In Tunisia, where financial technology founders have long promised to liberate a cash-obsessed population from the clutches of paper money, the central bank has responded with a clear message: not so fast, and certainly not without a safe and a direct police landline on the premises.

Circular №2026–10, issued on September 25 by the Banque Centrale de Tunisie (BCT) and signed by Governor Fethi Zouhair Nouri, officially overhauls the country’s 2018 payment rules. In practice, it hands North Africa’s aspiring tech disruptors a 90-day ultimatum to transform their nimble digital wallets into heavily audited, state-monitored mini-banks before full enforcement begins in late December.

The regulatory squeeze illustrates the growing divide between North Africa’s tech enthusiasts and its monetary guardians. For years, Tunisia’s cohort of roughly 50 fintech startups pitched international investors on “democratizing finance” in a country where an estimated 30 to 40 percent of economic activity takes place in the cash-driven informal sector. In their rush to build scale, some operators turned to creative workarounds — such as allowing users to convert mobile phone airtime into spendable digital balances — that functioned less like formal banking and more like an unregulated barter economy.

The BCT, with the risk tolerance of a 19th-century vault keeper, appeared to have had enough. Having spent years steering Tunisia off international money-laundering watchlists, the central bank has decided that if young technologists wish to move money, they will do so under some intense supervision. 

Capping the “Disruption”

To curb systemic risk, the BCT has laid down strict upper limits on how much cash digital platforms are actually allowed to touch. Accounts have been split into four distinct legal tiers, capped firmly in Tunisian Dinars (TND):

• Level 1 Accounts: Individual retail users only, with balances capped at TND 1,500 ($507) under simplified identity checks.
• Level 2 Accounts: Open to individuals and small businesses, capped at TND 5,000 ($1,689), with daily cash withdrawals limited to TND 3,000 ($1,014).
• Level 3 Accounts: Corporate and high-volume individual accounts, capped at TND 20,000 ($6,757), with daily withdrawals capped at TND 10,000 ($3,378). These require full tax and income verification.
• Merchant Accounts: Uncapped transitional accounts designed strictly to process verified commercial sales, provided every millime (a fractional unit of a Tunisian dinar) is backed by a business contract.

To ensure startups do not try to manufacture scale through multiple registrations, individual users are legally restricted to a single account per institution. Overdrafts and negative have been explicitly outlawed. Crucially, the BCT has closed a favorite industry loophole: payment accounts can no longer be topped up using mobile phone airtime recharges — a practice that had effectively created an unmonitored secondary currency managed by telecom operators. Individual cash remittance transfers are capped at TND 3,000 ($1,014) per transaction, while incoming cross-border remittances are capped at TND 20,000 ($6,757) and require paper justification. All transaction logs must be archived for a mandatory 10 years.

The Partnership Trap: IT Isolation and Co-Branding Controls

One of the circular’s most onerous provisions targets commercial alliances. In recent years, early-stage fintechs survived by partnering with major telecom companies (such as Ooredoo or Tunisie Telecom), supermarket chains, and bank card networks to offer co-branded payment cards and piggyback on existing retail distribution.

Under the new rules, any commercial or technical partnership, white-label deal, or co-branded card issuance is subject to prior authorization from the BCT. To secure permission, fintechs must submit a detailed three-year business plan, a multi-layered risk map, and draft contracts.

More challenging for software developers is the mandate for strict structural and system-information (SI) isolation. The central bank requires a complete technical firewall between the payment institution’s database and the partner’s IT infrastructure. Commercial partners are explicitly barred from accessing customer payment ledgers or using client balances to offset shared operational debts. For fintechs whose entire core architecture was built on lightweight APIs integrated directly into partner systems, this requirement forces an expensive infrastructure redesign.

BCT-Mandated Fintech–Partner Isolation Architecture

CRITICAL FIREWAL: Commercial partners have zero direct access to client payment ledgers.

The End of Cheap Code

For startups whose business models relied on lightweight software and remote user acquisition, the circular introduces a punishing array of operational requirements.

Under the new rules, payment institutions can no longer simply hold customer money on their balance sheets or deploy it into operational cash flow. Every dinar of client funds must be segregated and deposited into a pooled “Global Account” at a traditional commercial bank no later than the next business day. Daily automated reconciliations are compulsory, and firms must maintain approved professional indemnity insurance or a bank guarantee proportional to their transaction volume.

Remote customer onboarding (e-KYC) has also been subjected to state scrutiny. Smartphone sign-ups must now feature two-factor authentication, document integrity scans, and biometric liveness detection to prevent identity spoofing. Before launching, platforms must undergo penetration testing and cybersecurity audits certified by the National Agency for Cybersecurity (ANSI), with mandatory re-audits every two years or after any software patch. Severe technical glitches or cyber intrusions must be reported to regulators immediately.

Micro-Management?

Where the central bank truly asserts its authority is in corporate governance and physical oversight.

The circular requires payment platforms to institute Board-level Audit and Risk Committees alongside independent risk and compliance teams. The central bank has granted itself a 30-day veto power over all senior executive and board appointments, requiring firms to submit potential hires for regulatory clearance 7 days in advance. Free-market pricing has also been curtailed: platforms cannot adjust fee schedules or launch new features without submitting a cost-benefit analysis to the BCT for prior authorization. Discontinuing a service requires giving customers 30 days’ advance notice.

Physical distribution networks have not escaped the administrative tape measure. Any payment institution wishing to open a physical branch must ensure the premises measure at least 20 square meters, contain a safe, employ at least two full-time staff members, and feature a direct landline to the local police station. Closing or moving a branch requires 15 days’ notice to the BCT and 45 days’ notice to the public.

Agent networks are similarly restricted: “Principal Agents” can onboard higher-tier accounts and process cross-border payouts, while smaller “Retail Agents” are restricted to basic local payments. Overdrafts on agent float accounts are strictly forbidden.

The Paper Trail and Market Realities

To enforce compliance, the BCT has laid out an exhaustive reporting calendar:

Winners and Losers

The result is a classic regulatory paradox. In its zeal to eliminate financial instability and shadow banking, the central bank has crafted a compliance regime so demanding that it risks crushing the very innovation it claims to encourage.

Early-stage startups, lacking the capital to retain armies of compliance lawyers or fund annual ANSI audits, face an existential threat. Conversely, well-capitalized incumbents — such as telecommunications operators like Ooredoo, established commercial banks, and the state-owned postal service (La Poste Tunisienne) — are best positioned to absorb the regulatory overhead.

While Tunisia’s central bank has succeeded in building an ironclad fortress around its financial system, it may soon find that the only entities left inside are the legacy institutions it originally set out to modernize.