The mandatory extension of electronic invoicing to all VAT-liable service providers, by the 2026 Finance Law, has sparked serious concern. Presented as a simple step toward administrative modernization, this reform—if implemented without solid guarantees—risks triggering a cash-flow crisis for thousands of small businesses and, paradoxically, fueling the informal economy it is meant to combat.
A Parliamentary Vote Without Debate on Feasibility or Legal Security
When the provisions expanding the scope of electronic invoicing were adopted, there was no real debate on the tax administration’s operational capacity to absorb such a technical shock.
No questions were raised about:
- the capacity of the National Agency for Electronic Certification (ANCE) to issue hundreds of thousands of electronic certificates within reasonable timeframes;
- the real cost of this obligation for very small businesses and small trades;
- the availability of administrative and digital infrastructure across the entire national territory.
Even more troubling, the measure was introduced without any public data on the categories of taxpayers concerned, their geographic distribution, or their level of digital readiness.
A Vulnerable Audience Exposed to Unintentional Non-Compliance
The target population is particularly fragile: artisans, small traders, and service providers, mostly under the flat-rate tax regime, often with limited education and digital literacy.
Already struggling with the reporting requirements of the standard tax regime, these taxpayers are abruptly pushed into a world of technical, costly, and complex requirements that are largely disconnected from their actual capacities.
Without advance communication, clear educational demonstrations, or local support structures, many will find themselves in violation—not through fraudulent intent, but due to simple material inability.
The Specter of a Widespread Cash-Flow Crisis
The most immediate risk is technical. The TTN (Tunisia TradeNet) platform is a mandatory gateway. In the event of saturation, outages, or malfunctions, the entire invoicing and payment chain could be blocked.
A service provider unable to issue an electronic invoice will not be paid, especially when the client is a company subject to strict accounting and VAT deductibility requirements. For businesses with tight cash flow, a few weeks of delay can be enough to jeopardize operations.
This technical risk is compounded by a major structural issue:
Under Article 5 of the VAT Code, the taxable event occurs upon issuance of the invoice, regardless of actual payment. The service provider is therefore required to remit VAT to the State even before receiving payment from the client.
This mechanism turns VAT into a forced cash advance, exposing small providers to penalties and sanctions completely disconnected from their real financial capacity.
The Perverse Effect: A Return to the Informal Economy
The irony of the system is that a measure intended to fight informality may end up reinforcing it. Faced with a technically inaccessible and financially burdensome obligation, many small providers will be tempted to propose cash transactions without invoices.
For modest amounts—such as a 200-dinar repair—the provider and the client will objectively have an incentive to bypass the electronic procedure. The system thus risks creating its own parallel market, based on tacit survival agreements.
Hidden Costs and Underestimated Technical Risks
Beyond formal compliance, providers will have to bear:
- the purchase of computer equipment;
- a stable and continuous internet connection;
- subscriptions to certified software;
- acquisition and renewal of electronic certificates;
- increased reliance on an accountant or technical intermediary;
- and, in some cases, a per-invoice fee, akin to a real tax on activity.
The reliability of the system also raises questions: does ANCE truly have the human and logistical resources to cover the entire territory, especially interior regions? What happens in the event of a prolonged TTN outage or system saturation? Is economic activity expected to come to a halt?
A Catastrophic Scenario That Must Be Avoided Urgently
In light of the difficulties already encountered by companies currently enrolled and the malfunctions observed on the TEJ platform, many observers fear a cumulative scenario: administrative saturation, blocked payments, digital exclusion of the most vulnerable, and ultimately a generalized return to informal practices out of necessity.
In response to these risks, urgent support measures are needed:
- a tolerance period without sanctions;
- massive and accessible training;
- extreme simplification of interfaces;
- and, above all, a recalibration of the VAT taxable event for very small businesses, by linking tax payment to actual cash collection.
A Major Economic and Legal Stake
The issue goes far beyond administrative modernization. What is at stake is the legal security, economic viability, and tax confidence of a whole segment of Tunisia’s productive fabric in the implementation—or the failure—of this reform.
At this stage, the question is no longer whether electronic invoicing is desirable, but how and under what conditions it can be imposed without weakening the economic fabric.
A tax reform rolled out without public debate, without impact assessment, and without protection mechanisms for the most vulnerable is not modernization—it is a collective risk-taking.
If electronic invoicing becomes a factor of exclusion, payment blockage, and a return to informality, then the failure will be shared by the administration, the legislature, and the national economy.
There is still time to open a transparent and responsible public debate, before technology becomes an instrument of precarization rather than a lever of trust.
