Tunisia Payments & Fintech Regulation

Licensing, Authorisation & Market Access

Tunisia's central bank has issued a circular, numbered 2026-10 and published on 25 September 2026, that explicitly repeals and replaces Circular 2018-16 as the governing rulebook for payment institutions. Press reporting across multiple independent Tunisian outlets is consistent on this point, though no bct.gov.tn primary text has been retrieved this period, holding confidence at the probable level. Among the market-access-relevant changes, the circular is reported to require prior central-bank approval for any partnership between a payment institution and a third party, a step that did not exist in the same explicit form under the prior rulebook and that gives the central bank a new, ongoing gatekeeping role over how payment institutions structure their commercial relationships, not merely at the point of initial licensing.

Against this tightening on the governance side of market access, the underlying structural architecture of what a payment institution may do appears, on the lower-tier evidence available this period, to remain unchanged: account-tier transaction caps are reported to continue at TND 1,500, 5,000 and 20,000, payment institutions remain limited to distributing rather than issuing electronic money, and activity remains confined to Tunisian-dinar, domestic-only transactions. This continuity claim rests on a single lower-tier source not independently corroborated, so it should be read as the best available signal rather than a confirmed fact, but it is consistent with a reform pattern that tightens oversight and governance without expanding the product or geographic scope available to licensed payment institutions.

Outlook

The near-term question for market access is how the central bank operationalises its new partnership-approval requirement in practice: whether this becomes a routine administrative step or a substantive gating mechanism that materially slows commercial partnerships will shape the practical market-access environment for payment institutions through the circular's reported implementation window to around late December 2026. Separately, whether the account-tier caps and product-scope limits are revisited in a future circular remains an open question with no signal in the current record pointing toward change.

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.

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.

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.

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.

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.

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.

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.

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.