Visa-Mastercard duopoly, with public commentary explicitly drawing a parallel to Europe's Wero initiative. #### Outlook This is an exploratory, strategic-project-stage discussion rather than a confirmed rule change or scheme decision; no interchange-fee regulation or statutory rate-cap regime has been identified in Tunisia to date, and PCI DSS certification status for Tunisian card-scheme processors remains unresolved from available sources. Watch for a concrete SMT restructuring announcement as the marker that would convert this from a debate into a scheme-level decision. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T2 [https://www.tunisienumerique.com/souverainete-financiere-tunisie/](https://www.tunisienumerique.com/souverainete-financiere-tunisie/) retrieved 2026-07-04 2. T3 [https://payatlas.com/countries/tunisia-tn](https://payatlas.com/countries/tunisia-tn) retrieved 2026-07-04 3. T2 [https://www.tunisienumerique.com/souverainete-financiere-tunisie/](https://www.tunisienumerique.com/souverainete-financiere-tunisie/) retrieved 2026-07-04 ### W5 Payment Corridor Dynamics Probable confirmed 2026-07-04 Tunisia's principal payment corridors are its outbound diaspora remittance flows (~$2.3bn/year from France, Italy, Germany, Belgium and Canada), moved via bank transfer and MTOs (Western Union, RIA) under a tightly controlled exchange regime, alongside recent regional-rail integration through PAPSS accession and SWIFT ISO 20022 migration. Standing sub-brief · as of 4 August 2026 163 words · last cycle 2026-10-04 #### Payment Corridor Dynamics / Emerging-Market Rails A national mobile switch is planned to enable full interoperability between payment service providers, and ISO 20022 (SWIFT MX) adoption is planned to let banks and fintechs communicate without friction and facilitate instant transfers; neither initiative carries a confirmed rollout date. A persistent cash-out rate of 14.2% has been identified as a structural friction point for closing Tunisia's digital-payment loop, and is assessed as the binding constraint on interoperability gains from TUNPAY and the planned switch. Both bank-affiliated and non-bank mobile-money providers are affected equally by the interoperability push, since the switch and the messaging-standard migration operate at the infrastructure layer rather than at the level of individual provider licences. #### Outlook Neither the national mobile switch nor the ISO 20022 migration carries a confirmed date; both remain directional plans to track for firm timelines next cycle. The 14.2% cash-out rate is likely to remain the pacing constraint on realised interoperability gains regardless of the technical rollout schedule. Periodic update · new data 2026-10-04 #### Payment Corridor Dynamics Circular No. 2026-10 newly introduces or restates cross-border cash remittance and inbound-funds caps applicable to payment institutions, and continues dinar-exclusivity for payment-institution services, meaning these institutions remain restricted to operating in Tunisian dinar for the services the circular governs. This is assessed as a probable, tightening development for the cross-border corridor dimension of Tunisia's payments environment, running in parallel with the domestic licensing and governance reset in the same instrument. #### Outlook The practical effect of the new or restated remittance and inbound-funds caps on transaction volumes and pricing for cross-border flows into and out of Tunisia is not yet evidenced and is worth monitoring once the circular takes effect around 25 December 2026. **Sources and findings (3)** 1. T2 [https://www.wearetech.africa/fr/fils/actualites/finance/tunisie-les-transactions-electroniques-ont-atteint-8-8-milliards-de-dollars-en-2024](https://www.wearetech.africa/fr/fils/actualites/finance/tunisie-les-transactions-electroniques-ont-atteint-8-8-milliards-de-dollars-en-2024) retrieved 2026-07-04 2. T3 [https://www.spendnode.io/crypto-cards/country/tunisia/](https://www.spendnode.io/crypto-cards/country/tunisia/) retrieved 2026-07-04 3. T1 [https://www.bct.gov.tn/bct/siteprod/documents/fiche35_a.pdf](https://www.bct.gov.tn/bct/siteprod/documents/fiche35_a.pdf) retrieved 2026-07-04 ### W6 Industry Structure & Commercial Probable confirmed 2026-07-04 Tunisia's payments industry remains bank-dominated (state-owned and legacy banks such as BIAT, STB, BNA) but has a growing licensed non-bank PSP segment (16 PSPs by March 2026) and an active fintech startup scene led by Flouci/Kaoun and La Poste Tunisienne's D17 wallet, alongside the national processor SMT. Standing sub-brief · as of 23 August 2026 229 words · last cycle 2026-08-21 #### Industry Structure & Commercial Dynamics Tunisia's payment-institution sector, governed by Banque Centrale de Tunisie Note n°16 of 2018, registered a substantial scaling signal this cycle: a March 2026 explainer reports that payment-institution transaction volumes conducted via smartphone rose 81 per cent, while the value of funds transferred through the sector rose 59 per cent, over an unspecified reporting period. Neither figure is broken down by individual provider, and the period of comparison is not stated in the sourced reporting. The figures nonetheless corroborate, from an industry-structure perspective, the same underlying dynamic visible in this cycle's licensing activity: a market that BCT Note n°16 opened to non-bank payment institutions in 2018 is now sixteen providers deep and, on this reporting, growing meaningfully in both transaction count and value moved. The divergence between the 81 per cent volume growth and the 59 per cent value growth is itself an analytically relevant data point: it implies a shift toward a larger number of lower-average-value transactions, consistent with a market in which smartphone-channel payment institutions are capturing everyday, lower-ticket use cases. #### Outlook Confirmation of the reporting period behind the 81 per cent and 59 per cent figures, and any provider-level breakdown that becomes available, would materially sharpen this cycle's industry-structure read. OFT Tunisie's addition as a sixteenth licensed provider is likely to contribute to future volume growth once its six-month launch window elapses. No new data since the standing brief. 1 periodic run re-emitted it unchanged. **Sources and findings (3)** 1. T2 [https://africanmanager.com/oft-tunisie-obtient-lagrement-definitif-de-la-bct-en-tant-quetablissement-de-paiement/](https://africanmanager.com/oft-tunisie-obtient-lagrement-definitif-de-la-bct-en-tant-quetablissement-de-paiement/) retrieved 2026-07-04 2. T3 [https://tracxn.com/d/explore/fintech-startups-in-tunisia/OOMGzIeyZYPyvEWpfn5a99rctj1DiS4wy_Az3wDFFAQ/companies](https://tracxn.com/d/explore/fintech-startups-in-tunisia/OOMGzIeyZYPyvEWpfn5a99rctj1DiS4wy_Az3wDFFAQ/companies) retrieved 2026-07-04 3. T3 [https://www.forbesmiddleeast.com/lists/the-middle-easts-fintech-50-2025/flouci-by-kaoun/](https://www.forbesmiddleeast.com/lists/the-middle-easts-fintech-50-2025/flouci-by-kaoun/) retrieved 2026-07-04 ### W7 Legal & Litigation Probable confirmed 2026-07-04 The most significant recent payments-adjacent legal development is the 2024 cheque-law reform (Law 41-2024) reshaping cheque issuance and clearing, provoking SME distress; a separate draft e-commerce regulation (bill n°42/2024) proposes sanctions and site-closure powers for non-compliant online sellers. No landmark payments-specific court rulings were identified in this sweep. Standing sub-brief · as of 4 July 2026 125 words · last cycle 2026-07-04 #### Legal & Litigation The most significant recent payments-adjacent legislative development is Law No. 41-2024, which amended Commercial Code provisions (Articles 410 ff.) governing cheque issuance and use; the reform has coincided with reported revenue declines exceeding 50% in 2025 for cheque-dependent small and medium enterprises and direct-debit rejection rates reported as high as 45.4%. Separately, draft bill n°42/2024 would create a Ministry of Commerce monitoring unit for online sales, with proposed sanctions including site closure and fines of 1,000-5,000 dinars for e-commerce infractions. #### Outlook No landmark payments-specific court ruling or enforcement judgment was identified in this sweep. Draft bill n°42/2024 remains pending with no confirmed enactment date; its progress, alongside continued monitoring of cheque-reform market effects, are the principal items to track in this module. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T2 [https://ecotous.tn/wp-content/uploads/2025/10/Policy-Brief_Reglementation-des-cheques.pdf](https://ecotous.tn/wp-content/uploads/2025/10/Policy-Brief_Reglementation-des-cheques.pdf) retrieved 2026-07-04 2. T2 [https://africanmanager.com/hausse-des-operations-de-paiement-en-ligne-un-secteur-en-mal-de-regulation/](https://africanmanager.com/hausse-des-operations-de-paiement-en-ligne-un-secteur-en-mal-de-regulation/) retrieved 2026-07-04 3. T2 [https://www.bt.com.tn/mediateur](https://www.bt.com.tn/mediateur) retrieved 2026-07-04 ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-04 Merchant acquiring in Tunisia is bank/SMT-centric: SMT (Monétique Tunisie) operates the central switch for POS terminals, ATMs and e-commerce gateways, masking card data from merchants via an SSL-secured payment page; e-commerce growth (2.2 million online payments in 2024) is outpacing merchant-protection safeguards, prompting a draft regulatory response. Standing sub-brief · as of 4 July 2026 140 words · last cycle 2026-07-04 #### Merchant Acquiring & Risk Merchant acquiring in Tunisia runs substantially through Société Monétique Tunisie, which operates a central SSL-secured payment gateway for e-commerce merchants such that neither the merchant nor SMT's own servers retain card number, expiry or CVV2 data after validation. Against this infrastructure, e-commerce activity is growing quickly: 2.2 million online payments were recorded in 2024, up 13.4% year-on-year, across 1,126 payment-enabled websites, while 86 consumer complaints were logged in early 2025 concerning non-conforming goods and absent guarantees — growth in volume that has prompted the draft e-commerce oversight bill n°42/2024 addressed under W7. #### Outlook Transaction-volume growth is currently outpacing dedicated merchant- and consumer-protection safeguards for online commerce specifically, which is the underlying driver of the pending regulatory response; watch for whether draft bill n°42/2024 advances and whether it introduces merchant-facing obligations beyond the sanctions regime currently proposed. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T3 [http://www.monetiquetunisie.com/index.php/fr/faq.html](http://www.monetiquetunisie.com/index.php/fr/faq.html) retrieved 2026-07-04 2. T2 [https://news.gnet.tn/paiement-electronique-tunisie/](https://news.gnet.tn/paiement-electronique-tunisie/) retrieved 2026-07-04 3. T2 [https://fr.allafrica.com/stories/202504110453.html](https://fr.allafrica.com/stories/202504110453.html) retrieved 2026-07-04 ### W9 Product Innovation & Market Development limited signal Probable confirmed 2026-07-04 Product innovation is centred on mobile-payment consolidation: the BCT-led TUNPAY unified visual identity/QR standard (2026), rapid mobile-wallet growth (+81% volume in 2025), the TuniChèque electronic-cheque digitisation platform, PAPSS regional-rail integration, and eKYC-enabled remote onboarding via the E-Houwiya digital identity system, all operating within the BCT's regulatory sandbox framework. Standing sub-brief · as of 23 August 2026 148 words · last cycle 2026-10-11 #### Product Innovation & Market Development Ooredoo Fintech Tunisie obtained Banque Centrale de Tunisie authorisation, reported 17 February 2026, to launch "walletii by Ooredoo," a digital wallet product. The authorisation preceded, by roughly a month, the definitive payment-institution licence separately granted to OFT Tunisie, the corporate sibling entity within the same Ooredoo group, on 29 January 2026 (per one reporting timeline) or 14 March 2026 (per another). The product-authorisation and entity-licensing events are related but distinct regulatory actions within the same corporate family, and the sequencing that put the product into market ahead of the parent entity's own definitive licence is the notable feature of this entry. #### Outlook Whether walletii's transaction activity is folded into the sector-wide volume growth reported under this cycle's industry-structure coverage, and how the product's operations relate to OFT Tunisie's own six-month licence launch window, are the two open questions carried into the next cycle. Periodic update · new data 2026-10-11 #### Product Innovation & Market Development Tunisia's payments-infrastructure growth continued through the first half of 2026 on the evidence of the BCT's Bulletin des Paiements N17, which confirms adoption of TunPay as the national mobile-payment label -- described as intended to become the sector's unifying standard. A national mobile-payment label serves a coordination function distinct from any individual product launch: rather than one operator's proprietary wallet or scheme, TunPay appears positioned as a sector-wide interoperability standard, which if it functions as intended would reduce the fragmentation that can otherwise slow mobile-payment adoption when multiple incompatible wallet schemes compete for merchant and consumer uptake. The same bulletin reports continued growth in underlying acceptance infrastructure: active point-of-sale terminals reached 45,600, a 5.7 percent year-on-year increase, while proximity transactions reached 25.3 million, an 18.8 percent increase. The materially faster growth in transaction volume (18.8 percent) relative to terminal-count growth (5.7 percent) suggests increasing utilisation intensity per terminal -- existing acceptance infrastructure is being used more heavily rather than growth being driven primarily by new terminal deployment, a pattern consistent with rising consumer and merchant comfort with card and mobile payment methods on an already-installed base. The TunPay standardisation initiative sits against the backdrop of Circulaire n2026-10's broader regulatory tightening (captured separately under licensing and conduct), and the two developments are complementary rather than in tension: a national interoperability standard is more valuable to the market if the underlying payment establishments operating within it are subject to a strengthened governance and cybersecurity regime, since interoperability increases the number of parties whose operational resilience affects the overall system. No specific technical architecture, governance body, or participation-mandate details for TunPay have been identified in this cycle's sourcing beyond the BCT's confirmation of its adoption as the national standard. #### Outlook The next concrete marker for Tunisia's product-innovation trajectory would be further detail on TunPay's technical and governance architecture -- whether participation is mandatory for licensed payment establishments, how interoperability is enforced across existing proprietary mobile-wallet products, and what timeline applies for full-market adoption. The continued acceleration in proximity-transaction volume (18.8 percent) relative to terminal growth (5.7 percent) in H1 2026 is worth tracking in the next BCT bulletin to see whether the trend persists or whether TunPay's rollout itself becomes the next driver of acceptance-infrastructure expansion. **1 earlier distinct update(s)** Periodic update · new data 2026-10-04 #### Product Innovation & Market Development Among the changes introduced by Circular 2026-10, reporting describes Open-API provisions for payment institutions alongside the digital-onboarding updates addressed elsewhere in this cycle's findings. This signal is thin: it rests on a single lower-tier Tunisian technology-press source describing the circular's content, without independent corroboration of the Open-API element specifically and without a retrieved primary text confirming its scope or technical requirements. The product-development significance, if the reporting holds, would be the introduction of a regulatory basis for API-based access to payment-institution infrastructure in Tunisia, a theme that in other jurisdictions underpins open-banking and embedded-finance product development. No further detail -- on scope, mandated versus voluntary participation, technical standards referenced, or timeline distinct from the circular's general three-month transition -- is available from this cycle's research. This item is flagged as limited signal pending either a primary-text retrieval or independent corroboration from a second outlet. #### Outlook The next step for this module is independent corroboration of the Open-API element and, ideally, sight of the circular's actual provisions on the subject. Until that occurs, this should be treated as an unconfirmed product-development signal rather than a settled regulatory fact. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (5)** 1. T2 [https://carthagemagazine.com/tunpay/](https://carthagemagazine.com/tunpay/) retrieved 2026-07-04 2. T2 [https://www.wearetech.africa/fr/fils/actualites/finance/tunisie-les-transactions-electroniques-ont-atteint-8-8-milliards-de-dollars-en-2024](https://www.wearetech.africa/fr/fils/actualites/finance/tunisie-les-transactions-electroniques-ont-atteint-8-8-milliards-de-dollars-en-2024) retrieved 2026-07-04 3. T1 [https://fintech.bct.gov.tn/en/node](https://fintech.bct.gov.tn/en/node) retrieved 2026-07-04 4. T3 [https://www.linkedin.com/company/flouci](https://www.linkedin.com/company/flouci) retrieved 2026-07-04 5. T3 [https://www.spendnode.io/crypto-cards/country/tunisia/](https://www.spendnode.io/crypto-cards/country/tunisia/) retrieved 2026-07-04 ### W10 Consumer Protection & APP Fraud limited signal Probable confirmed 2026-07-04 Consumer protection for payment-institution customers rests on Circular 2018-16's dedicated 'dispositif de protection du consommateur' plus a pre-existing statutory banking-mediation regime (mediator per credit institution, escalating to the BCT Governor) and the BCT's Observatoire de l'Inclusion Financière complaint-handling channel. No dedicated APP-fraud mandatory-reimbursement rule (of the UK/EU PSR type) was identified. Standing sub-brief · as of 4 July 2026 122 words · last cycle 2026-10-04 #### Consumer Protection & APP Fraud BCT Circular n°2018-16 defines a dedicated consumer-protection mechanism for payment-institution customers, alongside governance, internal-control and agent-usage rules for licensed payment institutions. The BCT's Observatoire de l'Inclusion Financière (OIF) additionally operates a financial-complaint submission channel that refers consumers to the mediator or the relevant institution, supported by documentation requirements. #### Outlook No dedicated authorised-push-payment fraud mandatory-reimbursement rule of the kind seen in the UK or EU payment-services regimes has been identified in Tunisia; consumer redress instead routes through the Circular 2018-16 mechanism, the statutory banking-mediation process addressed under W1b, and the OIF channel. This is best read as a genuine regime absence rather than a research gap, and is a marker worth tracking against any future BCT consumer-protection rulemaking. Periodic update · new data 2026-10-04 #### Consumer Protection & APP Fraud Two consumer-facing requirements are reported as part of Circular 2026-10's overhaul of the payment-institution rulebook, both resting on a single lower-tier Tunisian source and corroborated only insofar as they describe content consistent with the circular's broader, more strongly sourced provisions. First, closing or transferring a client's account now requires individual notice to the client plus a notice published on the institution's website, with a minimum lead time of 45 days. This extends the practical window a client has to arrange alternative payment arrangements before losing access to an account, and it formalises a dual-channel notification requirement (direct plus public) rather than leaving notice method to institutional discretion. Second, a minimum branch floor area of 20 square metres has reportedly been introduced, a physical-infrastructure standard presumably intended to support in-person service quality and compliance-related interactions at branch level. Neither provision has an enforcement mechanism or penalty structure described in the available reporting, and neither has been corroborated by a second independent source or a primary circular text. Both should be read as probable rather than confirmed, consistent with the general gap between the confirmed existence of Circular 2026-10 and the more granular, secondary-sourced detail of its specific provisions. #### Outlook The notice-period and branch-standard requirements take effect on the same three-month transition timeline as the rest of the circular, with the practical deadline falling around 25 December 2026. Confirmation of enforcement mechanics, and independent corroboration of the branch-floor-area figure specifically, remain open items for a future cycle. **Sources and findings (4)** 1. T2 [https://www.webmanagercenter.com/2019/01/02/429225/une-circulaire-de-la-bct-definit-les-conditions-dexercice-de-lactivite-des-etablissements-de-paiement/](https://www.webmanagercenter.com/2019/01/02/429225/une-circulaire-de-la-bct-definit-les-conditions-dexercice-de-lactivite-des-etablissements-de-paiement/) retrieved 2026-07-04 2. T2 [https://www.bt.com.tn/mediateur](https://www.bt.com.tn/mediateur) retrieved 2026-07-04 3. T1 [https://oif.bct.gov.tn/blog/formulaires-mediation-et-reclamation/formulaires-de-reclamation](https://oif.bct.gov.tn/blog/formulaires-mediation-et-reclamation/formulaires-de-reclamation) retrieved 2026-07-04 4. T2 [https://fr.allafrica.com/stories/202504110453.html](https://fr.allafrica.com/stories/202504110453.html) retrieved 2026-07-04 ### W11 AML/CFT & Financial Crime (Sentinel.gi-fed) [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/tunisia/#sec-dom-D7) Probable confirmed 2026-07-04 sentinel.position: Tunisia's AML/CFT framework is anchored in Organic Law 2015-26 (as amended by Organic Law 2019-9), with the CTAF (Commission Tunisienne des Analyses Financières) operating as the administrative-type FIU seated at the BCT. Tunisia exited FATF's on-going monitoring process in October 2019 following remediation of its 2016 mutual-evaluation deficiencies; the CTAF's own analysis flags a shift toward small-value, legitimate-source terrorism financing that evades conventional threshold-based detection. Standing sub-brief · as of 4 July 2026 209 words · last cycle 2026-07-04 #### AML/CFT & Financial Crime This module is sourced from the Sentinel.gi feed; intelligence here is attributed to that source and not independently re-analysed. The Commission Tunisienne des Analyses Financières (CTAF) is established under Article 118 of Organic Law 2015-26, as amended by Law 2019-9, seated at the Banque Centrale de Tunisie, and functions as an administrative-type financial intelligence unit receiving, analysing and forwarding suspicious-transaction declarations to the public prosecutor. Tunisia exited the FATF's on-going monitoring process on 18 October 2019, following remediation of deficiencies identified in the 2016 MENAFATF mutual evaluation. A recent CTAF strategic-analysis bulletin (the 16th, covering 2020-2025) found that terrorism-financing funds increasingly originate from small, legitimate-source sums — salaries, personal income, donations — that evade conventional detection thresholds, with cash (29%) and local interbank transfers (23%) the most-used instruments, and estimated that Tunisia loses roughly $1.2 billion a year, around 3% of GDP, to illicit financial flows, tracked in part via the Hannibal analytics platform launched in February 2021. #### Outlook Per Sentinel.gi attribution, further illicit-finance typology analysis on these findings is directed to the Financial Intelligence Monitor rather than developed within this payments brief. The structural AML/CFT framework itself — CTAF's FIU role and Tunisia's post-2019 clean FATF standing — shows no signal of imminent change. no periodic updates on record for this sub-brief ** Sources and findings (9)** 1. T1 [https://www.bct.gov.tn/bct/siteprod/documents/Cir_2018_16_fr.pdf](https://www.bct.gov.tn/bct/siteprod/documents/Cir_2018_16_fr.pdf) retrieved 2026-07-04 2. T? FIM (sentinel.gi) per-JID baseline profile — Tunisia — Tunisia's AML/CFT regime rests on Organic Law No.26 (2015) and CTAF (Commission Tunisienne des Analyses Financieres) as FIU. Tunisia exited FATF's ICRG monitoring in 2019 after a 2016 MENAFATF Mutual Evaluation and multiple enhanced follow-up re-ratings. A 5th-round MER is now pending. Beneficial-ownership rules for trusts exist (CTAF Decision No.3/2017) but lack punitive teeth, and asset-recovery capacity remains structurally weak. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness 4. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: absent-field-provenance 5. T1 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-003) — Sanctions: OFAC listing 6. T1 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-004) — Enforcement: OFAC — Ayadi Chafiq Bin Muhammad (Tunisian national, Al-Qaida financier, SDGT) 7. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: political-constraint 8. T2 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-002) — Enforcement: Tunisian investigating judiciary — Chawki Al-Tabib, former head of the National Anti-Corruption Authority 9. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: enforcement-absence ### W12 Correspondent Banking, Settlement & Access Probable confirmed 2026-07-04 Legal/regulatory infrastructure for cross-border settlement is in active reform via the draft Code des Changes (proposition de loi n°2025/115), targeted for a pre-summer-2026-recess vote. Standing sub-brief · as of 23 August 2026 261 words · last cycle 2026-09-21 #### Correspondent Banking, Settlement & Access Tunisia's correspondent-banking and cross-border settlement architecture is the subject of the most structurally significant reform tracked this cycle: proposition de loi n°2025/115, a draft Code des Changes registered before the Assembly of the Representatives of the People on 20 October 2025 and now under review by the Finance and Budget Committee, would replace Law n°18 of 1976 with a twelve-title, ninety-one-article code governing exchange controls and cross-border financial flows. The business federation CONECT submitted forty-one proposed amendments to the draft on 1 June 2026, and the Finance and Budget Committee chair has stated an ambition to bring the bill to a vote before the Assembly's 2026 summer recess. The module's analytical spine, the asymmetry between bank-channel and non-bank payment-institution access to cross-border settlement infrastructure, is directly implicated by a reform of this scope: a 1976-era exchange-control law predates Tunisia's 2016 payment-institution licensing framework entirely, meaning the non-bank PI/EMI sector currently operates its cross-border dimension against a statutory backdrop never designed with it in mind. The draft's twelve-title, ninety-one-article scope suggests a comprehensive rather than incremental rewrite, though the specific provisions bearing on correspondent-banking access are not detailed in this cycle's sourced reporting. #### Outlook The Finance and Budget Committee's stated ambition to reach a vote before the 2026 summer recess makes the coming one to two cycles the most likely window for this reform to either advance or stall. Confirmation of the specific correspondent-banking and settlement-access provisions within the draft's ninety-one articles, once available, would allow this module's coverage to move from structural framing to provision-specific analysis. Periodic update · new data 2026-09-21 #### Correspondent Banking, Settlement & Access The analytical spine of this module is normally the bank-versus-non-bank access asymmetry, and this cycle's principal development bears directly on that spine from an unexpected angle: capital-control liberalisation rather than correspondent-access mechanics narrowly defined. Tunisia's parliament adopted an amendment to the 2026 Finance Law on 2 December 2025, by a vote of 69 to 17 with 17 abstentions, permitting resident foreign-currency accounts without prior Banque Centrale de Tunisie approval for the first time in roughly five decades. Notably, a comparable proposal had been rejected in November 2024 by a much narrower 51-to-48 margin, underscoring how recently this reform was politically contested. This liberalisation is scoped to conventional foreign-currency accounts specifically; it does not, on the evidence reaching this cycle, extend to correspondent-banking access mechanics or settlement-rail participation for non-bank payment institutions. A broader draft overhaul of Tunisia's Foreign Exchange Code remains pending separately, with a multi-year uncertainty band and no confirmed advancement beyond consultation. For bank-PSPs operating correspondent relationships into Tunisia, this amendment marginally eases one friction point — resident foreign-currency holding — without altering the underlying correspondent-access architecture itself. Non-bank PIs and EMIs are not the direct beneficiaries of this specific amendment, which concerns account-holding rights for residents generally rather than institutional correspondent-access rights. #### Outlook The pending broader Foreign Exchange Code overhaul is the item to watch: if it advances beyond consultation, it could extend liberalisation into correspondent-banking-relevant territory beyond simple resident account-holding rights. Given the multi-year uncertainty band currently attached to that overhaul, no near-term change beyond the December 2025 amendment should be assumed. 1 further periodic run re-emitted the standing brief unchanged and is not shown. **Sources and findings (4)** 1. T2 [https://www.ebrd.com/content/dam/ebrd_dxp/assets/pdfs/office-of-the-chief-economist/working-papers/working-papers-2023/WP-285-Broken-Relationships-De.pdf](https://www.ebrd.com/content/dam/ebrd_dxp/assets/pdfs/office-of-the-chief-economist/working-papers/working-papers-2023/WP-285-Broken-Relationships-De.pdf) retrieved 2026-07-04 2. T1 [https://www.bct.gov.tn/bct/siteprod/documents/fiche35_a.pdf](https://www.bct.gov.tn/bct/siteprod/documents/fiche35_a.pdf) retrieved 2026-07-04 3. T2 [https://www.agranibank.org/assets/nrb/overseas/Foreign_Bank_Country_wise_19112025.pdf](https://www.agranibank.org/assets/nrb/overseas/Foreign_Bank_Country_wise_19112025.pdf) retrieved 2026-07-04 4. T2 [https://www.wearetech.africa/fr/fils/actualites/finance/tunisie-les-transactions-electroniques-ont-atteint-8-8-milliards-de-dollars-en-2024](https://www.wearetech.africa/fr/fils/actualites/finance/tunisie-les-transactions-electroniques-ont-atteint-8-8-milliards-de-dollars-en-2024) retrieved 2026-07-04 ### W13 Commercial Intelligence (M&A, Investment & Product) limited signal Probable confirmed 2026-07-04 The trailing-12-month window is dominated by regulatory market entry rather than disclosed M&A: OFT Tunisie (Ooredoo FinTech) received its final BCT payment-institution licence in January 2026, becoming the 16th licensed PSP; the BCT itself launched the TUNPAY national mobile-payment brand in 2026; disclosed venture funding for Tunisian fintechs remains limited and largely undisclosed in amount. Standing sub-brief · as of 4 August 2026 107 words · last cycle 2026-10-11 #### Commercial Intelligence (M&A, Investment & Product) Ooredoo Fintech secured Central Bank of Tunisia regulatory approval to launch its 'walletii' digital wallet on 23 February 2026, in partnership with QNB Group and Monetique. The product category is a digital wallet; the launch jurisdiction is Tunisia; financial terms were not publicly disclosed. This is a non-bank, telecom-affiliated market entry rather than a bank-led product launch, adding a new licensed participant to Tunisia's mobile-money space ahead of the TUNPAY consolidation. #### Outlook Watch for walletii's user-acquisition trajectory once TUNPAY branding requirements phase in, and for whether QNB Group's and Monetique's involvement signals further bank/telecom joint-venture wallet launches in the Tunisian market. Periodic update · new data 2026-10-11 #### Commercial Intelligence & Fintech Tunisian payments fintech Konnect Networks announced a strategic multi-investor funding round led by Attijariwafa Ventures, with participation from Visa, Plug and Play, Renew Capital and Digital Africa Ventures. The amount raised has not been publicly disclosed. The investor roster is notable for its composition: Attijariwafa Ventures brings a regional pan-African banking-group perspective as lead investor, Visa's participation signals strategic interest from a global card scheme in Tunisia's payments infrastructure, and the presence of accelerator-linked investors (Plug and Play) alongside development-finance-adjacent vehicles (Renew Capital, Digital Africa Ventures) suggests a round structured to combine strategic, financial and ecosystem-development capital rather than a single-investor-led raise. This transaction needs to be read against a thin broader funding environment: Tunisia recorded only approximately three funding transactions worth a combined $300,000 across the first half of 2026, the lowest aggregate figure in its North Africa peer set. Against that backdrop, the Konnect round -- even with its amount undisclosed -- is very likely the most significant individual fintech funding event for Tunisia in the period under review, given that the H1 2026 aggregate of $300,000 across three deals is a figure that a single strategic round of typical seed-to-Series-A scale for a multi-investor syndicate including Visa would likely exceed on its own. This makes Konnect something of an outlier data point in an otherwise constrained Tunisian fintech funding market. The round's event status is announced rather than closed or confirmed-complete in the sourcing available, and no primary source beyond secondary press/aggregator reporting (via Wamda's Tunisia country page) has been directly retrieved for the transaction's full terms. The strategic nature of the round -- combining a regional banking-group venture arm, a global card scheme, and ecosystem investors -- is consistent with a company at a growth stage seeking both capital and commercial partnership value (particularly from Visa) rather than purely financial investors. #### Outlook The principal unknowns are the round's disclosed size and its closing date, neither of which has been confirmed in sourcing available this cycle. Given Visa's participation, a relevant marker to watch is whether any subsequent commercial partnership announcement (card-scheme integration, acquiring partnership, or similar) follows the investment, which would be consistent with strategic investors of Visa's type typically pairing capital with a commercial relationship. The broader Tunisian fintech funding environment, at roughly $300,000 aggregate across three deals in H1 2026, remains the weakest in the North Africa peer set, and whether the Konnect round represents an inflection point for the market or an isolated outlier will depend on whether further funding activity follows in subsequent reporting periods. **1 earlier distinct update(s)** Periodic update · new data 2026-09-21 #### Commercial Intelligence & Fintech The discrete commercial event this cycle is Ooredoo Fintech's launch of the walletii digital wallet, following Banque Centrale de Tunisie regulatory approval granted 23 February 2026. The launch was executed in partnership with QNB Group and Monétique, positioning walletii as a bank-fintech-telecom collaborative product rather than a purely independent fintech launch. No transaction value or investment amount was publicly disclosed for this launch; the deal terms, to the extent any commercial arrangement beyond the product partnership exists, are not publicly disclosed. This is a specific, completed product-release event, distinguishable from the structural market-growth and infrastructure-standardisation developments covered elsewhere this cycle (the 31 percent transaction-value growth and the TUNPAY mandate respectively) — walletii is a single named product from a single named vendor consortium, not a market-wide trend. #### Outlook Further branded wallet launches following the walletii pattern — telecom-fintech-bank partnerships targeting BCT approval — should be watched for as a recurring commercial-event pattern in Tunisia's mobile-payments space, particularly given the market's continued double-digit transaction-value growth. **Sources and findings (3)** 1. T2 [https://africanmanager.com/oft-tunisie-obtient-lagrement-definitif-de-la-bct-en-tant-quetablissement-de-paiement/](https://africanmanager.com/oft-tunisie-obtient-lagrement-definitif-de-la-bct-en-tant-quetablissement-de-paiement/) retrieved 2026-07-04 2. T2 [https://carthagemagazine.com/tunpay/](https://carthagemagazine.com/tunpay/) retrieved 2026-07-04 3. T3 [https://pitchbook.com/profiles/company/434265-76](https://pitchbook.com/profiles/company/434265-76) retrieved 2026-07-04 ** No modules match.** Filters combine as OR inside a group and AND across groups. ## Editorial metadata Provenance only. Nothing below gates publication or affects the render. Editorial metadata for Tunisia| Field | Value | |---|---| | `trust.lawyer_review.status` | never_reviewed | | `trust.lawyer_review.reviewer` | no reviewer on record | | ` trust.content_source` | ai_generated | ## Provenance and declared absence **Disclosure model:** module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is. **Sentinel-fed modules** receive no special rendering treatment. `sentinel_feed` is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page. **Family taxonomy** is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning. **Suppressed by doctrine:** derived risk score; per-module RAG traffic light; `derived_scores` = `{"legal_accessibility": {"per_product": {"account_to_account": "regulated", "cards": "regulated", "prepaid_emoney": "licensed-emi", "stablecoin": "emerging-regime"}}}`. **Band honesty:** uncertainty bands are computed against a frozen build clock of 2026-10-21. A year-precision row is never promoted into a tighter band. **Orphan deltas:** 1 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card. **Envelope:** baseline resolved at `jurisdiction_json.baseline`; 14 module(s), 60 finding(s), 142 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).