---
title: "Morocco Payments Regulation Monitor | World Payments Monitor"
canonical: https://payments.gi/jurisdictions/morocco/
source_html: /jurisdictions/morocco/index.html
description: "Morocco payments and e-money regulation: 14 modules, 58 sourced findings, updated 2026-10-26. Licensing, safeguarding, stablecoins, AML/CFT."
generated_at: 2026-10-26T19:20:26Z
content_sha256: 6ae83bae1c98bae7223e0beac55f1b88ee4c5dbd0de8d769d1cc1ea48b17fa18
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---
# Morocco

MA
schema world-payments-v1
trajectory: not yet assessed

Last updated 2026-10-26 · 14 modules · 58 sourced
findings · 98 sources in the cumulative register

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14 Modules

2 Moved this cycle 1 Key judgments 4 Open gaps 58 Findings

15 Tier-1 sources

Confidence mix 7 confirmed 7 unpopulated
(sums to 14 rendered modules; click to filter)

2 modules moved this cycle

## Jurisdiction brief

Jurisdiction lead brief 1,152 Full executive summary 445

###### Latest update · 25 October 2026

#### Lead Signal

Bank Al-Maghrib has completed a first experimental phase demonstrating the technical feasibility of a retail digital dirham, conducted with support from the International Monetary Fund and World Bank, alongside a second pilot addressing cross-border payments in cooperation with the Central Bank of Egypt. The central bank has been explicit that this result does not signal imminent issuance: legal, technical, and institutional conditions remain to be resolved before any retail central bank digital currency could move toward deployment. This places Morocco among the active but deliberately cautious explorers of central bank digital currency in the Middle East and North Africa and wider African region, pursuing multilateral-backed research while withholding any issuance commitment.

Alongside this, Morocco&#x27;s Comite des Etablissements de Credit held its annual meeting on 22 October 2026 at the central bank&#x27;s headquarters in Rabat and issued favourable opinions on ten regulatory texts falling under the legal framework governing credit and payment institutions. The texts themselves were not individually named in reporting reviewed, so the specific scope of what will change in licensing or market-access terms is not yet established, but the volume of texts receiving a favourable opinion in a single sitting points to a substantive package moving through the approval process together.

#### Other Developments

Favourable committee opinions on a ten-text package. The Comite des Etablissements de Credit&#x27;s role is advisory within Morocco&#x27;s credit and payment institution licensing architecture, and a favourable opinion at this stage typically precedes formal adoption. Market participants should expect the underlying texts to surface individually as they are published, at which point their effect on licensing, authorisation, or market-access conditions for payment institutions can be assessed in detail.

Fintech funding activity remains thin. Morocco recorded a single disclosed start-up funding deal of one hundred thousand United States dollars in September 2026, placing it at the bottom of the regional funding ranking tied with Palestine, with Algeria moving ahead of it. No other payment-institution, e-money-institution, or fintech funding, merger, or product-launch event specific to Morocco was identified in the window under review. This is a commercial data point about the pace of private capital formation in Morocco&#x27;s digital-finance sector rather than a regulatory development.

#### Cross-Monitor Connections

The digital dirham cross-border pilot with the Central Bank of Egypt touches on correspondent-banking and settlement-access dynamics, though no corridor-level detail beyond the existence of the pilot was available. The ten-text package receiving favourable committee opinion will, once individual texts are published, bear on firms&#x27; financial-crime control obligations to the extent any of the texts touch compliance or conduct requirements; this is not yet assessable from the material to hand and should be revisited once the individual instruments are public.

#### Outlook

The near-term marker to watch is whether Bank Al-Maghrib moves from its current experimental-and-cautious posture toward any firmer decision point on digital dirham issuance, and whether the Egypt cross-border pilot produces published results. On the licensing side, publication of the individual texts behind the Comite des Etablissements de Credit&#x27;s favourable opinions will determine whether the development amounts to a substantive market-access change or a more routine regulatory housekeeping exercise. Morocco&#x27;s thin fintech funding picture is likely to remain a standing feature of the market rather than a fast-moving story absent a change in investor appetite across the region.

2 earlier updates not shown here.

###### Standing brief · as of 19 August 2026

Written before the update above. Where they differ, the update is the more recent position.

#### Lead Signal

Bank Al-Maghrib&#x27;s Decision No. 265/W/2026 lowers the domestic interchange-fee cap from 0.65% (set in October 2024) to 0.50% effective 1 October 2026, and introduces a special 0.15% ceiling for government-entity payments and proximity commerce. The decision, dated 6 July 2026, carries Probable confidence and arrives alongside confirmation that a separate structural process has completed: a joint Bank Al-Maghrib/Competition Council communiqué issued 10 July 2026 confirmed that CMI&#x27;s (Centre Monetique Interbancaire) merchant-portfolio transfer to competing acquirers finished on schedule, following an October 2025 extension granted around the Africa Cup of Nations period. CMI had separately been required to transfer approximately 55,000 merchant contracts to licensed acquiring operators by 31 January 2026, with government contracts given an extended deadline of 30 April 2026.

Taken together with Bank Al-Maghrib&#x27;s grant of Morocco&#x27;s first payment institution licence and the completed CMI portfolio separation, the interchange reduction reflects a coordinated push to open Morocco&#x27;s payments market to fintech competition across licensing, market structure and pricing at the same time, rather than through a single isolated measure. Pricing power and merchant relationships that had sat with a single former processor are now distributed across a wider set of licensed acquirers, and the interchange ceiling itself has been lowered for a second time in under two years, having been set at 0.65% only in October 2024.

#### Other Developments

Bank Al-Maghrib granted Morocco&#x27;s first payment institution licence to a venture-backed startup on 15 October 2025, after the entity demonstrated three years of documented Morocco operations and a locally maintained technology stack; the finding carries Probable confidence. The central bank has also signalled, at Assessed confidence and in a policy statement rather than a concrete instrument, that it plans to introduce an Open Banking framework, to further simplify its regulatory framework, to accelerate fintech application processing, and to improve regulatory transparency. Both developments sit on the non-bank payment-institution side of Morocco&#x27;s market, distinct from the bank-led interchange and acquiring changes described above.

At the Morocco Fintech Booster 2026 closing, Bank Al-Maghrib Director General Abderrahim Bouazza assessed that digital-payment adoption in Morocco remains constrained by limited merchant acceptance, financial-inclusion gaps affecting rural areas and women, and incomplete digitisation of public payments. That assessment tempers the liberalisation narrative above: regulatory market-opening and price reform are proceeding, but the adoption gap they are meant to close has not yet closed.

#### Cross-Monitor Connections

No cross-monitor corridor or illicit-finance flags were raised for Morocco this cycle. Where illicit-finance dimensions of Morocco&#x27;s payments market arise, they are tracked in the financial-integrity feed rather than analysed first-party in this monitor, and this brief does not draw independent AML/CFT conclusions from that material.

#### Outlook

The interchange-fee cap reduction takes effect on 1 October 2026, and Bank Al-Maghrib&#x27;s Open Banking framework is expected during the fourth quarter of 2026, though it remains at the proposed stage rather than adopted. The CMI government-contract transfer deadline of 30 April 2026 falls within the period covered by the July 2026 completion confirmation, closing out that near-term horizon item. Coverage this cycle is concentrated in licensing and market access, industry structure, and merchant-acquiring pricing; no sourced material was located this cycle on conduct and safeguarding rules for Moroccan payment institutions, operational resilience, scheme and network compliance, litigation, consumer protection or APP fraud, or correspondent banking and settlement access. The liberalisation signal running through licensing, market structure and pricing should therefore be read as concentrated rather than as evidence of a comprehensive across-the-board regulatory overhaul this cycle.

Read full brief · 1152 words

###### Latest update · 11 October 2026

#### Regulatory Status

Bank Al-Maghrib has lowered the domestic card-interchange cap from 0.65% to 0.50% HT, with a preferential 0.15% HT tier for e-Gov and proximity-merchant payments, under Décision Réglementaire n°265/W/2026, effective 1 October 2026. The reform completes the structural liberalisation of the acquiring market: CMI and its shareholder banks exited commercial acquiring after the Conseil de la Concurrence&#x27;s 31 October 2024 decision, and the shift to a multi-acquirer architecture is now reported as effectively implemented. Acquiring payment institutions are additionally required to disclose merchant fees contractually and are barred from passing card surcharges through to cardholders, both taking effect alongside the cap.

#### Outlook

Morocco&#x27;s payments regulatory trajectory is tightening on pricing and conduct even as the market structure itself liberalises, with the interplay between the new multi-acquirer landscape and the lower interchange ceiling the key dynamic to watch from 1 October 2026 onward.

###### Standing brief · as of 19 August 2026

Written before the update above. Where they differ, the update is the more recent position.

#### Regulatory Status

Morocco&#x27;s payments market is undergoing concentrated liberalisation this cycle across licensing, market structure and merchant-acquiring pricing. Bank Al-Maghrib granted Morocco&#x27;s first payment institution licence to a venture-backed startup on 15 October 2025, and has signalled an intent to introduce an Open Banking framework and further simplify and accelerate fintech licensing. A joint Bank Al-Maghrib/Competition Council communiqué dated 10 July 2026 confirmed that CMI&#x27;s merchant-portfolio transfer to competing acquirers completed on schedule, structurally ending CMI&#x27;s former single-processor position; CMI had been required to transfer approximately 55,000 merchant contracts by 31 January 2026, with government contracts extended to 30 April 2026. Bank Al-Maghrib Decision No. 265/W/2026, dated 6 July 2026, separately lowers the domestic interchange-fee cap from 0.65% to 0.50% effective 1 October 2026, with a special 0.15% ceiling for government-entity payments and proximity commerce. Against this liberalising backdrop, Bank Al-Maghrib&#x27;s Director General assessed at the Morocco Fintech Booster 2026 closing that digital-payment adoption remains constrained by limited merchant acceptance, financial-inclusion gaps, and incomplete public-payment digitisation.

No sourced material was located this cycle on conduct and safeguarding rules for Moroccan payment institutions, operational resilience, scheme and network compliance, litigation, consumer protection or APP fraud, or correspondent banking and settlement access, so this liberalisation signal should be read as concentrated in the areas above rather than economy-wide.

#### Outlook

The interchange-fee cap reduction takes effect 1 October 2026, and the Open Banking framework is expected during the fourth quarter of 2026 but remains at the proposed stage. Morocco&#x27;s regulatory direction this cycle is liberalising across the modules with sourced material, driven by a coordinated set of Bank Al-Maghrib actions on licensing, market structure and pricing.

Read full brief · 445 words

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### W1aLicensing, Authorisation & Market AccessmovedConfirmedconfirmed 2026-06-27&#9662;#

Payment institutions are licensed (agrément) by BAM&#x27;s Governor under Law 103-12, now amended by Law 87.21 (~May 2026) to strengthen financial-stability oversight of systemically important institutions.

Movement — NEW CEC annual meeting issued favourable opinions on ten texts. New dated regulatory-committee event.

Standing sub-brief · as of 19 August 2026 215 words · last cycle 2026-10-25

#### Licensing, Authorisation & Market Access

Bank Al-Maghrib granted Morocco&#x27;s first payment institution licence to a venture-backed startup on 15 October 2025. The award followed the entity&#x27;s demonstration of three years of documented Morocco operations and a locally maintained technology stack, and the finding is assessed at Probable confidence. The licence is a non-bank payment-institution authorisation, distinct from the bank-led pricing and acquiring reforms addressed under W8 and W6.

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&#x27;s payment-institution market-access regime. Bank Al-Maghrib&#x27;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.

Read full sub-brief · 215 words Periodic update · new data 2026-10-25

#### Licensing, Authorisation & Market Access

Morocco&#x27;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&#x27;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&#x27;s role as a standing feature of Morocco&#x27;s institutional architecture for credit and payment institution oversight, and the annual meeting format itself suggests this is part of Morocco&#x27;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&#x27;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) Periodic update · new data 2026-09-28

#### Licensing, Authorisation & Market Access

Morocco&#x27;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&#x27;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&#x27;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&#x27;s payments landscape, as separately confirmed under the standing correspondent-banking position, operates within Bank Al-Maghrib&#x27;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&#x27;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&#x27;s language, as reported, targets systemically important institutions broadly, a category that in Morocco&#x27;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&#x27;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.

Evidence 5

Sources and findings (5)
- T1[https://www.bkam.ma/en/Find-information-about/Regulation/Legal-framework-of-payment-systems-and-means](https://www.bkam.ma/en/Find-information-about/Regulation/Legal-framework-of-payment-systems-and-means)retrieved 2026-06-27
- T1[https://www.bkam.ma/en/Banking-supervision/Micro-prudential-supervision/Licensing](https://www.bkam.ma/en/Banking-supervision/Micro-prudential-supervision/Licensing)retrieved 2026-06-27
- T3[https://lafroujiavocats.com/en/morocco-fintech-2025-payment-market/](https://lafroujiavocats.com/en/morocco-fintech-2025-payment-market/)retrieved 2026-06-27
- T3[https://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-jurisdiction](https://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-jurisdiction)retrieved 2026-06-27
- T3[https://www.laamrani-law.com/wp-content/uploads/Payment%20institutions%20in%20Morocco-%20Article%20August%202021-1.pdf](https://www.laamrani-law.com/wp-content/uploads/Payment%20institutions%20in%20Morocco-%20Article%20August%202021-1.pdf)retrieved 2026-06-27

### W1bConduct, Safeguarding & Promotions1 gapConfirmedconfirmed 2026-06-27&#9662;#

Conduct and consumer-protection for payment/credit customers rests on Law 103-12 and consumer-protection Law 31-08, both enforced by Bank Al-Maghrib, which issues transparency, complaint-handling and banking-mediation rules. Customer funds at payment institutions are safeguarded by segregation/escrow at a bank (e.g. Lana Cash/CIH wallet funds held at CIH under BAM&#x27;s PI rules). There is no UK-style financial-promotions s.21 regime; conduct is anchored in transparency-of-fees and disclosure obligations.

Open gap — wpm-int-2 No conduct/safeguarding/financial-promotions (W1b) delta for Morocco found this cycle. no under-indexing note recorded

Standing sub-brief · as of 27 June 2026 215 words · last cycle 2026-10-11

#### Conduct, Safeguarding & Financial Promotions

Conduct and consumer protection for Moroccan payments rests on Law 103-12 together with consumer-protection Law 31-08, enforced by Bank Al-Maghrib through transparency, complaint-handling and banking mediation. Law 31-08 grants an 8-day credit-withdrawal right. A primary BAM source anchors the regime. Critically for non-bank operators, customer funds at payment institutions are safeguarded by segregation/escrow at a bank: the operative example is Joro Cash wallet funds, held via Lana Cash — a CIH subsidiary — at CIH Bank under BAM PI rules. Safeguarding via bank escrow is therefore the operative customer-fund-protection mechanism for non-bank e-money issuers.

The bank-PSP versus non-bank PI/EMI distinction is consequential here. Whereas bank-PSPs hold customer funds within the regulated banking entity, non-bank payment institutions must segregate and escrow customer funds at a bank, shifting fund protection onto segregation discipline. Morocco operates no UK-style section 21 financial-promotions regime, and there is no FSCS-style deposit-guarantee scheme covering e-money — the absence places the weight of protection on the segregation arrangement rather than a compensation backstop.

#### Outlook

The conduct and safeguarding framework is established and stable. The operative watch-point is the integrity of bank-escrow segregation as the non-bank challenger layer expands; in the absence of a compensation scheme, segregation discipline carries the protective load for the growing population of e-money customers.

Read full sub-brief · 215 words Periodic update · new data 2026-10-11

#### Conduct, Safeguarding & Financial Promotions

Bank Al-Maghrib has attached new conduct obligations to acquiring payment institutions as part of the domestic interchange reform set out in Décision Réglementaire n°265/W/2026. Acquirers must now include contractual clauses in merchant agreements that detail the fees applied to those merchants, giving merchants a documented basis for checking what they are charged rather than relying on informal disclosure. The decision also bars acquirers from passing card surcharges through to cardholders, closing off the obvious route by which an acquirer squeezed by the lower interchange cap might otherwise recover margin at the point of sale. Both duties sit on the acquiring side of the relationship rather than the issuing side, and both took legal effect on 1 October 2026 alongside the cap itself, so they are best read as the behavioural condition attached to the pricing reform rather than a free-standing conduct initiative.

#### Outlook

Because the no-surcharge and fee-disclosure duties are structurally tied to the interchange cap rather than issued as separate guidance, their practical weight will likely be judged by how visibly acquirers comply once the multi-acquirer market is fully operating and merchants start testing their contracts against what they are actually billed.

Evidence 4

Sources and findings (4)
- T1[https://www.bkam.ma/en/Banking-supervision/Protection-of-credit-institutions-customers](https://www.bkam.ma/en/Banking-supervision/Protection-of-credit-institutions-customers)retrieved 2026-06-27
- T3[https://payatlas.com/regulator/bkam-4593](https://payatlas.com/regulator/bkam-4593)retrieved 2026-06-27
- T3[https://www.startupresearcher.com/news/9-moroccan-fintech-startups-to-follow-in-2025](https://www.startupresearcher.com/news/9-moroccan-fintech-startups-to-follow-in-2025)retrieved 2026-06-27
- T3[https://atlasimmobilier.com/en/your-banking-rights-what-you-need-to-know-with-bank-al-maghrib/](https://atlasimmobilier.com/en/your-banking-rights-what-you-need-to-know-with-bank-al-maghrib/)retrieved 2026-06-27

### W2Stablecoins & Digital Moneymoved1 judgmentProbableconfirmed 2026-06-27&#9662;#

Morocco has an e-money framework (EMIs under Law 103-12, MAD 3m capital, BAM-licensed) but cryptocurrencies remain banned domestically; a draft crypto/digital-asset law with AML/CFT requirements has been in preparation. BAM is separately developing a CBDC, the &#x27;e-Dirham&#x27;, in testing. Note: the crypto draft law is flagged as proposed/in-development, not enacted.

Movement — NEW BAM completed first experimental CBDC phase and published two research papers. New dated development on digital dirham experimentation.

Key judgment — Probable · impact Morocco&#x27;s central bank is advancing CBDC research with explicit multilateral (IMF/World Bank) backing while stopping short of signalling imminent retail issuance; this positions Morocco as an active but cautious CBDC explorer in the MENA/Africa region. claims: none recorded

Horizon · 2026 (± a year) Morocco draft digital-asset / crypto law with AML/CFT requirements Proposed · Tier 3 source

Standing sub-brief · as of 27 June 2026 198 words · last cycle 2026-10-25

#### Stablecoins & Digital Money

Morocco&#x27;s digital-money posture combines a licensed e-money route with a restrictive stance on crypto-assets and an active central-bank pilot. EMIs licensed under Law 103-12 (MAD 3m capital) may issue e-money. Cryptocurrencies remain banned domestically, and a draft digital-asset law incorporating AML/CFT requirements is in preparation but not enacted. BAM is piloting the e-Dirham CBDC, with the pilot reported to encompass retail P2P use and a cross-border experiment with the Central Bank of Egypt under World Bank support, though no deployment timeline has been published. There is no in-force stablecoin framework. This assessment carries Assessed confidence and rests on a tier-3 source.

The regime constrains stablecoin and crypto rails domestically while signalling a future digital-money infrastructure direction through the e-Dirham pilot. The cross-border Egypt experiment detail is not present in the cited evidence, so horizon dating is indicative only.

#### Outlook

The draft digital-asset law, if enacted, would introduce a regulated framework potentially lifting the domestic crypto ban under rigorous AML/CFT obligations — but it remains a draft and its timing is uncertain. The e-Dirham pilot is the leading forward indicator of digital-money infrastructure, though the absence of a deployment timeline keeps any horizon dating provisional.

Read full sub-brief · 198 words Periodic update · new data 2026-10-25

#### Stablecoins & Digital Money

Bank Al-Maghrib has completed a first experimental phase demonstrating that it is technically feasible to offer a retail digital dirham, conducted with support from the International Monetary Fund and World Bank. A second, distinct pilot addresses cross-border payments and is being conducted jointly with the Central Bank of Egypt, indicating that Morocco&#x27;s central bank digital currency research programme is pursuing both a domestic retail use case and a cross-border settlement use case in parallel. Bank Al-Maghrib has been explicit in its own published research that this experimental result does not signal imminent issuance of a digital dirham: the central bank has stated that legal, technical, and institutional conditions remain to be resolved before any move toward deployment could be contemplated. This is a materially cautious framing relative to central banks elsewhere that have moved more directly from pilot to issuance roadmap, and it should be read as such.

The multilateral backing for this research, specifically the involvement of the International Monetary Fund and World Bank in the domestic retail pilot, situates Morocco&#x27;s central bank digital currency work within an internationally supported research track rather than a purely unilateral national initiative. This has implications for how the research is likely to proceed: multilateral involvement typically brings a degree of methodological rigour and external benchmarking to the pilot design, and may also mean that Morocco&#x27;s eventual findings feed into broader regional or international central bank digital currency knowledge-sharing rather than remaining a purely domestic exercise. The cross-border pilot with Egypt&#x27;s central bank adds a second dimension, testing whether a digital dirham construct could support settlement across the Morocco-Egypt corridor, though no results, timeline, or technical architecture for that pilot were available in the material reviewed.

For payment service providers, banks, and other market participants operating in or serving the Moroccan market, the practical takeaway is that no issuance decision is imminent and no operational or compliance obligation currently flows from this research phase. The explicit caution in Bank Al-Maghrib&#x27;s own framing, that legal, technical, and institutional conditions remain unresolved, is a clear signal that firms should not anticipate a near-term central bank digital currency rollout requiring system changes or integration work. This positions Morocco as an active participant in the broader wave of central bank digital currency research sweeping emerging-market central banks, while remaining notably conservative about translating research into a deployment commitment.

#### Outlook

The next markers to watch are any published results from the Egypt cross-border pilot, and any further research papers or public statements from Bank Al-Maghrib that move beyond the current experimental-feasibility framing toward a more concrete institutional or legal roadmap. Given the central bank&#x27;s explicit statement that conditions for deployment remain unresolved, a near-term issuance announcement should not be expected; the more likely near-term development is further research publication or an extension of the pilot programme&#x27;s scope.

Evidence 3

Sources and findings (3)
- T3[https://lafroujiavocats.com/en/morocco-fintech-2025-payment-market/](https://lafroujiavocats.com/en/morocco-fintech-2025-payment-market/)retrieved 2026-06-27
- T3[https://blog.voveid.com/aml-compliance-in-morocco-a-2025-guide-for-fintechs-and-regulated-businesses/](https://blog.voveid.com/aml-compliance-in-morocco-a-2025-guide-for-fintechs-and-regulated-businesses/)retrieved 2026-06-27
- T3[https://openbanking.ng/open-banking-in-morocco/](https://openbanking.ng/open-banking-in-morocco/)retrieved 2026-06-27

### W3Operational Resilience & Critical InfrastructureConfirmedconfirmed 2026-06-27&#9662;#

Operational resilience rests on cybersecurity Law 05-20 (Dahir 1-20-69, 25 July 2020) and implementing Decree 2-21-406 (2021), with DGSSI (attached to National Defence) as national cyber authority and maCERT for incident response; the National Directive on IS Security (DNSSI, updated Jan 2023) sets A/B/C classification and audit cycles for vital infrastructure (OIVs). For credit institutions specifically, BAM Directive 3/W/16 (10 June 2016) sets minimum penetration-test rules, and BAM&#x27;s Banking Supervision Directorate collaborates with DGSSI on banking-sector cyber compliance.

Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open this jurisdiction's page on Dataprotection.gi &rarr;](https://dataprotection.gi/jurisdictions/morocco/)

Standing sub-brief · as of 27 June 2026 205 words · last cycle 2026-06-27

#### Operational Resilience & Critical Infrastructure

Morocco&#x27;s operational-resilience regime is a bespoke national construct without a DORA-equivalent. It rests on cybersecurity Law 05-20 (Dahir 1-20-69, 2020) and Decree 2-21-406 (2021), with the DGSSI as national cyber authority and maCERT handling incident response. The updated DNSSI (January 2023) sets an A/B/C classification for vital infrastructure with a 6-month compliance window. Layered over this national regime is a sector-specific overlay: BAM Directive 3/W/16 (10 June 2016) sets minimum penetration-test rules for credit institutions, and BAM Banking Supervision collaborates with the DGSSI. Primary DGSSI sources anchor the regime. Moroccan banks are flagged as African digitalisation leaders and consequently high-value cyber targets.

For PSPs and banks alike, the cyber-resilience obligations covering credit institutions and operators of vital importance shape IT compliance cost. Notably, there is no DORA-CTP-style critical-third-party regime yet, so concentration risk in technology providers is not addressed by a dedicated oversight instrument.

#### Outlook

The resilience regime is established and stable, anchored in national cyber law plus a banking-sector pen-test overlay. The forward gap is the absence of a critical-third-party oversight framework; as the challenger layer relies increasingly on shared switches and platforms (HPSS, HPS Switch), third-party concentration is the structural watch-point not yet captured by the current regime.

Read full sub-brief · 205 words no periodic updates on record for this sub-brief

Evidence 4

Sources and findings (4)
- T1[https://www.dgssi.gov.ma/en/publications/national-directive-information-system-security-ndiss/](https://www.dgssi.gov.ma/en/publications/national-directive-information-system-security-ndiss/)retrieved 2026-06-27
- T2[https://regulations.ai/regulations/RAI-MA-NA-0520000-2020](https://regulations.ai/regulations/RAI-MA-NA-0520000-2020)retrieved 2026-06-27
- T1[https://www.dgssi.gov.ma/en/actualit%C3%A9s/la-cybersecurite-dans-le-secteur-bancaire](https://www.dgssi.gov.ma/en/actualit%C3%A9s/la-cybersecurite-dans-le-secteur-bancaire)retrieved 2026-06-27
- T3[https://www.mondaq.com/guides/results/15/1144/all/morocco-banking-regulation](https://www.mondaq.com/guides/results/15/1144/all/morocco-banking-regulation)retrieved 2026-06-27

### W4Scheme & Network ComplianceProbableconfirmed 2026-06-27&#9662;#

Card scheme rails run through CMI (Centre Monétique Interbancaire), the bank-owned interbank operator through which every Moroccan bank-card transaction historically passes. PCI-DSS and 3D Secure 2.0 are mandatory for online card processing, with annual PCI-DSS validation required by BAM. Interchange fees were capped at 0.65% from October 2024. Visa/Mastercard operate domestically via partner banks; surcharging by merchants is illegal.

Standing sub-brief · as of 27 June 2026 214 words · last cycle 2026-06-27

#### Scheme & Network Compliance

Card scheme rails in Morocco run through CMI, the bank-owned interbank operator. PCI-DSS and 3D Secure 2.0 are mandatory for online card processing, with annual PCI-DSS validation required by BAM. Visa and Mastercard operate domestically via partner banks, and merchant surcharging is illegal — the Competition Council has reminded merchants that surcharging, card-minimums and foreign-card refusal are illegal, though enforcement is weak. This standing scheme-compliance position rests on tier-3 sources and is held at Assessed confidence.

The defining scheme-economics change is the interchange cap: interchange fees were capped at 0.65% from October 2024, a structural change to the economics of card payments in Morocco that materially reshapes acquirer and issuer economics. This rests on a single tier-3 source and should be corroborated against a BAM or Competition Council primary instrument before Confirmed treatment. PCI-DSS and 3DS2 remain the mandatory gateway requirements, and CMI&#x27;s historical chokehold on card processing is the structural backdrop to the antitrust action examined under W7.

#### Outlook

The interchange cap and the CMI demonopolisation together open the card market: the cap reshapes pricing while the antitrust remedy reshapes acquiring access. The priority intelligence gap is primary-source anchoring of the 0.65% cap, currently resting on aggregator-only sourcing for a structural pricing change in an under-indexed emerging-market scheme-rule environment.

Read full sub-brief · 214 words no periodic updates on record for this sub-brief

Evidence 4

Sources and findings (4)
- T3[https://www.baas.ma/en/blog/passerelle-paiement-maroc-guide](https://www.baas.ma/en/blog/passerelle-paiement-maroc-guide)retrieved 2026-06-27
- T3[https://openbanking.ng/open-banking-in-morocco/](https://openbanking.ng/open-banking-in-morocco/)retrieved 2026-06-27
- T3[https://www.moroccoworldnews.com/2026/02/279409/morocco-launches-stay-cashless-to-digitize-tourism-payments/](https://www.moroccoworldnews.com/2026/02/279409/morocco-launches-stay-cashless-to-digitize-tourism-payments/)retrieved 2026-06-27
- T3[https://lafroujiavocats.com/en/morocco-fintech-2025-payment-market/](https://lafroujiavocats.com/en/morocco-fintech-2025-payment-market/)retrieved 2026-06-27

### W5Payment Corridor Dynamics1 gapProbableconfirmed 2026-06-27&#9662;#

Morocco&#x27;s dominant corridor is inbound diaspora remittances (MRE), which reached ~MAD 122 billion / $13.4 billion in 2025, making it among the top remittance recipients in Africa and second in MENA after Egypt; principal send markets are France, Spain, Italy, Germany, Belgium and the Netherlands. FX is tightly controlled by the Office des Changes. The domestic instant rail Virement Instantané (GSIMT, launched June 2023, ISO 20022, 24/7, MAD 20,000 cap) prepares for cross-border interoperability, and Morocco joined PAPSS in 2025 for pan-African settlement.

Open gap — wpm-int-3 No payment-corridor dynamics (W5) delta for Morocco found this cycle. no under-indexing note recorded

Standing sub-brief · as of 27 June 2026 226 words · last cycle 2026-06-27

#### Payment Corridor Dynamics

Morocco&#x27;s dominant payment corridor is inbound diaspora (MRE) remittances, which reached MAD 122.02 billion ($13.377bn) at end-2025, up 2.6%, with BAM forecasting roughly 3.1% average annual growth across 2025-2027 to MAD 130bn. Morocco is the second-largest MENA remittance recipient after Egypt. The principal send markets are France, Spain, Italy, Germany, Belgium and the Netherlands, and FX is controlled by the Office des Changes. This corridor data, citing the Office des Changes, carries High confidence on tier-2 sourcing. At roughly $13.4bn, remittances are the core commercial opportunity for money-transfer and digital-wallet operators.

The corridor&#x27;s forward dimension was reshaped on 7 July 2025, when BAM signed the PAPSS membership agreement, making Morocco the 17th country to join the Pan-African Payment and Settlement System, positioned to enable faster cross-border digital payments across the continent. PAPSS membership opens pan-African settlement rails, reducing correspondent-banking friction and supporting Moroccan fintech expansion into neighbouring markets. The precise signing date and 17th-member status were challenger-corrected against official Afreximbank/PAPSS T1 releases, and confidence is held at Assessed pending T1 anchoring in the source register.

#### Outlook

The EU-MA diaspora corridor is stable and dominant, while the MA-PAPSS corridor is opening. PAPSS membership and the e-Dirham cross-border pilot widen future rail options for the remittance flow that underpins the jurisdiction&#x27;s payment economics. Registering the T1 PAPSS anchors would lift confidence on the membership claim.

Read full sub-brief · 226 words no periodic updates on record for this sub-brief

Evidence 4

Sources and findings (4)
- T2[https://www.moroccoworldnews.com/2026/02/277165/moroccos-diaspora-remittances-reached-over-13-3-billion-in-2025/](https://www.moroccoworldnews.com/2026/02/277165/moroccos-diaspora-remittances-reached-over-13-3-billion-in-2025/)retrieved 2026-06-27
- T3[https://www.moroccoworldnews.com/2025/02/165076/moroccan-diaspora-remittances-reached-11-7-billion-in-2024/](https://www.moroccoworldnews.com/2025/02/165076/moroccan-diaspora-remittances-reached-11-7-billion-in-2024/)retrieved 2026-06-27
- T3[https://www.lightspark.com/knowledge/instant-payments-morocco](https://www.lightspark.com/knowledge/instant-payments-morocco)retrieved 2026-06-27
- T3[https://onyx.ma/moroccos-fintech-startups-reshape-money-in-2025/](https://onyx.ma/moroccos-fintech-startups-reshape-money-in-2025/)retrieved 2026-06-27

### W6Industry Structure & CommercialProbableconfirmed 2026-06-27&#9662;#

The market is bank-centric and historically concentrated: CMI, a consortium of major banks, ran the entire card-acquiring and processing chain (processing 200m+ transactions annually in 2024). The wider PSP base is led by bank-owned payment institutions (Cash Plus, Wafacash, Damane Cash/BCP, Attijari Payment/Attijariwafa, Lana Cash/CIH, M2T) with telcos (Maroc Telecom, Orange, Inwi) participating via partnerships, plus a growing fintech challenger layer (NAPS, Chari, ORA, PayTic, VPS/Payzone). Cash dominance is high (~80% of transactions; currency in circulation ~26% of GDP).

Standing sub-brief · as of 19 August 2026 174 words · last cycle 2026-10-11

#### Industry Structure & Commercial Dynamics

A joint Bank Al-Maghrib/Competition Council communiqué dated 10 July 2026 confirmed that CMI&#x27;s (Centre Monetique Interbancaire) merchant-portfolio transfer to competing acquirers completed on schedule, following an October 2025 extension granted around the Africa Cup of Nations period. The finding is assessed at Probable confidence and marks the structural separation of Morocco&#x27;s card-acquiring market from its former single processor; CMI&#x27;s merchant relationships now sit with a wider set of licensed acquiring operators.

This structural change runs alongside Bank Al-Maghrib&#x27;s interchange-fee cap reduction (see W8) and its first payment-institution licence grant (see W1a), together forming a coordinated liberalisation of market structure, pricing and licensing this cycle.

#### Outlook

With the portfolio transfer completed, the near-term structural question shifts to how the newly enfranchised acquirers compete on pricing and merchant service under the lower interchange ceiling taking effect 1 October 2026. No discrete M&A event was sourced this cycle for Morocco&#x27;s payments industry, and no sourced material was located on scheme or network compliance dynamics (W4) that might follow from the acquiring-market reconfiguration.

Read full sub-brief · 174 words Periodic update · new data 2026-10-11

#### Industry Structure & Commercial Dynamics

Morocco&#x27;s card-acquiring market has completed a structural transition from a mono-acquirer model to a multi-acquirer architecture. Centre Monétique Interbancaire (CMI), the interbank utility that had historically held the acquiring function, and its shareholder banks have exited commercial acquiring following the Conseil de la Concurrence&#x27;s decision of 31 October 2024. Press coverage through September 2026 confirms this unwind as effectively implemented, with multiple licensed payment institutions and bank subsidiaries now acting as acquirers rather than routing merchant acquisition through a single interbank entity. This market-structure shift is the precondition for the October 2026 interchange-cap reduction to function as intended: a cap imposed on a single acquirer would simply have reset that one entity&#x27;s pricing, whereas the same cap applied across a liberalised, multi-acquirer market constrains pricing across competing acquirers simultaneously.

#### Outlook

The completed unwind of CMI&#x27;s acquiring monopoly sets up the next phase of scrutiny: whether the new acquirers compete on service and merchant terms beyond the regulated price ceiling, or whether pricing converges at the cap in the absence of other differentiators.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Evidence 4

Sources and findings (4)
- T3[https://launchbaseafrica.com/2025/11/03/moroccos-fintech-revolution-hits-the-snooze-button/](https://launchbaseafrica.com/2025/11/03/moroccos-fintech-revolution-hits-the-snooze-button/)retrieved 2026-06-27
- T3[https://www.baas.ma/en/blog/paiement-mobile-maroc-maroc-pay](https://www.baas.ma/en/blog/paiement-mobile-maroc-maroc-pay)retrieved 2026-06-27
- T3[https://www.moroccoworldnews.com/2026/02/279409/morocco-launches-stay-cashless-to-digitize-tourism-payments/](https://www.moroccoworldnews.com/2026/02/279409/morocco-launches-stay-cashless-to-digitize-tourism-payments/)retrieved 2026-06-27
- T3[https://onyx.ma/moroccos-fintech-startups-reshape-money-in-2025/](https://onyx.ma/moroccos-fintech-startups-reshape-money-in-2025/)retrieved 2026-06-27

### W7Legal & LitigationConfirmedconfirmed 2026-06-27&#9662;#

The landmark payments-sector enforcement matter is the Competition Council (Conseil de la Concurrence) Decision No. 152/D/2024 against CMI. Triggered by a complaint from NAPS SA, the Council found CMI&#x27;s all-in-one acquiring/processing model anti-competitive and imposed binding commitments dismantling its merchant-acquiring monopoly, requiring CMI to become a &#x27;neutral technical platform&#x27;. The legal basis is Law 104-12 (freedom of prices and competition) and Law 20-13 (Competition Council). Merchant-contract transfer deadlines were extended on 27 Oct 2025 (other contracts by 31 Jan 2026; government contracts by 30 Apr 2026), with daily penalties for missing them.

Horizon · 2026-04 (± a quarter) CMI merchant-contract transfer deadlines (Competition Council Decision 152/D/2024) Adopted, not yet in force · Tier 3 source

Standing sub-brief · as of 27 June 2026 204 words · last cycle 2026-06-27

#### Legal & Litigation

The landmark payments-sector enforcement matter is the Competition Council&#x27;s Decision No. 152/D/2024 against CMI, triggered by a complaint from NAPS SA. The decision found CMI&#x27;s all-in-one acquiring/processing model anti-competitive under Law 104-12 and Law 20-13, imposing binding commitments to dismantle its merchant-acquiring monopoly and to become a &#x27;neutral technical platform&#x27;. From 1 November 2024 CMI could no longer sign new contracts. On 27 October 2025 the deadlines were extended: other merchant contracts must transfer by 31 January 2026 and government contracts by 30 April 2026, with daily penalties for non-compliance. CMI is the respondent and NAPS SA the complainant. The matter rests on a tier-2 Competition Council activity report plus corroborating sources and is Confirmed.

This decision opens Morocco&#x27;s entire merchant-acquiring market to competing payment institutions — it is the single most consequential structural event for payments operators in the jurisdiction, restructuring the entire acquiring market rather than merely sanctioning a single firm.

#### Outlook

The near-term litigation horizon is dominated by the contract-transfer deadlines: non-government merchant contracts by 31 January 2026 and government contracts by 30 April 2026, with daily penalties driving compliance. The decision&#x27;s enforcement trajectory is escalating, and its downstream effects on the acquiring market are tracked under W8.

Read full sub-brief · 204 words no periodic updates on record for this sub-brief

Evidence 4

Sources and findings (4)
- T2[https://www.moroccoworldnews.com/2025/08/255876/competition-council-issues-174-decisions-authorizes-155-mergers-in-2024/](https://www.moroccoworldnews.com/2025/08/255876/competition-council-issues-174-decisions-authorizes-155-mergers-in-2024/)retrieved 2026-06-27
- T3[https://en.yabiladi.com/articles/details/166918/morocco-ends-near-monopoly-opens-electronic.html](https://en.yabiladi.com/articles/details/166918/morocco-ends-near-monopoly-opens-electronic.html)retrieved 2026-06-27
- T3[https://lafroujiavocats.com/en/morocco-fintech-2025-payment-market/](https://lafroujiavocats.com/en/morocco-fintech-2025-payment-market/)retrieved 2026-06-27
- T3[https://www.bremerlf.com/resources/moroccan-competition-council-2024-activity-report](https://www.bremerlf.com/resources/moroccan-competition-council-2024-activity-report)retrieved 2026-06-27

### W8Merchant Acquiring & RiskProbableconfirmed 2026-06-27&#9662;#

Morocco&#x27;s card-acquiring market operates a multi-acquirer architecture under BAM/Conseil de la Concurrence oversight. BAM&#x27;s Décision Réglementaire n°265/W/2026 (6 July 2026) set the domestic interchange cap at 0.50% HT generally (0.15% HT for e-Gov/proximity payments), effective 1 October 2026, replacing the prior 0.65% cap of 20 September 2024.

Horizon · 2026-10-01 (± a quarter) BAM interchange-fee cap reduction takes effect Adopted · Tier 3 source

Horizon · 2026-04-30 (± a quarter) CMI government-contract transfer deadline Adopted, not yet in force · Tier 3 source

Standing sub-brief · as of 19 August 2026 185 words · last cycle 2026-10-11

#### Merchant Acquiring & Risk

Bank Al-Maghrib Decision No. 265/W/2026, dated 6 July 2026, lowers the domestic interchange-fee cap from 0.65% (set in October 2024) to 0.50% effective 1 October 2026, and introduces a special 0.15% ceiling for government-entity payments and proximity commerce. This is assessed at Probable confidence and represents the central bank&#x27;s second interchange-fee intervention in under two years.

CMI was required to transfer approximately 55,000 merchant contracts to licensed acquiring operators by 31 January 2026, with government contracts given an extended deadline of 30 April 2026. That contract-transfer obligation, also assessed at Probable confidence, is the operational counterpart to the portfolio-separation development tracked under W6, and both bank and non-bank acquiring operators are now subject to the same reduced fee ceiling.

#### Outlook

The interchange-fee cap reduction takes effect on 1 October 2026. Its special 0.15% ceiling for government and proximity-commerce merchants suggests continued regulatory attention to lowering acceptance costs for lower-margin merchant segments. No sourced material was located this cycle on consumer protection or APP fraud exposure (W10) arising from the changed acquiring landscape, nor on correspondent banking or settlement access implications (W12).

Read full sub-brief · 185 words Periodic update · new data 2026-10-11

#### Merchant Acquiring & Risk

Bank Al-Maghrib&#x27;s Décision Réglementaire n°265/W/2026 lowers the general domestic card-interchange cap from 0.65% to 0.50% HT, with a preferential cap of 0.15% HT for e-Gov and proximity-merchant payments. The decision took legal effect on 1 October 2026 and replaces the previous cap set on 20 September 2024, applying to both acquiring payment institutions and issuing banks. The cut is confirmed by regulatory reporting and corroborated across multiple press outlets, and it arrives directly on top of the acquiring market&#x27;s shift to a multi-acquirer structure, meaning the lower ceiling applies to a now-competitive population of acquirers rather than a single interbank utility. The preferential 0.15% HT tier specifically targets e-Gov and proximity (low-value, high-frequency) merchant payments, a segment where interchange economics have historically been cited as a barrier to digital acceptance.

#### Outlook

The interchange reduction compresses acquirer margins across the market from 1 October 2026, and the preferential tier for e-Gov and proximity payments is the clearest lever available for pushing merchant acceptance into segments that had previously found card acceptance uneconomic under the higher cap.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Evidence 4

Sources and findings (4)
- T3[https://lafroujiavocats.com/en/morocco-fintech-2025-payment-market/](https://lafroujiavocats.com/en/morocco-fintech-2025-payment-market/)retrieved 2026-06-27
- T3[https://lafroujiavocats.com/en/morocco-fintech-2025-payment-market/](https://lafroujiavocats.com/en/morocco-fintech-2025-payment-market/)retrieved 2026-06-27
- T3[https://www.baas.ma/en/blog/passerelle-paiement-maroc-guide](https://www.baas.ma/en/blog/passerelle-paiement-maroc-guide)retrieved 2026-06-27
- T3[https://payatlas.com/countries/morocco-ma](https://payatlas.com/countries/morocco-ma)retrieved 2026-06-27

### W9Product Innovation & Market Developmentlimited signalProbableconfirmed 2026-06-27&#9662;#

Innovation is BAM-led and inclusion-focused. Maroc Pay is the national interoperable QR mobile-payment standard (operated on HPS Switch; BAM-mandated wallet interoperability via the GP2M economic-interest group) avoiding the closed-silo model. Virement Instantané (GSIMT, June 2023) provides instant interbank transfer. BAM is building the e-Dirham CBDC, migrating to ISO 20022, and in Dec 2025 published a fintech project-holder guide formalising the licensing pathway. A Morocco FinTech Center launched in Jan 2025; open-banking APIs are still nascent.

Horizon · 2026-Q4 (± six months) Open Banking framework expected Proposed · Tier 3 source

Standing sub-brief · as of 19 August 2026 127 words · last cycle 2026-08-19

#### Product Innovation & Market Development

Bank Al-Maghrib has signalled, at Assessed confidence, an intent to introduce an Open Banking framework as part of a wider policy statement that also covers simplified and accelerated fintech licensing and improved regulatory transparency. This is a forward product-access theme rather than a published framework or a launched product; no implementing rules, technical standards or timelines beyond an expected fourth-quarter-2026 window have been sourced.

#### Outlook

The Open Banking framework remains at the proposed stage. Limited signal is available on this item this cycle: it derives from the same central-bank policy statement covering licensing simplification (W1a) rather than from a dedicated Open Banking consultation or draft instrument, so this entry should be read as a watch item rather than a confirmed regulatory development.

Read full sub-brief · 127 words No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Evidence 4

Sources and findings (4)
- T3[https://www.baas.ma/en/blog/paiement-mobile-maroc-maroc-pay](https://www.baas.ma/en/blog/paiement-mobile-maroc-maroc-pay)retrieved 2026-06-27
- T2[https://www.undp.org/sites/g/files/zskgke326/files/2023-05/SDFE%20Assessment%20Morocco%20Report%202023%20Final%203_17Feb.pdf](https://www.undp.org/sites/g/files/zskgke326/files/2023-05/SDFE%20Assessment%20Morocco%20Report%202023%20Final%203_17Feb.pdf)retrieved 2026-06-27
- T3[https://openbanking.ng/open-banking-in-morocco/](https://openbanking.ng/open-banking-in-morocco/)retrieved 2026-06-27
- T3[https://fintechnews.ae/30097/fintech-africa/fintech-startups-from-morocco-to-follow/](https://fintechnews.ae/30097/fintech-africa/fintech-startups-from-morocco-to-follow/)retrieved 2026-06-27

### W10Consumer Protection & APP FraudConfirmedconfirmed 2026-06-27&#9662;#

Consumer protection for financial customers rests on Law 31-08 (consumer protection) and Law 103-12, enforced by BAM through transparency, complaint-handling and recommendation 1/G/2012. The dispute route is internal complaint first, then the Centre Marocain de Médiation Bancaire (CMMB / &#x27;Al Wassit Al Banki&#x27;, created March 2014), a free voluntary out-of-court mediation body chaired by the BAM Governor; mediation extends to payment institutions, and a 2026 expansion brought in consumer-association partnerships. Morocco has no dedicated UK-style APP-fraud mandatory-reimbursement regime; safeguards focus on PSP fraud-monitoring, SARs and PCI/3DS controls.

Standing sub-brief · as of 27 June 2026 189 words · last cycle 2026-06-27

#### Consumer Protection & APP Fraud

Consumer protection in Morocco rests on Law 31-08 and Law 103-12, enforced by BAM. The dispute route requires an internal complaint first, then escalation to the Centre Marocain de Médiation Bancaire (CMMB, &#x27;Al Wassit Al Banki&#x27;), created in March 2014 as a free, voluntary out-of-court mediation body governed by Law 31-08 and Circular 9/W/16; a client may escalate after 40 working days. A May 2026 expansion signed consumer-federation partnerships, and approximately 99% of cases over a two-year period were resolved via mediation. Mediation extends to payment institutions. The regime is anchored in a primary BAM source and is Confirmed.

Morocco operates no UK-style mandatory APP-fraud reimbursement regime — this is treated as not applicable to the regime per absent-field provenance. The mediation-centred dispute resolution, without a mandatory APP-fraud reimbursement obligation, keeps consumer-redress liability lower than UK and EU benchmarks for PSPs.

#### Outlook

The consumer-protection regime is stable, with the May 2026 CMMB expansion broadening mediation reach via consumer-federation partnerships. The structural watch-point is whether the absence of an APP-fraud reimbursement regime persists as the digital-wallet and instant-transfer base grows and authorised-push-payment fraud exposure rises.

Read full sub-brief · 189 words no periodic updates on record for this sub-brief

Evidence 4

Sources and findings (4)
- T1[https://www.bkam.ma/en/Find-information-about/Services-to-customers-of-credit-institutions/Settling-disputes-between-customers-and-credit-institutions/Banking-mediation](https://www.bkam.ma/en/Find-information-about/Services-to-customers-of-credit-institutions/Settling-disputes-between-customers-and-credit-institutions/Banking-mediation)retrieved 2026-06-27
- T2[https://cmmb.ma/en/mediation-rules-of-al-wassit-al-banki/](https://cmmb.ma/en/mediation-rules-of-al-wassit-al-banki/)retrieved 2026-06-27
- T3[https://www.moroccoworldnews.com/2026/05/294119/morocco-signs-deals-to-expand-free-banking-mediation-services-for-consumers/](https://www.moroccoworldnews.com/2026/05/294119/morocco-signs-deals-to-expand-free-banking-mediation-services-for-consumers/)retrieved 2026-06-27
- T1[https://www.bkam.ma/en/Banking-supervision/Protection-of-credit-institutions-customers](https://www.bkam.ma/en/Banking-supervision/Protection-of-credit-institutions-customers)retrieved 2026-06-27

### W11AML/CFT & Financial Crime (Sentinel.gi-fed)1 gapSourced from Sentinel.gi &#8599;Confirmedconfirmed 2026-06-27&#9662;#

sentinel: Morocco&#x27;s AML/CFT posture rests on Law 43-05 (2007) as amended by Law 12-18 (2021), with BAM supervising banks/payment institutions, ANRF/UTRF as the FIU, and ACAPS/AMMC for insurance and capital markets. Morocco exited the FATF grey list in February 2023 after a 15-point action plan; the MENAFATF May 2024 follow-up rated it largely compliant on 28-39 of the 40 Recommendations but it remains in enhanced follow-up. PSPs must run AML/KYC and file SARs.

Open gap — wpm-int-1 No AML/CFT (W11) sentinel-fed development specific to Morocco found this cycle. Emerging-market scheme-rule primary sources under-indexed; aggregator-only sourcing for a structural pricing change.

Standing sub-brief · as of 27 June 2026 223 words · last cycle 2026-06-27

#### AML/CFT & Financial Crime

This module is sourced from the Sentinel feed; the World Payments Monitor carries the finding as provenance only and does not conduct original illicit-finance analysis. Per the Sentinel feed, Morocco exited the FATF grey list in February 2023 after a 15-point action plan. Per MENAFATF&#x27;s May 2024 follow-up, Recommendations 24, 25, 31, 32 and 38 were re-rated to largely compliant and R.15 to partially compliant, giving 39 Recommendations rated compliant or largely compliant; the country remains in enhanced follow-up. AML rests on Law 43-05 (2007) amended by Law 12-18 (2021); BAM supervises banks and payment institutions; UTRF/ANRF is the financial intelligence unit; and ML convictions rose to 134 in 2024 from 74 in 2021. The intelligence is anchored in T1 FATF/MENAFATF sources via the Sentinel feed (sentinel://www.fatf-gafi.org/en/publications/Mutualevaluations/fur-morocco-2024.html).

The FATF grey-list exit lowers correspondent-banking de-risking pressure on Moroccan PSPs, while the enhanced follow-up status keeps the AML compliance burden elevated. Any original illicit-finance, sanctions or beneficial-ownership analysis belongs to the Financial Integrity Monitor and is flagged as a cross-monitor reference, not a World Payments conclusion.

#### Outlook

The AML/CFT position is stable: grey-list exit achieved, broad Recommendation compliance reached, and enhanced follow-up ongoing. The forward dimension for payments operators is the bearing of the grey-list exit on correspondent-banking access, tracked structurally under W12. Detailed illicit-finance trajectory analysis is routed to FIM.

Read full sub-brief · 223 words no periodic updates on record for this sub-brief

Evidence 5

Sources and findings (5)
- T3sentinel://lafroujiavocats.com/en/morocco-fintech-2025-payment-market/
- T?FIM (sentinel.gi) per-JID baseline profile — Morocco — Morocco&#x27;s AML/CFT regime rests on Law 43-05 (as amended by Law 12-18) with UTRF (Unité de Traitement du Renseignement Financier) as FIU using goAML. Removed from FATF grey list in Feb 2023; remains in MENAFATF enhanced follow-up with 39/40 Recommendations rated C/LC as of the 2024 follow-up cycle, but structural gaps persist on cash couriers, beneficial ownership, and virtual assets.
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: sourcing-thinness
- T1FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-002) — Sanctions: OFSI divergence
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: regulatory-failure

### W12Correspondent Banking, Settlement & Access1 gapConfirmedconfirmed 2026-06-27&#9662;#

Large-value settlement runs through SRBM (Système des Règlements Bruts du Maroc), the BAM-operated RTGS established by Governor Circular 14/G/06 (20 July 2006), alongside the SIMT interbank clearing system (GSIMT) for non-card cashless instruments and the electronic/mobile switches operated by HPSS. Settlement-account access and FMI oversight sit with BAM under a multilateral payment-system supervision agreement (Jan 2009). Cross-border FX/settlement is controlled by the Office des Changes; correspondent-banking for remittances historically runs through Banque Populaire&#x27;s European branch network and licensed money-transfer intermediaries (BAM remittance licence since 2007).

Open gap — wpm-int-4 No correspondent-banking/settlement-access (W12) delta for Morocco found this cycle. Emerging-market (Morocco) primary-source availability under-indexed; over-reliance on law-firm and journalism aggregators.

Standing sub-brief · as of 27 June 2026 214 words · last cycle 2026-06-27

#### Correspondent Banking, Settlement & Access

The analytical spine of this module is the asymmetry between bank and non-bank access to settlement and correspondent rails. Large-value settlement in Morocco runs through SRBM (Système des Règlements Bruts du Maroc), the BAM-operated RTGS established by Governor Circular 14/G/06 (20 July 2006), alongside the SIMT/GSIMT interbank clearing system and electronic/mobile switches operated by HPSS. FMI oversight and settlement-account access sit with BAM under a January 2009 multilateral payment-system supervision agreement. This architecture rests on primary T1 sources and is Confirmed.

The bank versus non-bank access distinction is the operative concern. Direct SRBM RTGS and settlement-account access centre on banks, while non-bank operators gain remittance-channel access through a distinct route: cross-border FX and settlement are controlled by the Office des Changes, and independent money-transfer operators are authorised remittance intermediaries under a BAM licence introduced in 2007. The 2007 non-bank money-transfer licence is therefore the structural mechanism through which non-bank operators access the remittance channel without direct RTGS membership.

#### Outlook

The settlement architecture is established. The forward axis is whether the broader liberalisation — PAPSS membership, the acquiring opening and the FATF grey-list exit easing de-risking — translates into widening non-bank access to settlement and correspondent rails, or whether the bank-centric access asymmetry persists despite the opening of downstream acquiring.

Read full sub-brief · 214 words no periodic updates on record for this sub-brief

Evidence 4

Sources and findings (4)
- T1[https://cbpn.currencyresearch.com/blog/2022/02/22/steering-the-evolution-of-payments-in-morocco](https://cbpn.currencyresearch.com/blog/2022/02/22/steering-the-evolution-of-payments-in-morocco)retrieved 2026-06-27
- T1[https://www.bkam.ma/en/Find-information-about/Regulation/Legal-framework-of-payment-systems-and-means](https://www.bkam.ma/en/Find-information-about/Regulation/Legal-framework-of-payment-systems-and-means)retrieved 2026-06-27
- T2[https://gfrid.org/wp-content/uploads/2022/12/Diagnostics_Morocco_e_W.pdf](https://gfrid.org/wp-content/uploads/2022/12/Diagnostics_Morocco_e_W.pdf)retrieved 2026-06-27
- T3[https://www.moroccoworldnews.com/2026/02/277165/moroccos-diaspora-remittances-reached-over-13-3-billion-in-2025/](https://www.moroccoworldnews.com/2026/02/277165/moroccos-diaspora-remittances-reached-over-13-3-billion-in-2025/)retrieved 2026-06-27

### W13Commercial Intelligence (M&A, Investment & Product)Probableconfirmed 2026-06-27&#9662;#

Trailing-12-month commercial activity is dominated by fintech funding and a landmark licensing milestone: Chari secured a record $12m Series A (Oct 2025) and became the first VC-backed startup to win a BAM payment-institution licence; ORA Technologies raised $7.5m Series A (Jul 2025) and acquired Cathedis (Nov 2025); PayTic raised a $4m seed extension (Apr 2025); and AfricInvest&#x27;s FIVE fund moved (Feb 2026) to acquire joint control of payment institution VPS (Payzone/Payexpress). Morocco fintech raised ~$95m across ~40 deals in 2024.

Horizon · 2026-Q1 (± a quarter) AfricInvest/VPS acquisition Competition Council clearance Consultation · Tier 3 source

Horizon · 2026-Q1 (± a quarter) AfricInvest/VPS acquisition Competition Council clearance Consultation · Tier 3 source

Standing sub-brief · as of 19 August 2026 129 words · last cycle 2026-10-25

#### Commercial Intelligence & Fintech

At the Morocco Fintech Booster 2026 closing, Bank Al-Maghrib Director General Abderrahim Bouazza assessed that digital-payment adoption in Morocco remains constrained by limited merchant acceptance, financial-inclusion gaps affecting rural areas and women, and incomplete digitisation of public payments. This is a regulator&#x27;s adoption-barrier assessment delivered at an industry event rather than a discrete commercial event such as a funding round, acquisition or product launch; no such discrete commercial_events were sourced for Morocco this cycle.

#### Outlook

The adoption-constraint assessment frames the practical limits on how quickly Morocco&#x27;s licensing, market-structure and pricing liberalisation (W1a, W6, W8) can translate into higher digital-payment usage. No M&A, funding or product-launch events specific to Morocco were sourced this cycle; signal on this module remains thin relative to the regulatory-action material elsewhere.

Read full sub-brief · 129 words Periodic update · new data 2026-10-25

#### Commercial Intelligence & Fintech

Morocco recorded a single disclosed start-up funding deal valued at one hundred thousand United States dollars in September 2026, a figure that places the country at the bottom of the regional funding ranking for the Middle East and North Africa, tied with Palestine, with Algeria moving ahead of it in the same period. No other payment-institution, e-money-institution, or fintech-specific funding round, merger or acquisition, or notable product launch tied to Morocco was identified in the window under review. This is a narrow commercial data point rather than a comprehensive picture of Morocco&#x27;s digital-finance commercial landscape, since it reflects only disclosed deal activity surfaced in the reporting reviewed and does not capture undisclosed transactions or activity outside the specific funding-round category tracked.

The scale of this figure is worth placing in context: a single six-figure disclosed deal is a modest outcome relative to total regional fintech and start-up funding of over one billion United States dollars reported across the Middle East and North Africa for the same period, and Morocco&#x27;s position at the bottom of the country ranking, alongside Palestine and behind Algeria, indicates that whatever structural or market factors are driving fintech investment elsewhere in the region are not yet translating into comparable disclosed capital formation inside Morocco. This should be read as a data point about the pace of private investment rather than as a comment on the underlying regulatory environment; nothing in the material reviewed ties this funding gap to any specific licensing, authorisation, or market-access constraint, and the Comite des Etablissements de Credit&#x27;s favourable opinions on a ten-text package covered elsewhere in this review suggest regulatory attention is, if anything, continuing to move rather than stalling.

For market participants tracking Morocco&#x27;s digital-finance commercial trajectory, the absence of any identified merger, acquisition, or major product launch, beyond the single funding deal noted, suggests a period of relatively quiet commercial activity rather than a market experiencing a wave of consolidation or new product entry. Whether this reflects a genuine lull in commercial activity or a gap in available public reporting cannot be determined from the material reviewed.

#### Outlook

The principal question going forward is whether Morocco&#x27;s disclosed fintech funding figures recover in subsequent reporting periods, or whether the country continues to lag regional peers in private capital formation for digital-finance ventures. Given the modest disclosed activity, any future large funding round, acquisition, or major product launch involving a Moroccan payment or fintech firm would represent a significant change from the current baseline and should be treated as a notable development when it surfaces.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Evidence 5

Sources and findings (5)
- T3[https://lafroujiavocats.com/en/morocco-fintech-license/](https://lafroujiavocats.com/en/morocco-fintech-license/)retrieved 2026-06-27
- T3[https://fintechnews.ae/30097/fintech-africa/fintech-startups-from-morocco-to-follow/](https://fintechnews.ae/30097/fintech-africa/fintech-startups-from-morocco-to-follow/)retrieved 2026-06-27
- T3[https://www.startupresearcher.com/news/9-moroccan-fintech-startups-to-follow-in-2025](https://www.startupresearcher.com/news/9-moroccan-fintech-startups-to-follow-in-2025)retrieved 2026-06-27
- T3[https://launchbaseafrica.com/2026/02/11/riding-moroccos-fintech-wave-africinvest-moves-to-acquire-vantage-payment-systems/](https://launchbaseafrica.com/2026/02/11/riding-moroccos-fintech-wave-africinvest-moves-to-acquire-vantage-payment-systems/)retrieved 2026-06-27
- T3[https://www.startupresearcher.com/news/9-moroccan-fintech-startups-to-follow-in-2025](https://www.startupresearcher.com/news/9-moroccan-fintech-startups-to-follow-in-2025)retrieved 2026-06-27

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