Jurisdictions › Tunisia

Tunisia

National jurisdiction

No compliant entry route; closed monopoly market with tightening criminalisation — do not enter.

2 open · 13 closed · 5 uncertain → 20 classes
Collected 25 Oct 2026 · Published 26 Oct 2026 · Changed 25 Oct 2026 PDF Sign in for PDF Compare

Can we offer our product?

Every product class, in fixed taxonomy order. The band is what you can do; where the recorded legal status says something the band does not, it is shown beside the product.

Player products

  • CasinoProhibited · Models agree
    Closed
  • PokerProhibited · Models agree
    Closed
  • BingoProhibited · Models agree
    Closed
  • LotteryState monopoly
    Closed
  • Sports bettingState monopoly
    Closed
  • Other event bettingProhibited · Models agree
    Closed
  • Horse and greyhound racing bettingGrey zone · Contested
    Uncertain
  • Esports bettingProhibited · Models agree
    Closed
  • Exchange bettingProhibited · Models agree
    Closed
  • Pool bettingProhibited · Contested
    Closed
    Varies by form · 1
    • Horse racing pool: grey_zone
  • Virtual event bettingProhibited · Models agree
    Closed
  • Fantasy sportsGrey zone · Models agree
    Uncertain
  • Skill gamesGrey zone · Models agree
    Uncertain
    Varies by form · 1
    • Pure skill: outside_perimeter
  • Prediction marketsGrey zone · Models agree
    Uncertain
  • SweepstakesGrey zone · Contested
    Uncertain
  • Free playOutside the regulatory perimeter · Models agree
    Open

Supply roles

  • Software / B2BProhibited
    Closed
  • Affiliate marketingProhibited
    Closed
  • Payments for gamblingModels agree
    Open

Settlement rail

  • Crypto gamblingProhibited
    Closed

Class-level certainty is graded for 15 of 20 classes.

Board briefing

Tunisia is a closed, monopoly-plus-tourist-casino jurisdiction with no private online route and a tightening reform direction.

What has changed

  • In December 2025 and January 2026 two restrictive draft laws emerged: a 23-MP bill to amend Décret-loi 74-20 and a Ministry of Youth & Sports revision. Both pursue suppression of offshore online gambling — mandatory ISP/PSP blocking, fines up to 500,000 TND and 1–5 year prison terms — rather than a licensing regime.

What to do now

  • Do not pursue B2C or B2B entry; no compliant pathway exists and criminal exposure is set to rise. Treat any Tunisian-facing offshore activity as high-risk for payment de-risking and prospective criminalisation. The only legal land-based route (tourist casino) is administratively closed in practice.

What to watch

  • Parliamentary progress of the January 2026 bill and Council of Ministers review of the Youth & Sports draft. Enactment would convert today's passive tolerance into active criminalisation and payment blocking.

11 answers, each dated and graded

The weather grades favourability for an operator, not legality: legality is the product table above. The left rule is our confidence: solid confirmed, dashed probable, dotted uncertain.

01 · What kind of market is this?

Overview

Unfavourable

The principal development for Tunisia is a draft 2027 Finance Bill provision, article 24 paragraph 3, that would raise the tax rate on online games and competitions conducted via communication or ICT means from 40 percent to 60 percent. The provision amends article 17 of Law n°48/2024 as previously …

Full analysis · 136 words

The principal development for Tunisia is a draft 2027 Finance Bill provision, article 24 paragraph 3, that would raise the tax rate on online games and competitions conducted via communication or ICT means from 40 percent to 60 percent. The provision amends article 17 of Law n°48/2024 as previously amended by the 2026 Finance Law, and is reported across multiple Tunisian outlets covering the national budget process, dated 15 and 16 October 2026. The bill has not been adopted by parliament and the provision's own Journal Officiel text was not directly retrieved. No other material development in licensing, enforcement, technical compliance, platform rules, commercial activity, or market structure was found in this window. A separate deputies' bill, 2026/009, which would criminalise all gambling including online gambling, remains before the General Legislation Committee with no dated progress.

  • No private online licensing route
  • Islamic social constraints on liberalisation (~2% moral-acceptability)
  • Forthcoming criminalisation/suppression bill
  • Merchant-category payment restriction
02 · Can we get a licence?

Licensing and regulation

Unfavourable

Decree-Law No. 74-20 of 24 October 1974, on fairground installations, parlour games and lotteries, approved by Law No. 96 of the same year, is the sole governing instrument and remains in force unchanged. It criminalises games of chance and lottery schemes generally, carving out only a narrow exempt…

Full analysis · 137 words

Decree-Law No. 74-20 of 24 October 1974, on fairground installations, parlour games and lotteries, approved by Law No. 96 of the same year, is the sole governing instrument and remains in force unchanged. It criminalises games of chance and lottery schemes generally, carving out only a narrow exemption for land-based casinos restricted to foreign tourists under a tightly controlled regime. No licensing framework exists for online betting or online casino. Draft law 09/2026, filed by twenty-three deputies on 19 January 2026 and referred to the Commission de la legislation generale on 29 January 2026, would redefine jeux de hasard to explicitly capture physical and digital chance-based financial gain, impose a default prohibition subject to narrow exceptions, and add a chapter criminalising electronic and digital money games. The bill has not been enacted and remains at committee stage.

03 · How hard is entry, really?

Market entry in practice

Unfavourable

There is no legal market-entry path for private gambling operators. The Promosport concession is not open to private bid, casino authorisations are rarely issued and tourist-only, and no liberalisation pathway is anticipated — the sole legislative motion is suppression-oriented.

04 · What do the licences cost?

Licence fees

Unfavourable

No fee regime applies to private operators because no private online licensing route exists. Casino authorisation and Promosport concession terms are set administratively and are not published.

05 · What is the tax take?

Tax

Unfavourable

No tax regime is open to private online operators. Reported fiscal touchpoints: standard VAT 19%; a 25% withholding on gambling winnings; and a 2021 finance-law flat 15% tax on the gross operating margin of betting/gambling/lottery organisers introduced as an anti-grey-market measure. Casinos and Pr…

Full analysis · 49 words

No tax regime is open to private online operators. Reported fiscal touchpoints: standard VAT 19%; a 25% withholding on gambling winnings; and a 2021 finance-law flat 15% tax on the gross operating margin of betting/gambling/lottery organisers introduced as an anti-grey-market measure. Casinos and Promosport are taxed as Tunisian companies.

06 · Can we move player money?

Payments and banking

Unfavourable

Gambling is a blacklisted/restricted merchant category for Tunisian acquirers, and onboarding gambling merchants typically results in immediate rejection. The BCT supervises banks and PSPs and enforces strict FX controls; foreign PSPs cannot operate directly without local licensing. A 2018 BCT state…

Full analysis · 56 words

Gambling is a blacklisted/restricted merchant category for Tunisian acquirers, and onboarding gambling merchants typically results in immediate rejection. The BCT supervises banks and PSPs and enforces strict FX controls; foreign PSPs cannot operate directly without local licensing. A 2018 BCT statement criminalises unauthorised virtual-currency activity. The 2026 bill would compel payment institutions to block gambling-linked transactions.

07 · Can we advertise?

Marketing

Unfavourable

Only Promosport and the licensed tourist casinos may legally market their products. All marketing of private or offshore gambling to Tunisian residents is prohibited, and Arabic-language affiliate/social marketing of offshore brands is illegal. The 2026 bill would extend penalties to advertisers and…

Full analysis · 43 words

Only Promosport and the licensed tourist casinos may legally market their products. All marketing of private or offshore gambling to Tunisian residents is prohibited, and Arabic-language affiliate/social marketing of offshore brands is illegal. The 2026 bill would extend penalties to advertisers and facilitators.

08 · What must the platform meet?

Technical compliance

Unfavourable

No technical compliance developments were evidenced this cycle for Tunisia; no RNG certification, server-location, or technical-standards framework specific to gambling was located in the record.

09 · Can we ship through apps and platforms?

Distribution and platforms

Unfavourable

No distribution- or platform-specific rules, such as app-store restrictions, ISP blocking, or affiliate-marketing platform rules, were evidenced this cycle for Tunisia.

10 · How hard does the regulator enforce?

Enforcement

Mixed

Enforcement in Tunisia has historically been described as suppression-oriented rather than systematically pursued, with rare action taken against individual users of offshore gambling sites. That posture is set to change materially if the draft law revising Decree-Law No. 74-20 is enacted: the bill …

Full analysis · 171 words

Enforcement in Tunisia has historically been described as suppression-oriented rather than systematically pursued, with rare action taken against individual users of offshore gambling sites. That posture is set to change materially if the draft law revising Decree-Law No. 74-20 is enacted: the bill proposes prison sentences of one to five years for the use and promotion of unlicensed digital gambling platforms, a substantial escalation from the status quo. This is, at present, a Probable-confidence, pre-enactment proposal; the interpreter assigns it a fragile durability tag appropriate to draft legislation rather than an enacted statute, and no primary Journal Officiel or Assembly-record text was located this cycle to independently corroborate the bill's precise wording, leaving corroboration resting on secondary press and commentary. Read against the civil-law pattern in which unlicensed operation is typically an offence under the gambling statute itself rather than a secondary licence-breach theory, the proposed penalty would bring Tunisia's enforcement architecture into closer alignment with that regional model, converting what is currently an enforcement gap into an explicit criminal exposure.

ProbableAI-generated5 enforcement eventsRead full analysis & tables →
11 · What is coming?

Outlook

Unfavourable

The reform trajectory is tightening, not liberalising. A January 2026 draft (23 MPs) and a parallel Ministry of Youth & Sports revision (December 2025) both aim to suppress offshore online gambling and align with AML/integrity standards rather than open a licensing regime. No politically viable path…

Full analysis · 60 words

The reform trajectory is tightening, not liberalising. A January 2026 draft (23 MPs) and a parallel Ministry of Youth & Sports revision (December 2025) both aim to suppress offshore online gambling and align with AML/integrity standards rather than open a licensing regime. No politically viable path to private-operator liberalisation exists given Islamic social constraints; the only legislative motion is restrictive.

Evidential record & source register 2 enforcement · 25 red flags · 12 sources · Expand full record

Enforcement record

What the regulator has actually done, newest first. 2 recorded events.

  1. 19 Jan 2026
    23 MPs / ARP · Unlicensed online gambling (proposed)
    Confirmed
    Sources
  2. 11 Dec 2025
    Ministry of Youth and Sports · Sports-betting sector (reform)
    Confirmed
    Sources

What gets operators fined

25 red flags (10 high, 9 medium, 3 low) and 0 controls that address them.

  • high
    No B2B supplier authorisation pathway
    Suppliers cannot serve the market except via the Promosport contract holder
    Sources
  • high
    Gambling blacklisted merchant category
    PSP onboarding routinely rejected; payment flows fragile
    Sources
  • high
    Strict BCT FX controls
    Cross-border settlement of gambling flows constrained
    Sources
  • high
    2018 BCT crypto criminalisation
    Crypto cannot be used as a compliant funding rail
    Sources
  • high
    All private gambling marketing banned
    No legal acquisition channel for residents
    Sources
  • high
    Affiliate liability proposed under 2026 bill
    Affiliates exposed to criminal facilitation
    Sources
  • high
    Reform direction is tightening
    No liberalisation prospect; suppression risk rising
    Sources
  • high
    Proposed mandatory ISP blocking
    Offshore access would be degraded if enacted
    Sources
  • high
    Proposed mandatory PSP transaction blocking
    Payment channels would be cut for offshore operators
    Sources
  • high
    No retrievable Tier-1 primary statute text
    Material legal-certainty gap; advice must be locally verified
    Sources
  • medium
    Casino access barred to nationals
    Land-based addressable base limited to tourists
    Sources
  • medium
    Poker prohibited (no carve-out)
    No legal poker route online or land-based
    Sources
  • medium
    ~2% moral-acceptability of gambling
    Deep social/political resistance to liberalisation
    Sources
  • medium
    App stores restrict gambling apps for TN
    No compliant mobile distribution
    Sources
  • medium
    25% winnings withholding + 15% margin tax
    Heavy fiscal load even within the monopoly
    Sources
  • medium
    Promosport civil litigation against offshore operators
    Active private-enforcement risk in addition to state action
    Sources
  • medium
    Crypto-gambling prohibited
    No crypto wagering route
    Sources
  • medium
    Casino authorisations rarely issued
    Even the one legal land-based route is practically closed
    Sources
  • medium
    Foreign-group dependency for Promosport tech (Sisal/Flutter)
    Single-supplier concentration; entry only via that contract
    Sources
  • low
    Bingo not addressed in statute
    Treated as illegal by default
    Sources
  • low
    Cross-border data transfer authorisation (Law 2004-63)
    Adds compliance overhead for any data processing
    Sources
  • low
    Fantasy/esports betting prohibited by default
    Emerging verticals foreclosed
    Sources
  • critical
    No private online licensing route exists
    No compliant market entry for B2C operators
    Sources
  • critical
    2026 bill proposes 1–5 yr prison + 500,000 TND fines
    Criminal exposure for operators, advertisers and facilitators if enacted
    Sources
  • critical
    Promosport exclusivity in betting & lottery
    No competitive entry in betting/lottery
    Sources

Worked scenarios

5 entry scenarios, each with the move we would make.

EU-licensed sportsbook wishes to acquire Tunisian residents online.

No private online licence exists; activity is prohibited and slated for criminalisation under the 2026 bill, with payment de-risking already in effect.

Do this: Do not target Tunisian residents; geofence the market.

Sources

Game studio wishes to supply RGS content B2B into Tunisia.

No B2B authorisation class exists; supply is only feasible via the Promosport operating-contract holder (Sisal/Flutter).

Do this: Approach only through the Promosport contract holder; no standalone B2B route.

Sources

Affiliate runs Arabic-language tipster pages promoting offshore books.

Marketing of private gambling to residents is banned; the 2026 bill extends penalties to advertisers/facilitators.

Do this: Cease Tunisia-targeted promotion; criminal exposure rising.

Sources

PSP asked to onboard a gambling merchant for Tunisian flows.

Gambling is a blacklisted merchant category; onboarding is routinely rejected and BCT FX controls bind.

Do this: Decline onboarding; high facilitation and de-risking exposure.

Sources

Investor evaluates acquiring a tourist casino licence.

Authorisation under Loi 74-21 is by rare joint ministerial order; nationals barred; foreign-currency play only.

Do this: Feasible only with existing authorisation; greenfield licence practically unavailable.

Sources

What we looked for and could not find

Confirmed absence is a finding of its own. These are the questions we searched and could not answer from a citable source, with the searches we ran. Never behind the paywall.

Market opportunity. no credible published GGR or market-size figure for Tunisian gambling located; ggr_estimate set null.
  • searched: Tunisia gambling market size GGR
  • searched: Promosport revenue Tunisia annual
  • searched: Tunisia betting market value 2025
  • checked: focusgn.com
Competitive landscape. no published licensed-operator count or unlicensed market-share percentage; monopoly structure noted but figures absent.
  • searched: Tunisia licensed gambling operators count
  • searched: Tunisia offshore gambling market share
  • searched: Promosport market share Tunisia
  • checked: lcb.org
Aml cft regime. no MONEYVAL/FATF MER citation, statutory article references or reporting threshold for gambling retrievable; T1 primary text unavailable.
  • searched: Tunisia FATF MENAFATF MER gambling
  • searched: Tunisia AML law CTAF gambling reporting threshold
  • searched: Tunisia AML primary legislation article
  • checked: payatlas.com
No Tier-1 primary source (official statute text or regulator portal) retrievable; Tunisia lacks a consolidated public legislative database. Confidence ceilings capped at Probable.
  • searched: Décret-loi 74-20 texte officiel JORT
  • searched: Promosport official site statute
  • searched: Tunisia Ministry of Finance gambling regulation portal
  • checked: scribd.com

Source register

Every source on a four-step tier scale. A claim is never shown at a stronger tier than the source it cites.