The National Council of the Order of Physicians (CNOM) in Tunisia has expressed its reservations regarding the implementation of e-invoicing in the medical profession in its current form. The council emphasized that any modernization of the fiscal system must be progressive, clear, and in line with the law, without compromising the specifics of the medical profession, professional secrecy, or patients' rights. This stance was communicated through a recent statement on their official website.
The CNOM highlighted that the medical profession operates within a highly regulated sector subject to multiple declaration and control mechanisms. Therefore, e-invoicing cannot be applied to the medical profession without considering its unique aspects, particularly concerning fee notes, professional secrecy, and the protection of patients' personal and medical data. The council underscored that professional secrecy is a fundamental obligation for all physicians.
According to the CNOM, the medical profession was not automatically considered to be covered by the extension of e-invoicing to service provisions. This is because the medical profession is subject to a specific regime for non-commercial professions, primarily based on fee notes. The medical deontology code stipulates that the practice of medicine should not take on a commercial character. This distinction has been a point of contention with the recent publication of the general note n° 02 of 2026.
The general note n° 02 of 2026, which explains the provisions of article 53 of the 2026 finance law and the expansion of e-invoicing, has altered the situation. The CNOM believes that this note has overstepped its interpretive role and expanded the interpretation of the text to subject non-commercial professions to e-invoicing, even though they are not explicitly mentioned in the article. This has prompted the council to take initiative and engage with executive and legislative powers.
Following the publication of the note, the CNOM has held numerous meetings and consultations, and participated in the revision of the legislative framework. These efforts have led to the proposal of an amendment to the legal text, which the council is awaiting. The CNOM's engagement reflects its commitment to finding a solution that respects the medical profession's unique characteristics while complying with legal requirements.
The CNOM's reservations about e-invoicing for the medical profession center on the need for a legislative modification and the establishment of necessary legal and technical guarantees. Until these conditions are met, the council remains cautious about the implementation of e-invoicing in its current form. This cautious approach aims to protect the integrity of the medical profession and the rights of patients.
The situation highlights the complexities of implementing e-invoicing across different professions in Tunisia. The CNOM's proactive engagement with authorities and its insistence on a tailored approach for the medical profession underscore the need for a nuanced understanding of various sectors' specificities. As the council awaits the outcome of its proposed amendments, the medical community and other stakeholders will be watching closely for developments that could impact the profession.
Key points
- The National Council of the Order of Physicians in Tunisia has expressed reservations about implementing e-invoicing in the medical profession.
- The council emphasizes the need for a legislative modification and the establishment of legal and technical guarantees.
- E-invoicing implementation must consider the unique aspects of the medical profession, including professional secrecy and patients' rights.
