The BCT Regulatory Sandbox: How Tunisia Tests Fintech

The Central Bank of Tunisia (BCT) launched its fintech regulatory sandbox in January 2020, promising a supervised space where startups could test new financial services before holding a full licence. Six years on, the sandbox has run a first cohort, inspired a bank-only "Sandbox Express" and sits alongside a much stricter rulebook for payment institutions. Here is what founders should know.

What the BCT regulatory sandbox is

A regulatory sandbox is a controlled test environment. A company tries an innovative product on a small scale, with real but volunteer customers, under the regulator's watch, without having to meet every licensing requirement from day one. The BCT described its own version as a test environment that lets it monitor the experimentation of innovative solutions.

The idea was first announced in a BCT communiqué on 11 December 2019, as part of a package that also created:

• a BCT-Fintech committee, meant to act as a liaison between the regulator and the innovation ecosystem;
• a dedicated fintech website for the central bank;
• a channel for stakeholders to send proposals directly to the BCT.

The official launch took place in Tunis on 21 January 2020, in the presence of then-governor Marouane El Abassi, the minister of communication technologies, the president of the banking association APTBEF and a World Bank economist. The World Bank presented the sandbox as part of a wider programme it supports on financial inclusion and fintech. The APTBEF president described it as the first sandbox of its kind in North Africa.

Why the central bank created it

At the launch, the governor framed the sandbox as a meeting point between innovation and regulation. His argument, as reported by Managers, was that regulators need to understand new technologies before they can rewrite the rules, and that the legal framework is slow to change because it depends on government and parliament, not on the central bank alone. He also warned that investors could look elsewhere if Tunisia did not create the right conditions for fintech, and noted that around half of Tunisians had no direct relationship with a bank.

When the first tests started, the BCT listed its objectives more precisely:

• help fintechs emerge and diversify digital financial services;
• improve financial inclusion;
• let startups reach regulatory compliance faster;
• help the regulator understand new technologies and, where needed, adjust the rules;
• keep financial stability and user protection as non-negotiable limits.

The first cohort: four fintechs, nine months

In December 2020 the BCT announced that testing had begun with four selected fintechs. According to Tech In Africa, the first cohort was made up of Kraoun, Instaclear, TLedger and Sqoin & Coinsence. The selected projects covered four themes:

• remote customer identification (what is now called e-KYC);
• cross-border clearing;
• crypto-assets;
• central bank digital currency.

The test period was set at nine months. At the end, participants that met the regulator's test criteria could apply for a licence or authorisation. One concrete case was reported by Business News in March 2021: TLedger, a Startup Act-labelled payments fintech, was running a proof of concept of a digital central bank currency with volunteer clients, and Société Tunisienne de Banque (STB) was described as the first bank to join that test network.

Public information on what happened next is thin. We could not find a published BCT report listing the outcomes of the first cohort, or official announcements of later cohorts. Founders should ask the BCT directly about the current application windows rather than rely on older press coverage.

The Sandbox Express for banks

In February 2023, the governor announced a second track: the Sandbox Express, aimed at Tunisian banks rather than startups. Its stated purpose was to give banks that want to roll out digital solutions a faster route to market, while letting the BCT check that those solutions are robust, including in an open banking perspective. Press coverage at the time gave no detailed eligibility criteria or launch date.

The distinction matters. A bank testing a feature in the Express track already holds a licence and capital; a startup in the original sandbox is trying to prove it deserves one.

What the sandbox does not do

The sandbox is a testing arrangement, not a licence and not a shortcut around the law. It does not allow a startup to issue electronic money, take deposits or operate a payment business permanently. To do that commercially, a company still needs an authorisation under Law No. 2016-48 on banks and financial institutions, for example as a payment institution.

That exit route has become more demanding. On 25 September 2026, the BCT published Circular No. 2026-10 on payment institutions, replacing the 2018 framework. It adds governance, cybersecurity, client-fund segregation and partnership approval requirements, and enters into force three months after publication. Anything a startup tests in a sandbox today will eventually have to meet that standard.

Why it matters for Tunisian founders

For a fintech founder, the sandbox is mainly useful in three situations:

• Your product does not fit an existing licence category, for instance a new identification or settlement model. Testing with the regulator is the only realistic way to get a ruling.
• You need evidence before raising money. A supervised test with real clients is a stronger signal to investors than a pitch deck.
• You plan to apply for a licence anyway. Early contact with supervisors helps you design compliance, data protection and anti-money-laundering controls the way they expect.

The limits are equally clear. The sandbox is small, its later activity is poorly documented in public, and Tunisia's broader rules — on foreign exchange, crypto-assets and capital — remain unchanged by it. The governor said as much in 2020: the sandbox helps the central bank learn, but changing the law requires the government and parliament.