E-Invoicing Compliance Audit in Tunisia: A Practical Guide

Electronic invoicing in Tunisia is no longer a future project: it is an operational reality for VAT-registered legal entities since July 1, 2024, and it will extend to all businesses in September 2026. As this generalization approaches, tax audits are intensifying and finance departments must have a firm grip on their compliance obligations.

This eighth and final episode of our series on electronic invoicing in Tunisia offers an exhaustive audit guide: what inspectors from the Direction Générale des Impôts (DGI — General Tax Authority) examine first, the most common non-compliance scenarios, and an operational checklist to prepare your company for any audit.

What DGI Tax Inspectors Look for During an Audit

A tax audit covering electronic invoicing is not limited to verifying that digital invoices exist. Inspectors conduct a structured analysis across several dimensions.

The integrity of the invoicing chain. Every invoice issued via the El Fatoora platform must have been validated by the DGI before transmission to the buyer. Inspectors will cross-reference your invoicing software's register with the platform's data to detect any invoice issued outside the legal circuit or modified after validation.

Completeness of mandatory fields. Tax registration number (matricule fiscal), VAT number, unique invoice identifier, issue date, precise description of goods or services, applicable VAT rate, amounts exclusive and inclusive of tax — every field is checked. The absence of a single mandatory field can lead to fiscal rejection of the invoice and the disallowance of the VAT deduction for your customer.

Consistency with tax declarations. The volume of invoices issued, declared revenue, and collected VAT amounts must form a coherent whole. Any significant discrepancy between El Fatoora data and the monthly VAT declaration will trigger in-depth questioning.

Traceability of credit notes and cancellations. Every cancelled invoice must be offset by a duly validated electronic credit note (avoir électronique). Undocumented cancellations or credit notes issued outside the platform are among the most frequently identified irregularities.

Archiving Obligations: What the Law Requires

Article 62 of the Code de l'IRPP et de l'IS (Personal Income Tax and Corporate Tax Code) imposes a minimum retention period for accounting documents of five years from the closing date of the fiscal year. For electronic invoicing, this obligation applies to validated XML files, El Fatoora platform acknowledgements, PDF copies delivered to customers, and transmission logs.

Archiving is not optional. A fiscal document not retained within the legal timeframe is considered non-existent during an audit. In practice, this means that if your software provider ceases operations, you must have an independent copy of all your invoices.

Archiving costs to be aware of. The El Fatoora platform offers an archiving service at the following rates: invoice processing and archiving at 0.190 TND per 50 KB (excl. VAT), and reproduction of PDF or XML copies at 0.250 TND per unit beyond the first 100 free copies per period. These costs must be factored into your annual administrative management budget.

Practical recommendation. Do not rely exclusively on the platform's archiving. Set up a local or cloud backup of all your XML files, timestamped and organized by fiscal year. An automated daily backup system with monthly file integrity verification is the minimum acceptable practice.

Common Non-Compliance Scenarios and How to Correct Them

1. Invoice issued outside the platform

Symptom: a Word or Excel invoice sent directly by email to a customer, without going through El Fatoora.

Correction: issue a substitute electronic invoice via the platform with the same transaction date, adding an explanatory note in the comments field. If VAT has already been declared on this basis, no adjustment is required on the declaration, but the original paper invoice must be retained as a supporting document.

2. Purchase order used as an invoice

Some companies transmit purchase orders or pro-forma documents as final invoicing documents. These documents have no fiscal value. The final electronic invoice must always be issued after delivery or completion of the service.

3. Non-electronic credit notes

A paper or simple PDF credit note is not recognized for tax purposes. Every credit note (avoir) must reference the original invoice number and be validated on the El Fatoora platform. Credit notes issued retroactively for prior fiscal years receive particular scrutiny during audits.

4. Foreign-currency invoices without the exchange rate

For exported services or transactions with foreign partners, the invoice must show the foreign currency amount AND the Tunisian dinar equivalent, using the Banque Centrale de Tunisie (BCT) exchange rate on the issue date. Omitting this dual disclosure is a frequent non-compliance issue for export-oriented companies.

Self-Audit Checklist: 14 Points to Verify Before an Audit

Use this checklist before each quarterly close or ahead of any tax inspector visit.

Technical configuration

• Your company's electronic certificate is valid and its expiry is monitored (alert at D-30)
• Your invoicing software is updated to the latest version certified as El Fatoora compatible
• The contingency procedure in case of platform downtime is documented and tested

Invoicing flows

• All sales invoices to VAT-registered companies go through the El Fatoora platform
• No invoice is modified after validation; corrections are made exclusively via electronic credit notes
• Credit notes systematically reference the original invoice number
• Foreign-currency invoices include the BCT exchange rate and the TND equivalent amount

Archiving

• XML files for all invoices from the past five years are archived and accessible
• El Fatoora platform acknowledgements are retained alongside each invoice
• An independent backup (outside the platform) exists and is tested quarterly

Accounting consistency

• Revenue from El Fatoora invoices matches the VAT declaration for the same month
• Purchase invoices received via the platform are reconciled with your accounts payable
• Inter-company invoices within the same group are treated like any other taxable invoice
• Staff responsible for invoicing have received formal training on El Fatoora obligations

Credit Note and Electronic Correction Management

The electronic credit note (avoir électronique) is the only legally recognized mechanism for correcting or cancelling a validated invoice. It follows exactly the same procedure as a regular invoice: creation in your software, transmission to the platform, DGI validation, then transmission to the customer.

Practical case: an amount error discovered after validation. Suppose an invoice for 5,000 TND (excl. VAT) was issued when the correct amount is 4,500 TND (excl. VAT). You cannot modify the original invoice. The procedure is: issue a credit note for 500 TND (excl. VAT) referencing the original invoice, then, if you wish to maintain the transaction, issue a new invoice for 4,500 TND (excl. VAT). The customer thus receives three documents: the original invoice, the credit note, and the replacement invoice.

Partial credit notes. In the case of a partial goods return or a commercial discount granted after invoicing, a partial credit note is permitted. It must precisely identify the affected lines from the original invoice.

Prescription period. A credit note can only be issued within the fiscal prescription period. Beyond four years from the date of the original invoice, accounting correction is handled differently, under the guidance of your chartered accountant (expert-comptable).

Cross-Border and Multi-Currency Invoicing

Tunisian companies exporting services (software development, consulting, design, engineering) regularly invoice foreign customers in euros or dollars. These invoices are subject to specific rules.

Service exports are exempt from Tunisian VAT (TVA), provided the export justifications are produced (contract, foreign currency transfer received, bank account statement). The invoice must explicitly state the legal basis for the exemption.

The El Fatoora platform and foreign customers. An invoice issued to a non-resident customer is not subject to the El Fatoora validation circuit under the same conditions as a domestic B2B invoice. However, it must be properly accounted for and archived. Check with your chartered accountant for the exact modalities applicable to your sector.

The reference exchange rate. Always use the BCT selling rate on the invoice issue date. Keep a log of the rates applied, as the exchange differences generated at the time of actual payment will need to be accounted for separately.

Emergency Procedures: Platform Downtime and Certificate Expiry

Two technical situations can bring your invoicing to a halt. It is essential to have a documented procedure for each.

El Fatoora platform downtime. In the event of confirmed platform unavailability (verifiable on the DGI portal), invoices may be issued in degraded mode and transmitted as soon as the platform is back online, within a maximum of 24 hours. Retain a screenshot of the official incident notification. Inform your customers of this delay as soon as possible to avoid payment blockages.

Electronic certificate expiry. This is the most avoidable emergency and yet one of the most frequent. The certificate expires on a specific, known date. Set up an automated alert at D-60 and D-30. Renewal from the Agence Nationale de Certification Électronique (ANCE — National Electronic Certification Agency) takes between 3 and 10 business days. During this period, you cannot issue valid electronic invoices.

Renewal procedure. Initiate renewal no later than 30 days before expiry. Verify that your invoicing software accepts the new certificate upon installation. Perform a blank test invoice before resuming production.

Migrating from Paper to Electronic: Strategy for Companies Not Yet Obligated

The September 2026 generalization will cover self-employed individuals and small businesses currently outside the mandatory scope. If your company has not yet begun this transition, here is a methodical approach.

Phase 1 – Existing process audit (months 1-2). Map all your invoicing flows: customers, suppliers, transaction types, monthly volumes, currencies. Identify special cases: recurring subscriptions, intra-group invoices, B2C transactions (with private individuals).

Phase 2 – Solution selection (months 2-3). Evaluate software certified as El Fatoora compatible. Verify integration with your current accounting system. Negotiate a contract that includes user training and technical support in Arabic and French.

Phase 3 – Pilot and training (months 3-5). Start with a subset of willing customers or suppliers. Train all staff involved. Document internal procedures specific to your business activity.

Phase 4 – Full internal rollout (months 5-8). Switch all flows over. Maintain paper invoicing in parallel only for legally excluded customers (private individuals, transactions below legal thresholds).

Phase 5 – Pre-certification self-audit (months 8-9). Conduct your first self-audit using the checklist above before the official September 2026 switchover.

The Generalization Timeline: September 2026

The 2024 Finance Law and successive implementing decrees establish a clear schedule:

• July 1, 2024: Obligation for VAT-registered legal entities (already in force)
• September 2026: Extension to self-employed individuals under the real tax regime and companies not yet covered

This generalization will affect several hundred thousand additional businesses. Certified solution providers are anticipating strong demand in the first half of 2026: do not delay in selecting your solution.

Companies that begin their migration now will benefit from a significant operational advantage: their teams will be trained, their processes will be refined, and they will not be affected by the provider congestion that will inevitably occur as the deadline approaches.

Summary: The Five Pillars of Lasting Compliance

1. Technical rigor. Your electronic certificate is valid, your software is up to date, and your platform connections are tested regularly.

2. Ongoing training. Every staff member who handles invoicing knows the rules, the special cases, and the emergency procedures.

3. Robust archiving. Five years of invoices are accessible within an hour, on at least two separate media.

4. Regular reconciliation. El Fatoora data is reconciled with accounting records and tax declarations every month, not at year-end.

5. Quarterly self-audit. The checklist above is executed without exception before every quarterly close.

Conclusion: Compliance as a Competitive Advantage

A company fully compliant with its electronic invoicing obligations does more than avoid penalties. It has impeccable financial traceability that strengthens its credibility with banks, investors, and enterprise customers. It reduces its administrative processing costs. And it is ready — without stress — for the September 2026 generalization.

Electronic invoicing is not just another regulatory constraint: it is the digital infrastructure on which the trust relationship between your company, your business partners, and the tax authority is built.

This article is the eighth and final episode of our series on electronic invoicing in Tunisia. To start from the beginning, see our first episode: Introduction to El Fatoora. To access all our practical resources on electronic invoicing, visit our dedicated resource center.