The Financial Services Observatory (OSF) Warns of a “Pricing Drift” After the Non‑Renewal of Tunisia’s Central Bank Circular No. 2024‑3
Date: 23 February 2026
Background
The Financial Services Observatory (OSF) has publicly expressed deep concern and strong disapproval following the non‑renewal of the Central Bank of Tunisia (BCT) circular No. 2024‑3 dated 29 January 2024.
That circular introduced a minimum level of discipline and moderation in the setting of bank fees, a measure that was deemed essential in a context of:
- High inflation
- Eroding household purchasing power
- Weakening corporate cash‑flow
What Has Happened in 2025?
According to the OSF’s latest press release, the absence of the circular has led many Tunisian banks to raise fees and commissions dramatically during 2025.
Key observations:
| Fee/Commission | Change Reported |
|---|---|
| Account‑maintenance fees | Doubled or even tripled |
| Transaction commissions | Doubled or tripled |
| Credit‑related charges (including late‑payment penalties) | Doubled or tripled |
| Digital‑banking services (previously low‑cost) | Doubled or tripled |
Legal Breaches Highlighted by the OSF
The Observatory points out that several legal provisions have been ignored, notably:
- Advance client notification – Any change to a product’s characteristics, pricing, or remuneration must be communicated in writing at least 10 days before the change takes effect.
- Annual fee summary – By 31 January each year, banks must send clients a tax‑inclusive recap of all commissions and fees deducted during the previous year, again in writing.
- Variable‑interest‑rate disclosures – If a bank adopts a variable rate and the market rate moves ≥ 100 basis points, it must inform clients of the impact on principal and interest installments.
- Monthly statements – Deposit and current‑account holders must receive a written monthly statement that includes, at minimum, the details required by Annex I of Circular 2024‑2 (transaction breakdown, complaint‑handling contact, interest‑calculation methodology, etc.).
- Financing‑request timelines – Banks must respect the deadlines set by Circular 2024‑2 for evaluating loan applications.
- Guarantee release deadlines – Upon full repayment, banks must release real and personal guarantees within 30 working days.
Impact on Households and SMEs
“This pricing drift is an additional shock for individuals and SMEs already weakened by the economic climate. It raises the overall cost of financing, stifles investment, and fuels a sense of injustice in the bank‑client relationship. Moreover, the lack of information—as mandated by Circular 2024‑3—deepens the existing trust crisis,” – OSF statement.
- Higher financing costs → reduced business expansion and consumer spending.
- Opaque pricing → erosion of confidence in the banking sector.
- Unfair treatment → potential increase in financial exclusion.
OSF’s Recommendations
- Urgent reassessment by the BCT of the consequences stemming from the non‑renewal of Circular 2024‑3.
- Introduce a regulatory mechanism (e.g., caps or a supervisory framework) to limit bank fees.
- Reactivate the Financial Inclusion Observatory (under BCT supervision) to resume calculation and publication of the “Banking Services Price Index,” which has been dormant since 2017.
- Call on credit institutions to act responsibly and adopt a moderate pricing policy.
- Urge public authorities to launch a structural reform that establishes a sustainable, transparent, and equitable regulatory framework for banking tariffs.
Why Stability Depends on Consumer Protection
The OSF stresses that financial‑system stability cannot be separated from effective consumer protection. Trust in the banking sector rests on three pillars:
- Transparency – Clear, timely information on fees and product changes.
- Predictability – Stable, foreseeable pricing structures.
- Equity – Fair treatment of all clients, especially vulnerable households and SMEs.
Bottom Line
The non‑renewal of Circular 2024‑3 has triggered a significant and unjustified increase in banking fees across Tunisia, violating several legal obligations and jeopardizing both consumer confidence and economic growth. The OSF’s urgent appeal to the Central Bank and financial regulators aims to restore fairness, transparency, and stability in the Tunisian banking sector.
Keywords: Tunisia, Central Bank, BCT, banking fees, financial services observatory, OSF, consumer protection, inflation, SMEs, regulatory reform, price index, transparency.
