Electronic Invoicing Obligation Sparks Concerns Among Tunisian Professionals
The Council of Deans of the Tunisian Union of Liberal Professions (UTPL) has expressed strong concerns regarding the implementation of the electronic invoicing obligation for service providers, which came into effect with Article 53 of the 2026 Finance Law. This measure, presented as a tool for modernizing the tax system, strengthening transparency, and combating fraud, reveals significant practical and legal difficulties, particularly for SMEs and liberal professions, highlights the UTPL Council.
Major Technical and Legal Obstacles
Among the main difficulties identified:
- Legal Ambiguity: The law distinguishes between commercial invoices and fee notes, each subject to a specific tax regime. However, electronic invoicing explicitly applies only to commercial invoices, leaving fee notes outside the scope of application, creating a legal vacuum for non-commercial professionals.
- Lack of Standards and Approved Platforms: The absence of harmonized technical and legal formats generates confusion and accessibility difficulties for professionals.
- Insufficient Preparation and Financial Burden: Many operators lack technical skills and must bear the cost of specialized software and electronic signature certificates, a heavy burden for limited-resource structures.
- Generalized Application without Progressivity: The obligation concerns all service providers, without considering the size, technical, or financial capacity of businesses, which could undermine trust between the administration and professionals and hinder economic activity.
UTPL Recommendations
In response to these difficulties, the Union calls for:
- Including fee notes in the scope of electronic invoicing.
- Publishing necessary implementation texts to clarify obligations.
- Providing a transitional period with suspension of sanctions to allow professionals to comply progressively.
- Implementing training and technical support programs, particularly for small structures and liberal professions.
- Establishing a serious dialogue between the tax administration, professionals, and specialized experts for a progressive and equitable application of the law.
It is worth noting that the Ministry of Finance indicated on January 13, 2026, that the obligation would be applied with flexibility, particularly for SMEs and certain sectors, to avoid technical and economic difficulties and prevent any negative impact on the national economy.
