ESG

CSRD vs ISSB for Moroccan companies: what applies?

For most Moroccan companies neither framework is law, and the data requests arrive anyway. How to tell which door reaches you, what you can decline, and what to build first.

By Brahim Eloidii, Co-Founder, ESG & CSR Lead

Published 26 October 2026 · Sources last checked 17 October 2026

Two acronyms, one costly confusion

CSRD and ISSB are often presented as rivals, as if a company had to pick a side. They are different kinds of instrument. The CSRD is a European directive, with its own reporting standards, the ESRS, and it fixes who must report. IFRS S1 and S2, issued by the International Sustainability Standards Board, are global standards. They fix how to report once a regulator, a stock exchange or a contract requires them.

For a Moroccan company the confusion is costly, because these rules were written elsewhere. A company that answers the wrong question can spend a year preparing for a regulation that never applied to it, and still be unprepared for the customer questionnaire that did.

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What the CSRD actually covers

After the 2026 Omnibus, the CSRD applies from financial years beginning on or after 1 January 2027 to EU companies and groups that have more than 1,000 employees on average and more than EUR 450 million of net turnover. Both tests must be passed: a group with 5,000 employees and EUR 300 million of turnover is out.

It also reaches the EU subsidiary or branch of a non-EU group. That happens when the group has more than EUR 450 million of turnover in the EU in each of two consecutive years and the EU entity itself exceeds EUR 200 million. IFRS S1 and S2, by contrast, have no thresholds at all.

What applies in Morocco

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. Two groups have their own rules.

• Banks follow Bank Al-Maghrib Directive 1/W/2025, signed on 24 January 2025. It sets climate disclosure aligned with the ISSB standards, phased in over 24, 36 and 48 months for Scope 1 and 2, Scope 3 and subsidiaries. Confirm the dates against the published text.
• Listed companies file an annual ESG report under AMMC Circular 03/19, dated 20 February 2019. It predates IFRS S1 and S2 and is not an adoption of them.

For the full list of Moroccan ESG rules, with who each one applies to, the key dates and the source we read, see our ESG rules in Morocco page.

Six doors through which the rules reach you

Everyone else is reached indirectly. The diagram above shows the six channels, from binding law to market expectation. They differ sharply in what they let you refuse.

1. An EU legal presence. A subsidiary or branch in the EU can fall directly under the CSRD if it passes the thresholds. This is the only door where the CSRD applies to you as law.
2. Moroccan regulators. Bank Al-Maghrib for banks, the AMMC for listed issuers.
3. An EU parent group that consolidates you. Your plant can be inside the group’s ESRS report even though you are not a reporter yourself. Renault, for example, states that its consolidated sustainability statement follows the ESRS and that its group perimeter includes Moroccan manufacturing operations.
4. EU customers. Large European buyers cover their supply chain in their own reports, so they send suppliers questionnaires, CDP requests and codes of conduct.
5. Lenders. In September 2025 the European Investment Bank said it was aligning client-reporting requirements with EU sustainability standards such as the CSRD, to reduce duplication. It did not say that every non-EU borrower must produce a full ESRS statement.
6. Investors. IFRS S1 and S2 are designed for the providers of capital, so an investor may read your report through them.

No public source counts how many Moroccan companies sit behind each door. Our reading is that many exporters are likely to sit in the customer channel. It is the weakest in law and the strongest in daily pressure, because it arrives as a deal term with a customer’s deadline attached.

A request is not an obligation

The most useful distinction is between a legal obligation and a data request. A customer questionnaire, a CDP request, a supplier code or a financing covenant does not by itself make a Moroccan company a CSRD reporter, and it does not establish compliance with IFRS S1 and S2. It is a value-chain or contractual data request.

The Omnibus gives that distinction practical weight. Companies with up to 1,000 employees have a right to refuse requests made for CSRD purposes that go beyond the EU voluntary standard, subject to legal exceptions. But that cap covers requests made for CSRD reporting. It does not stop voluntary sharing, and it does not govern data collected for due diligence, for contractual compliance or for the buyer’s wider risk management. A request that arrives as a clause in a supply contract may sit outside the cap entirely. How national laws will apply the cap to a non-EU supplier is a point to watch.

In practice, answer each request on its own terms, check whether the cap protects you, avoid promising a framework you are not bound to, and keep one reusable data pack so that each new questionnaire does not restart the work.

Build one data core, not two systems

On climate the two frameworks share a skeleton: the same four pillars (governance, strategy, risk management, metrics and targets), aligned definitions of financial materiality and the GHG Protocol as the measurement base. The joint guidance of EFRAG and the IFRS Foundation says that almost all of the climate disclosures the ISSB standards require are included in the 2023 ESRS. IFRS S2 adds scenario analysis, transition-plan assumptions and, for financial institutions, financed emissions. The ESRS add impact materiality and dedicated non-climate topics. The official guidance covers the 2023 ESRS; a joint mapping to the revised 2026 ESRS had not been published at our cut-off.

That is why we do not recommend choosing a framework first. Our verdict has three steps:

1. Find your channel. Do you own a company in the EU? Do European customers, lenders or investors ask you for data? Are you a Moroccan bank or listed issuer?
2. Build one data core. A Scope 1 and 2 inventory on the GHG Protocol, a Scope 3 screening of the material categories, and a governance and climate-risk statement.
3. Choose the top layer. The ESRS for European-exposed companies, the Bank Al-Maghrib directive for banks, AMMC Circular 03/19 for domestic issuers, with IFRS S2 as the direction of travel. Add the IFRS S2 extras only when a bank, an investor or a regulator asks.

Where to start: three scenarios

All three paths share the same first two steps: an exposure check and a greenhouse gas inventory. The full report gives each scenario a phased path over about 18 months.

What is in the full report

• The path for each scenario in three phases, with timings
• Six recommended actions, and what would change our view
• Points to confirm against the original texts, and the key dates to 2029
• 34 numbered sources, each tagged official, company or adviser

No prior knowledge of either framework is assumed. Prefer to talk it through first? Write to us for a free 30-minute call, and we will tell you what we would check first, whether or not you work with us afterwards.