The National Medical Council of Tunisia has reaffirmed its reservations regarding the implementation of e-invoicing regulations for medical professionals in their current form. The council emphasized that any updates to the tax system must be gradual, clear, and in line with the law, without compromising the specifics of the medical profession or professional secrecy. The council also stressed that the medical profession operates within a regulated sector subject to multiple mechanisms for declaration, control, and data crossover.
The council highlighted that e-invoicing cannot be applied to the medical profession without considering its specificities, particularly with regards to fee notes, professional secrecy, and the protection of patients' personal and medical data. In a statement published on their website, the council reiterated that professional secrecy is a fundamental obligation imposed on every doctor. The council also noted that since the issuance of the rulings related to the extension of e-invoicing to service provision, they have not considered the medical profession to be automatically concerned by this procedure.
This is due to the profession being subject to a special system for non-commercial professions based essentially on fee notes, as stipulated by law. The law on professional ethics also states that the practice of medicine should not be of a commercial nature. However, with the issuance of the general note number 02 of 2026, which explains the provisions of article 53 of the 2026 finance law and extends the scope of e-invoicing, the council considered that this note had exceeded its interpretive role and had broadened the text's interpretation.
This led to the inclusion of non-commercial professions, despite not being explicitly mentioned in the article. The council then initiated contact with the executive and legislative authorities, holding several meetings and consultations, and participated in the work related to reviewing the legislative framework. These efforts resulted in a proposal to amend the legal text, which the council is still awaiting completion. The council emphasized that the medical profession is subject to a specific regulatory framework that must be taken into account when implementing e-invoicing.
The council's statement highlights the need for a balanced approach that considers the specificities of the medical profession. The implementation of e-invoicing regulations must be done in a way that respects professional secrecy and the protection of patients' personal and medical data. The council's concerns are shared by many medical professionals who fear that the implementation of e-invoicing regulations could compromise the quality of medical care.
The National Medical Council's reservations regarding e-invoicing regulations have sparked a national debate on the future of the medical profession in Tunisia. The council's efforts to engage with the authorities and find a solution that works for all parties involved are ongoing. The outcome of these efforts will have a significant impact on the medical profession and the quality of healthcare in Tunisia.
The council's statement concludes by emphasizing the importance of finding a solution that balances the needs of the medical profession with the requirements of the tax system. The implementation of e-invoicing regulations must be done in a way that respects the specificities of the medical profession and ensures the quality of medical care. The council will continue to work with the authorities to find a solution that meets the needs of all parties involved.
Key points
- The National Medical Council of Tunisia reaffirms its concerns over e-invoicing regulations for medical professionals.
- The council emphasizes the need for a balanced approach that considers the specificities of the medical profession.
- The implementation of e-invoicing regulations must respect professional secrecy and the protection of patients' personal and medical data.
