A process for fabricating a memory cell having two levels of polysilicon and being included in a memory device of the EEPROM type, wherein the device is formed on a semiconductor material substrate which has a first conductivity type. The process comprises the steps of forming, on the substrate a thin tunnel oxide region surrounded by a gate oxide region previously formed on the same substrate, depositing a layer of polycrystalline silicon over the gate oxide region and the thin tunnel oxide region, and successively depositing a composite ONO layer and an additional polysilicon layer over the polycrystalline silicon layer. A capacitive implant mask having a window is formed by depositing a layer of a light-sensitive material over the additional polysilicon layer, a dopant is implanted through the window at an energy and with dosages effective to penetrate the polycrystalline silicon, ONO, and polysilicon layers, respectively, and a region of electric continuity is formed laterally and beneath the thin tunnel oxide region.