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Morocco · ESG rulebook

ESG rules in Morocco: who must report what

Which ESG and sustainability rules apply to a company in Morocco is not obvious. Some bind banks and listed issuers, some are voluntary, and some reach Moroccan companies from European customers. This page lists each one with who it applies to, what it requires, the key dates, and the source we read, including what we did not read.

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Binding

A law or a regulator requires it, for the entities named.

Guidance or voluntary

A framework, label or direction of travel that is not a legal duty.

Reaches you from outside

Rules written elsewhere that reach Moroccan companies through customers, groups or lenders.

At a glance

Binding rules for specific entities

Two Moroccan regulators have set ESG disclosure rules, one for issuers that offer securities to the public and one for banks. Most other companies are not covered by either.

Binding

Annual ESG report for issuers: AMMC Circular 03/19

Who it applies to

Legal entities and bodies that make a public offering of savings (appel public à l’épargne), under Law 44-12 (Article 4): while their shares are listed or held by a number of shareholders set by the administration, and throughout the life of their debt securities. This covers listed companies and issuers of publicly offered debt securities. Alternative-market issuers have lighter requirements, set out below. Ask the AMMC whether your instruments are in scope.

What it says

  • Legal basis: Law 44-12 requires every such entity to publish an annual financial report (Article 10) and lets the regulator fix its content, deadlines and form (Article 13). The circular uses that power to include the ESG report. In the articles we read, the law itself does not mention ESG reporting.
  • Every issuer must publish an annual financial report on its website within 4 months of the year end, and alternative-market issuers within 5 months (Article 2.9). Among its required contents, item (g) is the “ESG report”.
  • Article 2.58: the annual financial report must contain an “Environment, Social and Governance” report. It is meant to inform the public about the issuer’s impact on the environment, its relations with employees and external stakeholders, and its governance.
  • Article 2.59: the ESG report must contain the general and specific information set out in Annex III.2.M. An issuer that cannot produce one or more of those items must explain the reasons (comply or explain).
  • Annex III.2.M says the report should be based on a recognised international ESG reporting framework. General elements, at minimum: the issuer’s profile and its social and environmental responsibility strategy; the reporting perimeter; a materiality analysis; a methodological note on how data is identified, collected and compiled; the external verifier’s attestation, where there is one; and explanations for any part of the framework not adopted.
  • Specific elements: environmental information (activities with an impact, environmental policy, litigation, waste, and water, energy and raw material consumption); social information (HR policy, headcount over three years with breakdowns, training, gender equality, and indicators such as accidents, dismissals and disputes); governance (board composition and independence, appointment dates, committees, attendance, remuneration, relations with shareholders, ethics and anti-corruption); information on stakeholders (local impact, dialogue, supplier and partner selection criteria); and the issuer’s CSR objectives and achievements over three years, tied to its business strategy.
  • Alternative-market issuers need include only the items marked with an asterisk in the annex, which are the issuer profile, the reporting perimeter and most governance items. Article 2.9 describes this as the governance information.

Key dates

  • 28 December 2012: Law 44-12 promulgated by Dahir no. 1-12-55, published in Bulletin officiel no. 6124 of 7 February 2013.
  • 20 February 2019: Circular 03/19, published in Bulletin officiel no. 6784 bis of 7 June 2019.
  • 22 December 2020: Circular 02/20 amends it (Bulletin officiel no. 7055 of 10 January 2022).
  • 2020: the ESG reporting obligation takes effect (AMMC Annual Report 2020).
  • Each year: the annual financial report, with its ESG report, within 4 months of the year end (5 months for alternative-market issuers).

How we checked it

Read: Articles 2.9, 2.58 and 2.59 and Annex III.2.M of Circular 03/19 as printed in the Bulletin officiel (scanned pages 1335 and 1336, 1344 and 1345, and 1452 to 1454), the AMMC Annual Report 2020, and the heading of Annex III.2.M in the Official Gazette text of Circular 02/20. Not read: the amended Annex III.2.M that Circular 02/20 introduced (its text is in Arabic and could not be read reliably), so check the current annex with the AMMC. Law 44-12: Articles 1 to 15 read from a scanned PDF supplied to us (Bulletin officiel no. 6124, pages 1234 to 1236); its remaining pages were not read.

Sources

Related on this site

Binding

Climate disclosure for banks: Bank Al-Maghrib Directive 1/W/2025

Who it applies to

Banks, and their subsidiaries and controlled entities, including those abroad, without prejudice to the rules of the host country (Article 1).

What it says

  • The directive sets the reference for how banks communicate climate-related financial risks. It cites international principles, among them the IFRS sustainability standards, and refers to Bank Al-Maghrib’s Directive 5/W/21 on managing climate and environmental financial risks.
  • It has four areas of disclosure. Governance (Articles 3 to 5): who oversees climate risks and opportunities, their competences, and how this feeds strategy, credit decisions and remuneration. Strategy (Articles 6 to 11): the short-, medium- and long-term risks and opportunities, the sites and asset types most exposed, the transition plan, the effect on financial position and cash flows, and resilience under climate scenarios. Climate risk management (Article 12): how risks are identified, assessed, prioritised and monitored, and how that fits the overall risk framework. Indicators and targets (Articles 13 to 15).
  • Indicators (Article 14): absolute gross Scope 1, 2 and 3 emissions in tonnes of CO2 equivalent following the GHG Protocol, with the approach used, the split between the consolidated group and subsidiaries, the Scope 3 categories and the financed emissions, meaning the gross emissions of the counterparties to which the bank has granted financing; the amount and share of assets vulnerable to physical and transition risks and of assets compatible with climate opportunities; the capital deployed; and whether and how an internal carbon price is used.
  • Targets (Article 15): the indicator, scope and time frame of each target, whether it is absolute or intensity-based, how it was set and reviewed and whether a third party validated the method, progress against it, and how carbon credits would be used.
  • The information must be clear, complete, reliable and consistent from year to year (Article 16).

Key dates

  • 24 January 2025: signed in Rabat.
  • Article 18, counted from signature: 24 months for Scope 1 and 2, 36 months for Scope 3, 48 months for aligning subsidiaries. That gives 24 January 2027, 24 January 2028 and 24 January 2029 (our calculation).

How we checked it

Read: pages 1 to 8 of the signed original on bkam.ma, a scanned image, which cover Articles 1 to 18. Not read: page 9, the annex that lists the Scope 3 categories.

Sources

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Framework, guidance and direction of travel

These do not create a reporting duty for most companies, but they show where the rules are heading and what regulators and bodies expect.

Guidance or voluntary

Framework Law 99-12: National Charter for the Environment and Sustainable Development

Who it applies to

The State, local authorities, public bodies and state companies, private companies, civil society and citizens.

What it says

  • The law sets the State’s fundamental objectives on environmental protection and sustainable development, including integrating sustainable development into sectoral policies and adopting a national sustainable development strategy (Article 1).
  • Article 21: private companies, like public bodies and state companies, undertake to respect the principles and objectives of the law. To that end they are to adopt responsible methods of sourcing, operation, production and management; assess the impact of their activities on the environment periodically; reduce their negative effects to the strict minimum; spread sustainable development values by requiring respect for the environment from their partners, notably their suppliers; and communicate transparently on their environmental management.
  • Article 30 creates a system of environmental taxation made of ecological taxes and fees on activities with high pollution or consumption of natural resources, to be specified by later legislation. Article 31 creates an ecolabel system.
  • The law also provides for an environmental liability regime and an environmental control system. It is a framework law: detailed duties depend on implementing texts and sector rules, which this page does not yet cover.

Key dates

  • 6 March 2014: promulgated by Dahir no. 1-14-09; published in Bulletin officiel no. 6240 of 20 March 2014, pp. 2496 to 2500.

How we checked it

Read: the object of the law (Article 1) and Articles 21, 22, 30 and 31 of the text printed in Bulletin officiel no. 6240, from a scan whose text layer has recognition errors, and the UNEP legal database record. Not read: the other articles in detail, including the liability and control provisions, or any implementing text.

Sources

Guidance or voluntary

Direction of travel: the AMMC’s 2026 priorities and the National Climate Finance Strategy 2030

Who it applies to

Capital market participants, issuers and their auditors. Not a new obligation today.

What it says

  • The AMMC says it will keep contributing to the National Climate Finance Strategy 2030, prepared with the Ministry of Economy and Finance, Bank Al-Maghrib and ACAPS.
  • Its key actions for 2026 are setting up a green taxonomy, evolving ESG reporting towards international standards, and publishing a guide for statutory auditors on reviewing funds raised through sustainable issuances.
  • It also reports a joint World Bank and IOSCO workshop on the adoption of ISSB standards for regulators of the region.

Key dates

  • January 2026: AMMC priorities for action 2026 published.

How we checked it

Read: the AMMC Priorities for action 2026 (pages 2, 4 and 10 of the PDF). These are the regulator’s stated intentions, not rules, and the timing is not given.

Sources

Guidance or voluntary

CGEM label for corporate social responsibility (RSE)

Who it applies to

Companies established in Morocco that are members of the CGEM and have been active for at least three years (CGEM rules document). The CGEM web page describes the label as open to Moroccan companies regardless of size and says a Responsible SME Label was launched in 2025; the rules of that SME label were not in the document we read.

What it says

  • Voluntary. The label certifies that the company’s management structures and acts give sufficient assurance of compliance with the objectives of the CGEM CSR Charter: tangible proof that it does not breach the legal obligations among those objectives, and formal commitments plus an improvement plan across the Charter’s nine action areas, in line with its size and activities.
  • Process: a written request to the CGEM CSR and Diversity Commission; an assessment by an organisation accredited by the CGEM, paid by the company; then the final report, signed commitments and an approved action plan go to the award committee, which interviews the company’s management.
  • The award committee has 15 members, decides unanimously among those present, and is not bound by the assessor’s opinion. The President of the CGEM grants the label on its advice.
  • The label lasts three years, with a follow-up assessment at mid-term (18 months). It can be revoked, and renewal requires a new assessment under the same conditions as the first.
  • Costs listed in the rules: the assessment itself (indicatively 5 person-days for fewer than 50 employees, rising to 15 or more above 700), a contribution to the CGEM by turnover (MAD 3,000 below MAD 10 million, MAD 10,000 up to MAD 50 million, MAD 20,000 above), and a fixed MAD 4,000 for the trophy. The rules also mention Maroc PME co-funding for eligible SMEs under a 2016 programme: check whether it is still available.

Key dates

  • 2007: label created.
  • Validity: 3 years, with a follow-up assessment at 18 months.
  • 2025: Responsible SME Label launched.

How we checked it

Read: the CGEM page on the label and the CGEM document “Règles d’attribution du Label RSE” (a PDF supplied to us). The rules document is undated and refers to a 2016 programme, so it may predate the 2025 SME label: check current terms, fees and eligibility with the CGEM. Neither source names the nine action areas.

Sources

Guidance or voluntary

AMMC Guide on Green, Social and Sustainability Bonds

Who it applies to

Issuers considering a green, social or sustainability bond.

What it says

  • A guide prepared by the AMMC with the support of the IFC, continuing its November 2016 guide on green bonds and adding social and sustainability bonds.
  • It says ongoing communication on these bonds is to be made within the annual ESG report that issuers making a public offering must publish.
  • It describes external review as consulting, verification, certification or scoring, and refers to the ICMA guidelines for external reviewers, which set five ethical and professional principles.

Key dates

  • November 2016: AMMC guide on green bonds.
  • June 2018: this guide.

How we checked it

Read: the 2018 guide. It is guidance, not a regulation. We have not checked whether the AMMC has replaced or updated it since.

Sources

Rules and requests that reach Moroccan companies from outside

These were written elsewhere and are not Moroccan law. They matter because European customers, groups and lenders apply them to their Moroccan suppliers and subsidiaries.

Reaches you from outside

EU carbon border adjustment mechanism (CBAM)

Who it applies to

EU importers carry the legal obligation. Moroccan exporters of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen are reached through their customers, who need the emissions data.

What it says

  • The definitive regime applies since 1 January 2026. The first annual declaration, for 2026 imports, is due by 30 September 2027.
  • Importers that bring in no more than 50 tonnes a year of covered goods are exempt. The total is counted per importer, across all its suppliers.
  • Emissions can be declared on default values or on actual data verified by an accredited verifier.

Key dates

  • 1 January 2026: definitive regime starts.
  • 1 February 2027: sales of certificates for 2026 emissions begin.
  • 30 September 2027: first annual declaration.

How we checked it

Checked on 26 October 2026 against Regulation (EU) 2025/2083 (Articles 2a, 6 and 20 of the CBAM Regulation as amended: the 50-tonne threshold, the first declaration in 2027 for 2026, and sales of certificates from 1 February 2027) and the European Commission’s CBAM pages and Questions and Answers.

Sources

Related on this site

Reaches you from outside

EU CSRD and the Omnibus reform

Who it applies to

EU companies and groups above 1,000 employees and EUR 450 million of net turnover, and some EU subsidiaries of non-EU groups. Moroccan companies are reached through an EU parent group, customers or lenders.

What it says

  • After the 2026 Omnibus, the CSRD applies from financial years beginning on or after 1 January 2027, and both tests must be passed.
  • No Moroccan statute, decree or AMMC instrument requires all companies, or all listed companies, to report under IFRS S1 and S2 or under the ESRS (as of 17 October 2026, in our CSRD vs ISSB report).
  • Suppliers with up to 1,000 employees have a right to refuse requests made for CSRD purposes that go beyond the EU voluntary standard. The cap does not cover due-diligence, contractual or wider risk-management requests.

Key dates

  • 18 March 2026: Omnibus I enters into force.
  • 1 January 2027: revised CSRD scope applies from financial years beginning on or after this date.

How we checked it

Facts repeated from ANKAA’s CSRD vs ISSB report and Omnibus article, stated as of 17 October 2026. We did not re-read the directives for this page.

Sources

Related on this site

Reaches you from outside

Customer questionnaires, EcoVadis and CDP requests

Who it applies to

Suppliers whose customers run supplier ESG programmes. Not a legal duty, but often a condition of doing business.

What it says

  • A questionnaire, a CDP request or a supplier code is a value-chain or contractual data request. It does not make a company a CSRD reporter.
  • EcoVadis is questionnaire and document based, so a weak folder gives a weak result even in a company that behaves well.

How we checked it

Facts repeated from ANKAA’s Omnibus and EcoVadis articles. See those articles for their sources and check dates.

Related on this site

Not yet on this page

We add an entry only after reading its primary source. These are next, and are not covered yet:

  • The masi.esg index of the Casablanca Stock Exchange (the exchange revised its methodology in November 2023; we have not read the current rules).
  • Environmental assessment and permitting rules, and the implementing texts of Law 99-12.
  • Carbon pricing and greenhouse gas certification arrangements in Morocco (so far only press reports).
  • Rules for insurers and pension funds (ACAPS) and sector rules.

How we keep this page

Each entry names the source we read and says what we did not read. The date at the top is the day the page was last updated, and each entry says what we read and when. Dates that we calculated, such as the phase-in dates of the Bank Al-Maghrib directive, are marked as ours.

If you find an error or a newer text, write to contact@ankaapartners.com. We correct the entry and add the date of the change here.

This page is general information prepared by ANKAA. It is not legal, financial, audit or compliance advice. Texts change: read the original source before relying on an entry.

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