Tunisian Central Bank Issues Revised Circular on Payment Institutions
The Central Bank of Tunisia (BCT) published a revised version of Circular No. 2026-10 on September 28, 2026. This circular outlines the rules governing the activities and operations of payment institutions. The original text had been published on the BCT’s website on September 25, 2026.
The BCT clarified that the new French version corrects only the numbering in two articles of the circular, with no changes to their content or scope. This correction follows an incident during the file conversion process. Consequently, the BCT stated that only the French version published on its website on September 28, 2026, is authoritative.
Key Regulatory Changes
Substantively, Circular No. 2026-10 repeals and replaces Circular No. 2018-16 dated December 31, 2018. It introduces several evolutions to the regulatory framework applicable to payment institutions, based largely on the experience accumulated since the effective start of their activities in 2021.
Increased Account Limits
The reform raises the limits for payment accounts to better meet user needs and encourage greater use of digital payment methods:
- Level 1 Accounts (exclusive to natural persons): The balance limit increases from 500 to 1,500 Tunisian Dinars (TND).
- Level 2 Accounts (accessible to natural and legal persons): The limit increases from 1,000 to 5,000 TND.
- Level 3 Accounts: The limit increases from 5,000 to 20,000 TND.
Cash withdrawal limits are also raised for Levels 2 and 3:
- Level 2: From 500 to 3,000 TND per day.
- Level 3: From 1,000 to 10,000 TND per day.
- Level 1: The previous daily withdrawal limit of 250 TND is removed.
Additionally, the new circular allows payment institutions to issue electronic payment instruments linked to payment accounts and co-branded cards through partnerships.
Remote Account Opening
While remote opening of payment accounts was already provided for in previous regulations, it is now extended to all types of accounts. However, this comes with strengthened identification requirements. The BCT mandates:
- Authentication based on at least two factors.
- Verification of the client’s effective presence through a "proof of life" mechanism.
- The use of facial recognition, audiovisual devices, or other equivalent mechanisms with an appropriate level of reliability.
Merchant Accounts
The circular provides clarifications on accounts dedicated to merchants. These accounts are:
- Uncapped in terms of balance.
- Exclusively intended to receive funds from payment operations performed on behalf of customers, such as invoice payments and fund transfers.
According to the BCT, this evolution aims to foster greater integration of merchants into the electronic payment ecosystem, expand the acceptance network, and promote the use of digital payment methods.
Oversight of Mandated Agents and Partners
The new circular strengthens the oversight of agents mandated by payment institutions. It requires greater attention to their:
- Selection
- Monitoring
- Training
- Control
The text also specifies conditions for engaging commercial and technical partners. However, the BCT maintains a central principle: the payment institution remains responsible to its clients and the Central Bank for the activities and services delegated to these partners.
Governance, Risk, and Security
The circular consolidates requirements regarding governance, risk management, and internal control, adopting an approach proportionate to the size, nature of activities, and risk profile of each institution.
Key enhancements include:
- Information Security: Strengthened requirements for IT system security, personal data protection, and cybersecurity.
- Anti-Money Laundering (AML): A risk-based approach is central to the AML framework.
- Auditing: Enhanced due diligence by statutory auditors in evaluating the internal control systems of payment institutions.
Enhanced User Protection
The new regulation enshrines the principles of fairness and pre-contractual information:
- Transparency: Fees, commissions, and taxes must be communicated transparently before and after each transaction, via electronic or physical means.
- Accessibility: Communication materials must be adapted for illiterate persons and those with specific needs.
- Complaints: The existing mechanism for handling customer complaints is maintained.
Segregation of Funds
The circular finally enshrines the principle of segregation between client funds and the payment institution’s own funds. Collected funds must be deposited, no later than the next business day after receipt, into a single omnibus account at an authorized deposit bank. This account must permanently maintain a balance corresponding to the assets of clients and merchants.
Conclusion
Through this overhaul, the BCT aims to open new development perspectives for payment institutions and encourage a gradual refocusing of their business models on digital payment services. The reform also seeks to contribute to reducing cash usage and promoting financial inclusion, while maintaining strict requirements for operational security, risk management, and user protection.
