The National Council of the Tunisian Order of Doctors has reaffirmed its reservations regarding the implementation of e-invoicing in the medical profession in its current form. This stance comes until the legislative amendments are finalized and the necessary legal and technical guarantees are provided. The council emphasized that the update of the tax system should be gradual, clear, and in line with the law, without compromising the specifics of the medical profession, professional secrecy, or patients' rights.
The council highlighted that the medical profession operates within a regulated sector subject to multiple mechanisms for declaration, control, and data intersection. It stressed that e-invoicing cannot be applied to the medical profession without considering its specificities, particularly the fee schedule, professional secrecy, and the protection of patients' personal and medical data. According to the council, professional secrecy is a fundamental commitment imposed on every doctor.
The National Council of the Tunisian Order of Doctors noted that since the issuance of the rulings related to the extension of e-invoicing to the provision of services, it has not considered the medical profession automatically subject to this procedure. This is due to its regulation under a special system for non-commercial professions, primarily based on a fee schedule. The law on professional ethics stipulates that the practice of medicine should not have a commercial character.
However, with the issuance of the general memorandum number 02 of 2026, which explains the provisions of Article 53 of the 2026 Finance Law and expands the scope of e-invoicing, the council reassessed the situation. It argued that this memorandum exceeded its interpretive role and broadened the text's interpretation, leading to the inclusion of non-commercial professions, despite not being explicitly mentioned in the article.
Following this development, the council initiated contact with the executive and legislative authorities, holding several meetings and consultations. It participated in the review of the legislative framework, which led to a proposal for amending the legal text. The council is currently awaiting the completion of this process. The implementation of e-invoicing in the medical profession has sparked concerns regarding its potential impact on professional practices and patient care.
The council's reservations are centered on the potential consequences of e-invoicing on the medical profession's specifics, including professional secrecy and the protection of patients' data. It emphasized that any update to the tax system should take into account the unique aspects of the medical profession. The council's efforts aim to ensure that the implementation of e-invoicing does not compromise the quality of medical care or the professional standards of doctors.
The National Council of the Tunisian Order of Doctors continues to engage with the relevant authorities to address its concerns and ensure that the implementation of e-invoicing is adapted to the specificities of the medical profession. The council's objective is to find a solution that balances the need for a modernized tax system with the need to preserve the integrity of the medical profession and protect patients' rights.
Key points
- The National Council of the Tunisian Order of Doctors reaffirms its concerns over e-invoicing implementation in the medical profession.
- The council calls for a gradual and clear update of the tax system that takes into account the specifics of the medical profession.
- The implementation of e-invoicing should not compromise professional secrecy, patients' rights, or the quality of medical care.
