Tunisian Banking Sector – Regulatory Retrospective 2025

1. Introduction

Between prudential caution, accelerated digitalisation and strengthened compliance requirements, 2025 will have been above all a year of “execution”: the Central Bank of Tunisia (BCT) translated structuring projects (cheque reform, Basel/IFRS convergence, modernisation of foreign exchange, AML/CFT) into operational texts directly actionable by banks.

2. Financial stability

Two key messages prevail: preserving equity capital and strengthening risk management tools.

2024 Dividends: Prudent Framework. Circular No. 2025-02 sets conditions for distribution (ceiling, buffer requirements, prior approval as applicable) and reiterates a simple principle: distribution occurs if and only if solvency remains comfortably above minimum levels.
Risk Diversification/Hedging: Prudential Adjustments. Circular No. 2025-01 continues the strengthening initiated since 2020 (particularly regarding hedging/provisioning parameters).
Preparatory Measures for Prudential and Regulatory Reforms: Circular No. 2025-08 reads like an “alignment” document: it organizes the operational implementation (governance, data, methods) before more structural steps.
Crédit Agricole: Revision of Rates/Margins. Circular No. 2025-11 reconfigures parameters applicable to agricultural financing, with a direct impact on the supply, pricing, and monitoring of the portfolios concerned.

Concrete impacts for banks: dividend vs. buffer trade-offs, ICAAP/ILAAP robustness and stress tests, risk data quality, and consistency between methods and provisions.

3. Check reform

2025 marks a significant acceleration towards securing and ensuring the traceability of check payments.

Platform operating framework: Circular No. 2025-03 establishes the operational conditions for the Single Electronic Check Platform.
List of participating institutions: Circular No. 2025-04 publishes the list and specifies a principle of updating it at least semi-annually.
Electronic enrollment: Circular No. 2025-06 organizes the enrollment of stakeholders (processes, obligations, and procedures), which is essential for widespread deployment.
List update: Circular No. 2025-09 updates the list of participating institutions, following the announced semi-annual schedule.

Concrete impacts: IT/electronic payment system adaptation, front/back office procedures, access management, internal control mechanisms, and customer communication (acceptance conditions, deadlines, rejections, and traceability).
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4.Banking conditions

The Central Bank of Tunisia (BCT) intervenes in areas of customer concern.

Savings interest rate (TRE): Circular No. 2025-07 sets the TRE (with an effective date of April 1, 2025) and updates the body of banking conditions.
Financing of community companies: capped preferential rate. Circular No. 2025-14 imposes a cap on interest rates (TMM reference + maximum margin) for loans granted using equity, in line with changes to the legal framework for community companies (Decree-Law No. 2025-3).

Concrete impacts: pricing and compliance settings, updating of general terms and conditions, ALM/PNB governance (impact on margins), and compliance verification (ex-post controls).

5. Exchange, foreign trade and mobility

2025 combined two key levers: digitization and simplification.

Studies/internships abroad: Circular No. 2025-10 revises the limits and procedures, explicitly extending the program to academic internships.
Remote submission of foreign exchange authorization requests: Circular No. 2025-12 establishes remote submission/processing procedures, with a strong focus on customer experience and traceability.
Exports: payment terms and rules: Circular No. 2025-13 relaxes constraints to support competitiveness and streamline operations.

Concrete impacts: redesigned FX processes, document control, foreign exchange compliance, processing SLAs, reporting, and team training.
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6. Compliance & Control

AML/CFT/Asset Freezing/Proliferation: Circular No. 2025-17 replaces/updates the previous framework (reference to Circular 2017-08), with a “programming” effect on KYC, screening, monitoring, and compliance governance.
On-site inspections: formalization of resources: Circular No. 2025-15 sets out the specifications for the mission order and professional card of Central Bank of Tunisia (BCT) agents responsible for on-site inspections (addressing the issue of legal certainty and standardization of interventions).

Concrete impacts: recalibration of the AML/CFT framework (policies, scenarios, investigations, asset freezing), preparation for inspections, and traceability of supervisor/bank communications.

7. List of BCT Circulars

2025-01: Risk diversification/hedging & monitoring of commitments (prudential adjustments).
2025-02: Distribution of dividends for 2024.
2025-03: Operating conditions of the Single Electronic Checking Platform.
2025-04: List of institutions participating in TuniChèque + semi-annual update.
2025-06: Electronic enrollment on the platform (operational procedures).
2025-07: Regulation of banking conditions / setting of the TRE (Tunisian Exchange Rate).
2025-08: Preliminary measures for prudential and regulatory reforms.
2025-09: Update of the list of institutions participating in the checking platform.
2025-10: Transfers for tuition and academic internship expenses abroad.
2025-11: Revision of parameters applicable to agricultural credit.
2025-12: Remote filing/processing of authorization requests related to foreign exchange transactions.
2025-13: Relaxations related to exports (payment deadlines/rules).
2025-14: Capped preferential interest rate for loans to community companies (ref. decree-law 2025-3).
2025-15: Specifications for mission orders/cards of Central Bank of Tunisia (BCT) agents (on-site inspections).
2025-16: Operational rules related to the tourist allowance (Hajj 2026).
2025-17: Overhaul/update of the AML/CFT framework (and associated obligations).