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Tunisia
TNschema crypto-v2.0.0trajectory: not yet assessedprohibitedoverlaps: FIM, WPM
Last updated · 8 categories · 10 sourced
findings · 14 sources in the cumulative register
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Jurisdiction lead brief
Lead Signal
Tunisia's crypto regulatory posture is undergoing its first genuine legislative test since the 2018 criminal ban on unauthorised trading, exchange services, and crypto-payment acceptance. Proposition de loi n°2025/115, the draft Code des Changes, would establish a declare-and-hold framework for virtual and digital assets under rules to be set by the Banque Centrale de Tunisie, a structural departure from the current prohibition regime. The bill remains at consultation stage as of mid-2026 and is not yet enacted, so Tunisia's operative law today remains the 2018 ban, carrying penalties of up to five years' imprisonment for unauthorised trading, exchange, or payment-acceptance activity.
Other Developments
Cross-border declaration and repatriation duties. Article 74 of the same draft law would impose custodial penalties of one month to three years and fines of three to five times the infraction value for failure to declare digital-asset holdings or repatriate related revenue. This sits alongside an estimated four hundred million dollars or more in informal crypto-based remittance flows into and via Tunisia each year, conducted through peer-to-peer platforms outside any formal reporting regime, a scale of flow the draft provisions would newly bring within statutory scope if enacted.
Cross-Monitor Connections
The AML/CTF dimension of Tunisia's crypto framework is tracked under this monitor's subscribed slot, supplied by the financial-integrity consumer's D7 and D5 coverage, rather than analysed independently here. Readers seeking the anti-money-laundering reading of the same Code des Changes reform should refer to that coverage rather than this brief's licensing- and transfer-focused treatment.
Outlook
The draft Code des Changes is projected toward a 2026-Q3 framework decision point, with a further multi-year horizon toward pilot exchanges in 2027 and fuller retail access by 2028 under a conditional-licensing and on-shore-KYC model reported separately. Confirmation of the bill's progress through the Assembly of the Representatives of the People, and any indication of its actual enactment date, are the developments most likely to move Tunisia's jurisdiction_status classification away from prohibited.
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Tunisia has no crypto-specific licensing statute. The Central Bank of Tunisia (BCT) supervises all foreign-exchange and cross-border monetary flows under the 1976 exchange-control code, and unauthorised crypto-asset transactions (purchase, sale, exchange conversion) fall outside any BCT-authorised channel, making them treated as unauthorised/prohibited in practice. A draft crypto-regulation bill has circulated in the Assembly of the Representatives of the People but is not enacted law.
Standing sub-brief180 words · last cycle 2026-08-21
Crypto Licensing
Tunisia's crypto-licensing posture remains one of outright criminal prohibition as of this cycle. Since a 2018 Banque Centrale de Tunisie directive, trading, exchange services, and acceptance of crypto as payment without state authorisation have been criminalised, carrying penalties of up to five years' imprisonment. This standing prohibition is not new, but it now sits alongside a genuinely new development: proposition de loi n°2025/115, the draft Code des Changes, would establish a declare-and-hold framework for virtual and digital assets under a strict BCT-defined regime, a fundamental structural departure from the 2018 ban. The draft is at parliamentary consultation stage as of mid-2026 and is not yet enacted.
Outlook
Confirmation of the draft bill's progress through the Assembly of the Representatives of the People, and any signal of an actual enactment timeline, are the developments most likely to move this module's red traffic-light assessment. A projected 2026 framework decision, 2027 pilot exchanges, and 2028 full retail access have been reported as a target sequence, though these dates carry Assessed rather than High confidence and rest on a single tier-four source.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (2)
T1 · Banque Centrale de Tunisie (BCT)Banque Centrale de Tunisie (BCT) — Cryptocurrency transactions are not licensed or authorised in Tunisia; the BCT applies the general exchange-control code to treat unauthorised crypto-asset dealings by residents as falling outside permitted foreign-exchange operations.retrieved M5bindingin force
T4 · CoinDeskCoinDesk — A draft law intended to establish a legal framework for cryptocurrency has circulated in the Tunisian parliament following 2021 statements by the then-Finance Minister, but no comprehensive crypto-licensing regime has been enacted as of the most recently verifiable status.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
Tunisia has no statute classifying crypto-assets into security-token, e-money-token, asset-referenced-token, stablecoin, utility-token, or NFT categories. The BCT's published legal-framework inventory (banking law, exchange regulation, circulars) contains no reference to token taxonomy.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (1)
T1 · Banque Centrale de Tunisie (BCT)Banque Centrale de Tunisie (BCT) — No statutory taxonomy exists in Tunisia distinguishing security tokens, e-money tokens, asset-referenced tokens, stablecoins, utility tokens, or NFTs; the BCT's published inventory of banking and exchange-control legal instruments contains no token-classification framework.retrieved M4bindingin forcea fact about the regime
No BCT or other Tunisian supervisory instrument addresses staking, DeFi lending, DEX operation, mining, node operation, validator activity, or tokenization. These activities are neither licensed, exempted, nor explicitly prohibited by name; they sit outside the perimeter of the exchange-control code except to the extent any associated cross-border currency flow would itself trigger the general prohibition.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (1)
T1 · Banque Centrale de Tunisie (BCT)Banque Centrale de Tunisie (BCT) — On-chain activities such as mining, staking, DeFi lending, DEX operation, node operation and validating have no dedicated legal or regulatory status in Tunisia and are not addressed by any BCT circular or law.retrieved M3non-bindinga fact about the regime
No Tunisian law authorises, licenses, or sets reserve/redemption/disclosure standards for stablecoins, e-money tokens, or asset-referenced tokens. Issuance of a stablecoin referencing the dinar or foreign currency would implicate the exchange-control code's restrictions on foreign-currency-denominated instruments and BCT's exclusive currency-issuance mandate.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (1)
T1 · Banque Centrale de Tunisie (BCT)Banque Centrale de Tunisie (BCT) — No legal framework in Tunisia authorises issuance of stablecoins, asset-referenced tokens, or e-money tokens; such issuance would fall under the general prohibition on unauthorised foreign-exchange dealings under the 1976 exchange-control code.retrieved M4bindingin force
No crypto-specific consumer-protection obligations (marketing restriction, custody segregation, complaint handling, suitability) exist in Tunisian law. General consumer-protection and banking-supervision statutes do not extend explicitly to crypto-asset service providers, as BCT's banking supervision mandate under Loi n°2016-48 covers banks and financial institutions, not unlicensed crypto platforms.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (1)
T1 · Banque Centrale de Tunisie (BCT)Banque Centrale de Tunisie (BCT) — Tunisia has no crypto-specific consumer-protection rules covering marketing restrictions, custody segregation, complaint handling, or suitability assessments for crypto-asset users.retrieved M3non-bindinga fact about the regime
No dedicated Tunisian tax code provisions addressing capital gains, income tax, VAT/GST, withholding, or reporting obligations specific to crypto-asset transactions were identified in available sources. This is a genuine research gap requiring escalation to primary tax-code sources (Code de l'IRPP et de l'IS, Code de la TVA) rather than a confirmed exemption.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (1)
T1 · Banque Centrale de Tunisie (BCT)Banque Centrale de Tunisie (BCT) — No specific guidance from Tunisian tax authorities on the tax treatment (capital gains, income tax, VAT, withholding, or reporting) of crypto-asset transactions was located in this research pass.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
Cross-border transfers of value connected to crypto-asset transactions are captured by Tunisia's general capital and current-account exchange controls, which require BCT authorisation for most capital-account operations and impose declaration duties on foreign-currency asset holdings. Because crypto transactions are treated as unauthorised, any associated outward transfer of funds to acquire or liquidate crypto-assets would itself constitute a breach of exchange-control provisions absent BCT authorisation.
Standing sub-brief176 words · last cycle 2026-08-21
Cross-Border Transfer
Cross-border movement of digital assets is the dimension of Tunisia's crypto framework seeing the most active legislative movement this cycle. Article 74 of the draft Code des Changes would impose custodial penalties of one month to three years, together with fines of three to five times the value of the infraction, for failure to declare digital-asset holdings or to repatriate related revenue. Separately, informal crypto-based remittance flows into and via Tunisia are estimated to exceed four hundred million dollars annually, conducted through peer-to-peer platforms outside any formal reporting regime. If enacted, the draft law's declaration and repatriation provisions would bring that scale of informal flow within a formal statutory scope for the first time.
Outlook
This module is assessed amber rather than red because it shows active legislative movement toward a specific, drafted mechanism, even though that mechanism remains pre-enactment. The current legislative status of the bill as of August 2026, specifically whether it has passed the pre-summer-2026 vote target referenced elsewhere in this cycle's record, is unconfirmed and is the key open question.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (2)
T1 · Banque Centrale de Tunisie (BCT)Banque Centrale de Tunisie (BCT) — Outward transfers of funds for the purpose of acquiring or liquidating crypto-assets are subject to Tunisia's general exchange-control authorisation requirements; unauthorised transfers are prohibited under the 1976 exchange and foreign-trade code.retrieved M5bindingin force
T1 · Banque Centrale de Tunisie (BCT)Banque Centrale de Tunisie (BCT) — Residents holding assets abroad, including potentially crypto-assets held on foreign platforms, are subject to declaration obligations under Articles 16-18 of the exchange-control code, though no crypto-specific reporting threshold has been established.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
This module is subscribed from the Financial Integrity Module (FIM) aml_ctf baseline per fleet doctrine; no aml_cft_regime claims are produced in this crypto DR baseline. Disambiguation context only: the FATF's 2025 Targeted Update on VA/VASP implementation notes continuing global gaps in licensing/registration and Travel Rule adoption, relevant context for Tunisia's unassessed VASP AML posture.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (1)
T2 · Financial Action Task Force (FATF)Financial Action Task Force (FATF) — AML/CFT treatment of virtual assets and VASPs for Tunisia is out of scope for this crypto DR baseline and is instead carried under the Financial Integrity Module (FIM) aml_ctf subscription.retrieved M1non-bindinga fact about the regime
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pass
tier_a_b_national_primary_pct
85.71
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0
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Editorial metadata for Tunisia
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