Tunisian tax law attaches fines to electronic invoicing mistakes: a paper invoice where an electronic one is required, an electronic invoice missing mandatory mentions, or goods on the road without the right document. This article gives the amounts from the Ministry of Finance note, with their dates, and the technical mistakes that lead to rejected invoices.
The fines
The amounts come from the Ministry of Finance note commune no. 10/2025, which explains article 71 of law no. 2024-48 of 9 December 2024 (the 2025 Finance Law) and lists the penalties in an annex (read it, Arabic only):
Penalty dates are not settled. A bill filed in February 2026 proposes delaying the penalties to 1 January 2027, and the press reported in September 2026 that the final calendar is still open (Business News, 15 September 2026). We found no published official text confirming the delay. Check the Official Journal before relying on a date.
- Paper invoice issued for an operation that must be electronic: 100 to 500 TND per invoice, with the total capped at 50,000 TND for the invoices found. It applies to offences from 1 July 2025.
- Electronic invoice issued without the mandatory mentions: 250 to 10,000 TND. It applies to offences from 1 January 2025.
- Goods transported without a paper copy of the electronic invoice or an equivalent document: 20% of the value of the goods, with a minimum of 500 TND. It applies to offences from 1 July 2025.
- Unnumbered invoices, or numbering in an irregular or broken series: 50 to 1,000 TND. This was already in the Code.
The annex also recalls the heavier offences that already existed in the Code of Tax Rights and Procedures, such as not issuing an invoice when required to, or issuing false invoices to avoid tax. These carry a prison term of 16 days to 3 years and a fine of 1,000 to 50,000 TND, and they are not specific to electronic invoicing.
Offences are recorded, prosecuted and settled under articles 70 to 80 of the same Code.
Do these apply to service providers now?
The 2026 note says the duty reaches service providers in steps. It applies from 1 January 2026 to those that joined the network and met the conditions, while providers with a pending membership keep issuing paper invoices (note commune 02/2026, Arabic). Read our article on who must issue electronic invoices for the detail. We have not found a later official text that changes this, and the rules can change, so check the latest notes on the tax administration’s site.
What the mandatory mentions are
Article 18 of the VAT Code requires an invoice to show the date of the operation, the identity and address of the customer (with the tax identifier when the customer must declare its existence), the supplier’s tax identifier, the product or service and the price excluding VAT, and the VAT rates and amounts. An electronic invoice carries the same mentions, plus the issuer’s electronic signature and a unique reference from the approved body.
Technical mistakes that get an invoice rejected
These come from TTN’s own documents (signature specification and archive):
- Editing the XML after signing. The platform checks the digests. Sign the final form only.
- More than one signature, or a signature that does not follow XAdES-B. Each invoice carries exactly one.
- An expired or revoked certificate. The platform checks that the chain is valid and not revoked.
- A signing solution that ANCE has not approved.
- Special characters or the wrong encoding. Use UTF-8.
- A wrong file name on SFTP. The file must be named after the invoice number and be XML. A rejected invoice returns a file ending in .error, and someone has to read it.
- Treating the PDF as the invoice. The legal document is the signed electronic invoice registered with TTN. A PDF copy is only a copy.
- Skipping the administrative steps: no membership with TTN and no declaration at the tax office.
A point in your favour
If your supplier breaks the rules, you keep your VAT deduction as long as you hold a paper invoice that complies with article 18 of the VAT Code. The 2026 note says so.
Avoiding the mistakes
Test every case you issue: credit notes, several VAT rates, foreign currency, a rejected invoice and a retry. Keep TTN’s answers. Our article on choosing software or connecting your ERP lists what to ask a vendor, and the TEIF article explains the signature. Axynoxia can review your setup: see our El Fatoora integration service.
Questions
What is the fine for issuing a paper invoice when an electronic one is required?
100 to 500 TND per invoice, with the total capped at 50,000 TND for the invoices found, for offences from 1 July 2025, according to note commune 10/2025.
What is the fine for an electronic invoice without the mandatory mentions?
250 to 10,000 TND, for offences from 1 January 2025, according to the same note.
What happens if goods travel without the right document?
A fine of 20% of the value of the goods, with a minimum of 500 TND, when they travel without a paper copy of the electronic invoice or an equivalent document, for offences from 1 July 2025.
Why would TTN reject an invoice?
Common causes are a changed XML after signing, several signatures, a revoked or expired certificate, a signing solution not approved by ANCE, wrong encoding or a wrongly named file.
Sources
- Ministry of Finance, note commune no. 10/2025 on article 71 of law no. 2024-48, with the penalty annex (Arabic only, Jibaya)
- Ministry of Finance, note commune no. 2/2026 on article 53 of law no. 2025-17 (Arabic only, Jibaya)
- TTN, Technical specifications of the electronic signature, version 3.0 of 29 May 2026
- TTN, El Fatoora specification archive (TEIF guide, web service and SFTP specifications)
Related reading: who must issue electronic invoices, TEIF and the electronic signature and choosing software or connecting your ERP.
This article is general information based on the texts cited. It is not legal or tax advice. Confirm your situation with your accountant.
Axynoxia connects existing invoicing software to El Fatoora and reviews setups before go-live. See the integration service or book a discovery call. You can also open Axynoxia Invoice, our invoicing platform prepared for Tunisian electronic invoicing, at invoice.products.axynoxia.com.