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Payment institutions are licensed (agrément) by BAM's Governor under Law 103-12, now amended by Law 87.21 (~May 2026) to strengthen financial-stability oversight of systemically important institutions.
Bank Al-Maghrib has separately signalled, in a policy statement rather than a concrete instrument, that it plans to introduce an Open Banking framework and to further simplify its regulatory framework, accelerate fintech application processing, and improve regulatory transparency. This is assessed at Assessed confidence, reflecting that it remains a stated intent rather than a published rule or licensing criterion change.
Outlook
The first-licence award and the stated intent to simplify and accelerate fintech licensing point toward continued liberalisation of Morocco's payment-institution market-access regime. Bank Al-Maghrib's Open Banking framework is expected during the fourth quarter of 2026 but remains at the proposed stage; no further licensing criteria or accelerated-processing rules have yet been published. No sourced material was located this cycle on conduct, safeguarding or promotions requirements applicable to Moroccan payment institutions (W1b), so the scope of this liberalisation should not be read as extending to conduct-side obligations.
Licensing, Authorisation & Market Access
Morocco's Comite des Etablissements de Credit, the advisory committee that sits within the licensing and prudential architecture for credit and payment institutions, held its annual meeting on 22 October 2026 at the central bank's headquarters in Rabat. At that meeting the committee issued favourable opinions on ten regulatory texts operating under the legal framework governing credit and payment institutions. The individual texts were not named in the reporting reviewed, so the precise scope of what will change for licensing, authorisation thresholds, or market-access conditions cannot yet be assessed in detail. What can be said is that ten texts receiving a favourable opinion in a single sitting is a substantive volume, suggesting a coordinated package rather than a single isolated amendment, and market participants with licensing or authorisation applications pending before Moroccan authorities should anticipate that some portion of the current rulebook may shift once these texts are formally adopted and published.
A favourable opinion from the committee is an advisory step that typically precedes formal adoption rather than constituting adoption itself. This means the practical effect on market access, whether for banks, payment institutions, or other credit establishments, remains contingent on the texts clearing whatever final adoption and publication steps follow committee review. Firms already licensed in Morocco, and those contemplating entry, should treat this as a signal to watch for the individual published texts rather than as an immediate change to current authorisation requirements. Given the scale of the package, it is plausible that some combination of prudential, conduct, or procedural rules affecting both bank and non-bank credit and payment institutions will be touched, though nothing in the material reviewed indicates which specific requirements will be amended, so no assumption should be made in either direction about increased or relaxed market-access conditions.
The broader context for this development is the committee's role as a standing feature of Morocco's institutional architecture for credit and payment institution oversight, and the annual meeting format itself suggests this is part of Morocco's regular regulatory review cycle rather than an ad hoc response to a specific market event. That said, the volume of texts reviewed in one sitting this year stands out relative to prior baseline activity and is treated as a material development for this reason, warranting continued attention as the underlying texts are published.
Outlook
The principal marker to watch is the publication of the ten individual texts that received the committee's favourable opinion. Once published, these will allow a concrete assessment of whether the package represents an expansion, contraction, or procedural refinement of market-access and licensing conditions for credit and payment institutions operating in Morocco. Until that publication occurs, firms should treat the current licensing and authorisation framework as unchanged in practice, while anticipating that some adjustment is likely to follow given the scale of the package reviewed.
1 earlier distinct update(s)
Licensing, Authorisation & Market Access
Morocco's parliament approved Law No. 87.21 by a 66-28 vote around May 2026, amending both Law 103-12, the credit-institutions framework, and Law 40-17, which sets out Bank Al-Maghrib's own statutes, with the stated purpose of strengthening financial-stability oversight of systemically important institutions. This is a prudential-architecture amendment rather than a change to the licence types or market-access pathways available to payment-relevant institutions; it operates by expanding or reinforcing the central bank's supervisory reach over institutions whose failure would carry systemic consequences, rather than by creating or removing a licence category.
The payments-relevant implication is structural: Morocco's payments landscape, as separately confirmed under the standing correspondent-banking position, operates within Bank Al-Maghrib's overall regulatory perimeter under Law 103-12, which covers credit institutions and, by extension, several categories of payment-service provider licensed as credit institutions. Law 87.21's systemic-oversight amendments therefore layer onto that same licensing base rather than displacing it, tightening the supervisory consequences of holding a systemically significant licence under the existing framework rather than changing who may hold one.
No change to the bank-versus-non-bank payment-institution licensing distinction was evidenced this cycle. The amendment's language, as reported, targets systemically important institutions broadly, a category that in Morocco's still bank-centric financial system is likely to capture large credit institutions ahead of smaller non-bank payment-institution or e-money-institution licensees, though this cycle's sourcing does not specify which institutions are newly or more heavily captured.
Outlook
The open question for market access is implementation: whether Bank Al-Maghrib issues implementing circulars under Law 87.21 that specify which institutions qualify as systemically important, and whether any payment-institution or e-money-institution licensees fall within that expanded designation. A future cycle should watch for such implementing regulation and for any resulting change to prudential requirements attaching to licences held by payment-relevant institutions.
1 further periodic run re-emitted the standing brief unchanged and is not shown.
Sources and findings (5)
- T1https://www.bkam.ma/en/Find-information-about/Regulation/Legal-framework-of-payment-systems-and-meansretrieved
- T1https://www.bkam.ma/en/Banking-supervision/Micro-prudential-supervision/Licensingretrieved
- T3https://lafroujiavocats.com/en/morocco-fintech-2025-payment-market/retrieved
- T3https://resourcehub.bakermckenzie.com/en/resources/global-financial-services-regulatory-guide/europe-middle-east-and-africa/morocco/topics/what-types-of-activities-require-a-license-in-your-jurisdictionretrieved
- T3https://www.laamrani-law.com/wp-content/uploads/Payment%20institutions%20in%20Morocco-%20Article%20August%202021-1.pdfretrieved