Payment Institutions in Tunisia: Licensing and the 2026 Rules

Tunisia's payment institution licence is the main legal route for a non-bank to hold customer payment accounts, move money and accept card or mobile payments. On 25 September 2026 the Central Bank of Tunisia (BCT) rewrote the rulebook with Circular No. 2026-10, which replaces the 2018 framework and takes effect three months after publication. For fintech founders, the bar to run a licensed payments business just got higher.

The legal basis: Law 2016-48

Payment institutions (établissements de paiement) were created by Law No. 2016-48 of 11 July 2016 on banks and financial institutions. The law lists the payment services they may provide and makes the BCT their licensing and supervisory authority. Recent licence decisions published in the Official Journal (JORT) cite article 10 of the law for the scope of services and article 20 for the payment institution authorisation itself.

The operating rules were set by BCT Circular No. 2018-16 of 31 December 2018. That text, which introduced tiered payment accounts, is now repealed and replaced by Circular No. 2026-10.

Payment institution vs e-money: who can do what

A frequent point of confusion for founders: in Tunisia, a payment institution is not an e-money issuer. Under the new circular, a payment institution may distribute prepaid electronic money, but that e-money must be issued by a bank or by the Office National des Postes (La Poste Tunisienne, which runs e-Dinar and D17).

According to La Presse's summary of Circular 2026-10, a licensed payment institution may:

• open payment accounts in Tunisian dinars;
• accept cash deposits and withdrawals on those accounts;
• execute direct debits, electronic transfers and cash-funded transfers;
• process remote and proximity payments, including mobile payments;
• issue payment instruments linked to its accounts;
• sell prepaid e-money issued by banks or La Poste;
• receive funds from abroad, by transfer or via money transfer operators;
• carry out manual currency exchange under BCT rules.

All of this must be done in dinars and inside Tunisia. A payment institution cannot take deposits, lend, or let accounts go overdrawn.

Who holds a licence

The BCT does not publish an easy-to-find register, and press coverage gives no total count. Two recent decisions illustrate the process:

• First Pay, a subsidiary of Amen Bank, was licensed as a resident payment institution by BCT licensing committee decision No. 59 of 1 July 2024, published in the JORT on 9 August 2024. It had six months from notification to start operating.
• OFT Tunisie, a subsidiary of Ooredoo FinTech International, received a BCT authorisation to set up a payment institution in December 2024, then a definitive licence by decision of 29 January 2026, published in the Official Journal (JORT). It also had six months to start operating, or risk losing the approval.

Both are backed by large groups — a bank and a telecom operator. That pattern is worth noting for startups weighing the licence route against partnering with a licensed institution. For the wider landscape, see our guide to mobile payments in Tunisia.

Circular 2026-10: account tiers and limits

The new circular keeps the three-level account structure from 2018. Several outlets, including Business News, stressed that the ceilings are unchanged:

Other limits include TND 3,000 per cash-funded transfer and the equivalent of TND 20,000 per incoming transfer from abroad, which must be justified. Each person may hold only one payment account per institution. Merchant accounts sit outside the tiers: they can only be credited with proceeds of accepted payments and require a written agreement with the merchant.

What is new: governance, cyber, partners, agents

The bigger change is in how payment institutions must be run.

Governance

Boards must set up an audit and risk committee, and audit, risk and compliance functions must be independent from operations. According to Challenges.tn, senior appointments must be notified to the BCT, which has one month to object.

Client funds

Customer and merchant money must be placed in a single global account at a bank no later than the next business day, kept fully separate from the institution's own funds, and reconciled so that the balance equals the sum of all customer balances. These funds cannot finance operations.

Remote onboarding and cybersecurity

Accounts can be opened remotely if the process is at least as strict as in-branch identification: document checks, proof of life (such as facial recognition) and at least two-factor authentication. Systems must be audited by firms certified by the national cybersecurity agency before launch and periodically, with an annual security audit sent to the BCT. Attacks or intrusions must be reported immediately. See our explainer on e-KYC and AML rules.

Partnerships and agents

Any commercial or technical partnership — distribution network, technology provider, specialist skills — needs prior BCT approval, backed by a file that includes a three-year business plan and a risk map. Information systems must stay segregated from the partner's. The circular distinguishes principal agents from retail agents, and the institution remains responsible for everything its network does.

What it means for founders

The 2026 circular pushes Tunisian payment institutions closer to bank-style supervision. For a startup, the practical consequences are:

• Compliance costs rise. Independent control functions, certified security audits and monthly-to-annual reporting require staff and budget before revenue.
• Partnerships slow down. White-label deals, co-branded cards and telecom tie-ups now need BCT sign-off in advance.
• Product design is constrained. Dinar-only, domestic-only, capped balances and no credit limit what a wallet can be.
• Timing matters. Existing institutions have until roughly late December 2026 to comply. Only the French text published on the BCT website on 28 September 2026 is authoritative; the bank issued a corrected version that day to fix numbering in two articles.

Founders who want to test a model before committing to a licence can look at the BCT regulatory sandbox. Those planning to operate at scale should budget for the 2026 requirements from day one.