Tunisia (TN)

Licensing, Authorisation & Market Access

Tunisia's payment-institution regime rests on a two-tier legal architecture. Law No. 2016-48 on banks and financial institutions is the governing primary statute, with Articles 24-30 creating the Commission d'agréments and the licensing criteria that establish payment institutions as a distinct, non-bank licensed category separate from banks and financial institutions. BCT Circular n°2018-16 supplies the implementing detail under Articles 20-21 of the 2016 law, authorising licensed payment institutions to open tiered payment accounts, execute transfers and direct debits, commercialise bank- or postal-issued e-money, and conduct manual currency exchange as an ancillary activity. Prudential entry is capital-gated: minimum capital thresholds run from 50 million dinars for resident banks and 25 million for financial institutions down to 10 million for business banks and factoring companies and 5 million specifically for payment institutions, with a compliance deadline set at July 2017.

The most recent market-access event is OFT Tunisie's final licence, granted by decision dated 29 January 2026 and making the Ooredoo FinTech International LLC subsidiary the sixteenth BCT-licensed payment service provider; the entity has up to six months from notification to commence operations. As of March 2026 the licensed PSP population stands at sixteen, spanning independent fintech entrants and bank- or postal-affiliated structures, operating within a regime that also includes a Fintech Sandbox (BCT-Lab) mechanism requiring a full approval-file submission once a sandbox pilot concludes. Two T2 sources corroborate the January 2026 decision date and sixteenth-PSP status but disagree on the JORT publication number, a discrepancy that does not affect the core licensing fact.

Outlook

OFT Tunisie's six-month operational window runs into the third quarter of 2026; the near-term marker to watch is whether the entity begins live operations within that period. Beyond this specific grant, the steady cadence of PI licensing to date suggests the BCT is continuing to treat non-bank market entry as an open channel rather than a constrained one, a posture that sits alongside the tighter conduct and safeguarding obligations addressed in the companion W1b module.

Conduct, Safeguarding & Financial Promotions

Tunisia's conduct and safeguarding regime for payment institutions is built primarily on BCT Circular 2018-16. The circular tiers payment accounts by identification level: Level 1 accounts, opened under lightened identification, are capped at a 500 dinar balance and 250 dinar daily outflow; Level 3 accounts, requiring full identification and physical presence, are capped at a 5,000 dinar balance and 1,000 dinar daily outflow. Under Article 21(5) of Law 2016-48, payment institutions must maintain professional civil-liability insurance or a bank guarantee sized to their own funds, with the BCT pre-approving the calculation methodology used. Customer funds themselves are protected through a structural prohibition rather than a discretionary safeguard: payment institutions are barred from extending credit on payment accounts or crediting balances with anything other than central-bank money, must hold client funds under a ring-fenced 'convention de compte global' with a depositary bank, and may never allow an account to show a debit position.

Consumer-facing dispute handling predates the PI-specific regime and continues to apply across both bank and non-bank channels: the banking-mediation framework under Decree n°2006-1881 requires consumers to exhaust recourse first with the credit institution, subject to a fifteen-working-day response requirement, then with the bank mediator, before a complaint can be escalated to the BCT Governor. On the access side, BCT KYC rules dated February 2025 enable remote onboarding via the E-Houwiya national digital identity system, a change reported to be improving unbanked access and underpinning fintech eKYC flows such as Flouci's.

Outlook

No dedicated financial-promotions enforcement action against a Tunisian payment institution was identified this sweep, a gap consistent with the broader under-indexing of promotional-conduct enforcement as a monitoring category; this remains a watch item rather than a confirmed absence of activity. The tiered-account and compte-global safeguarding architecture set in 2018-16 remains the operative baseline and shows no signal of imminent revision.

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.

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.

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.

Payment Corridor Dynamics

Tunisia has adopted SWIFT ISO 20022 messaging and joined the Pan-African Payment and Settlement System (PAPSS) to enable lower-cost intra-African settlement, with the BCT also planning to extend the domestic Elyssa-RTGS system to foreign-currency operations. The country's principal payments corridor by value, however, remains outbound diaspora remittances, estimated at roughly $2.3 billion a year according to World Bank data, flowing mainly from France, Italy, Germany, Belgium and Canada via La Poste Tunisienne, Western Union and RIA at reported fees of 5-8%, all conducted under strict BCT capital controls including a 6,000-dinar annual tourist foreign-exchange allowance.

Outlook

PAPSS accession and ISO 20022 migration point toward gradually broadening corridor access and rail modernisation, but the remittance corridor itself remains fee-heavy and tightly constrained by capital controls, with no signal this sweep of an imminent change to the tourist FX allowance or remittance-fee structure.

Industry Structure & Commercial Dynamics

Tunisia's payments industry remains bank-dominated at the incumbent level — BIAT, STB and BNA among others — alongside a growing licensed non-bank PSP segment that reached sixteen providers by March 2026, and an active fintech scene led by Flouci/Kaoun and La Poste Tunisienne's D17 wallet. Flouci itself reports having processed over $91.2 million in transactions with more than 305,000 downloads and 67,000 active users as of December 2024, having registered in 2024 as a payment facilitator for business clients.

Outlook

The structural direction is toward continued growth of the licensed non-bank segment against a still bank-dominated base; Flouci's scale figures, while notable for a market of Tunisia's size, remain modest relative to regional fintech peers, an important benchmark against which the pace of further PSP licensing should be read.

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.

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.

Product Innovation & Market Development

TUNPAY has been established as a unified national visual identity and technical standard for mobile payments, mandatory for all mobile-wallet issuers; mobile payment transactions grew 81% in 2025 to 8.4 million operations worth 1.769 billion dinars. Separately, Flouci (by Kaoun) has launched what is reported as Tunisia's first Banking-as-a-Service concept, BCT-approved, in partnership with Banque de Tunisie et des Émirats.

Outlook

TUNPAY's mandatory-adoption design means its effects will be felt across every mobile-wallet issuer's product roadmap, banks, La Poste and licensed PIs alike, making it the most structurally significant product development in this module this cycle. Flouci's BaaS launch, while reported only through a single company channel, points to continued non-bank experimentation with embedded-banking models; independent confirmation of scale or usage was not available this sweep.

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.

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.

Correspondent Banking, Settlement & Access

The central analytical spine of this module is the asymmetry between bank access to correspondent networks and non-bank reliance on those same bank-intermediated channels. Tunisia's correspondent-banking relationships show measurable decline per EBRD/BEPS III research drawing on SWIFT and BIS data on active correspondents per corridor between 2012 and 2022, grouping Tunisia with Egypt, Morocco, Lebanon and Jordan among de-risking-affected jurisdictions. Domestically, the SGMT large-value settlement system protects the national banking system against systemic liquidity and credit risk, exchanging inter-bank data via SWIFT messages in line with international standards. Tunisia's 2024 accession to PAPSS offers an alternative settlement channel intended to reduce correspondent-banking reliance for intra-African transactions by settling directly in local currencies.

Outlook

PAPSS accession is a partial mitigant rather than a full substitute for correspondent-banking access, since it addresses intra-African corridors specifically rather than Tunisia's broader correspondent-banking footprint; continued de-risking pressure on bank-to-bank relationships elsewhere remains the more significant structural risk to monitor, particularly given the non-bank sector's downstream dependence on bank-intermediated cross-border access.

Commercial Intelligence (M&A, Investment & Product)

Three discrete commercial events populate this module in the trailing window. OFT Tunisie received final BCT payment-institution licensing approval, finalising a process begun with a provisional licence in December 2024 — a regulatory market-entry event expanding Tunisia's licensed PSP roster to sixteen and signalling continued regulatory openness to telco-affiliated fintech entrants. TUNPAY was launched by the BCT in concertation with Société Monétique Tunisie as a completed product release: Tunisia's unified national mobile-payment visual identity and technical standard, with mandatory adoption reshaping wallet-issuer product roadmaps across banks, La Poste and licensed payment institutions. On the investment side, Flouci (Kaoun) has raised cumulative disclosed funding of $186,000 from Digital Currency Group, Orange Fab Tunisia, Visa Accelerator, Rally Cap Ventures and Launch Africa Ventures; this amount is publicly disclosed, though the exact timing of individual rounds within the trailing twelve months was not confirmed this sweep.

Outlook

The dominant commercial-intelligence signal this cycle is regulatory-market-entry and standard-setting activity (the OFT Tunisie licence and the TUNPAY launch) rather than disclosed private investment, which remains modest by regional comparison. Any future disclosed funding round for Flouci or a peer PI/EMI would be the next marker to watch in this module.