On October 27, 2025, Morocco’s Competition Council (Conseil de la Concurrence) granted a partial extension to Centre Monétique Interbancaire (CMI) for transferring merchant contracts to newly licensed payment service providers. Decision No. 152/D/2024 establishes new compliance deadlines: government contracts must transfer by April 30, 2026, while all other merchant agreements must complete transfer by January 31, 2026.
This regulatory decision dismantles CMI’s historical monopoly over electronic payment acquisition in Morocco and creates market entry opportunities for foreign financial technology companies seeking to establish operations in the country.
Morocco fintech 2025
Morocco fintech 2025
Morocco fintech 2025
Morocco fintech 2025
Morocco fintech 2025
Morocco fintech 2025
Morocco fintech 2025
Morocco fintech 2025
Morocco fintech 2025
Morocco fintech 2025
Morocco fintech 2025
Legal Background: Competition Council Decision 152/D/2024
The Competition Council’s original decision of November 2024 required CMI to cease all merchant acquiring activities and transfer its portfolio to competing operators. CMI held a dominant position covering approximately 55,000 merchant contracts and operating 65,000 payment terminals across Morocco.
The October 27, 2025 extension modified the original timeline in response to CMI’s request, citing technical complexities in migrating government payment systems. However, the Council maintained strict deadlines and warned that failure to comply would trigger daily penalties.
The legal basis for the Competition Council’s intervention derives from Law No. 104-12 on freedom of prices and competition. Article 7 prohibits abuse of dominant position, which the Council determined CMI violated through exclusionary practices that prevented market entry by competing payment service providers.
Regulatory Framework for Payment Service Providers
Bank Al-Maghrib, Morocco’s central bank and banking regulator, supervises all payment service providers under Law No. 15-95 as amended. The regulatory framework distinguishes between:
Établissements de paiement (Payment Institutions): Licensed entities authorized to provide payment services including merchant acquiring, payment processing, and money remittance. These institutions require minimum capital of MAD 3 million and must meet ongoing prudential requirements.
Établissements de monnaie électronique (Electronic Money Institutions): Similar to payment institutions but additionally authorized to issue electronic money. Minimum capital requirement is MAD 3 million.
Banks: Commercial banks may provide payment services as part of their banking license. Bank Al-Maghrib applies enhanced prudential supervision to banks, including minimum capital requirements of MAD 200 million for conventional banks.
Foreign companies seeking to enter Morocco’s payment market must obtain appropriate licensing from Bank Al-Maghrib. The licensing process requires:
- Submission of detailed business plan
- Demonstration of technical and operational capacity
- Proof of minimum capital requirements
- Background checks on directors and shareholders
- Establishment of local presence (subsidiary or branch)
Bank Al-Maghrib typically requires 6-12 months to process payment institution license applications, subject to the completeness of documentation and regulatory responsiveness of applicants.
Market Structure Post-Liberalization
Three licensed payment service providers have entered the merchant acquiring market following the Competition Council’s decision:
Al Filahi Cash: Licensed payment institution focused on agricultural sector and rural payments. Al Filahi Cash holds a Bank Al-Maghrib authorization granted in 2024.
Attijari Payment Services: Payment subsidiary of Attijariwafa Bank, Morocco’s largest commercial bank. This entity operates under a payment institution license separate from its parent bank’s license.
Damane Cash: Payment institution established by Banque Centrale Populaire group. Damane Cash received regulatory approval in 2024 to provide acquiring services.
These three operators must receive transferred merchant contracts from CMI by the January 31, 2026 deadline. CMI will transform into a neutral technical platform providing switching and clearing services without direct merchant relationships.
The new market structure separates payment processing infrastructure (CMI’s residual role) from merchant acquiring services (provided by competing operators). This separation aligns with European payment services regulations, particularly the EU’s Payment Services Directive (PSD2) framework.
Considering payment market entry in Morocco? Our banking and finance practice advises on regulatory compliance for payment service providers. Contact Cabinet Lafrouji Avocats at +212 (5) 22 47 55 29.
Interchange Fee Reduction Requirements
The Competition Council’s decision mandates significant reductions in interchange fees—the fees paid by merchants’ banks to cardholders’ banks for processing card transactions. Prior to the decision, interchange fees ranged from 1.20% to 1.30% of transaction value for domestic card payments.
Under the new regulatory framework, interchange fees have decreased to 0.65% of transaction value, representing a 40% reduction. This reduction directly affects merchants’ payment acceptance costs, making electronic payments more economically viable for retailers and service providers.
The interchange fee structure now includes:
- Domestic debit card transactions: 0.65% maximum
- Domestic credit card transactions: 0.65% maximum
- Online transactions: Subject to same caps as card-present transactions
Bank Al-Maghrib monitors compliance with these fee caps and has authority to impose sanctions on payment service providers that charge excessive rates.
Merchant Contract Transfer Process
CMI must complete the transfer of approximately 55,000 merchant contracts to licensed acquiring operators by January 31, 2026, with government contracts receiving an extended deadline of April 30, 2026. The transfer process involves:
Contract Assignment: CMI must obtain merchant consent for contract assignment to new acquiring operators. Under Moroccan contract law (Dahir of Obligations and Contracts), contract assignments require debtor consent unless waived by contract terms.
Terminal Migration: Physical payment terminals must be replaced or reprogrammed to connect to new acquiring operators’ systems. This technical migration requires coordination between CMI, acquiring operators, and terminal manufacturers.
Merchant Communication: Acquiring operators must inform merchants of new terms, conditions, and fee schedules. Merchants retain the right to reject proposed terms and select alternative acquiring operators.
Data Transfer: Merchant data, transaction history, and settlement information must transfer securely in compliance with Law No. 09-08 on personal data protection.
The Competition Council has indicated it will monitor transfer progress through quarterly reporting requirements. Failure to meet the January 31, 2026 deadline exposes CMI to daily penalties, though the specific penalty amount was not published in the decision.
Licensing Requirements for Foreign Entrants
Foreign financial technology companies seeking to enter Morocco’s payment market have three structural options:
Direct Licensing: Establish a Moroccan payment institution by incorporating a Moroccan legal entity (SARL or SA) and applying for a payment services license from Bank Al-Maghrib. This approach requires:
- Minimum paid-up capital of MAD 3 million deposited in a Moroccan bank
- At least two directors resident in Morocco
- Detailed operations manual and risk management procedures
- Cybersecurity certification from Morocco’s Direction Générale de la Sécurité des Systèmes d’Information (DGSSI)
- Compliance with anti-money laundering regulations under Law No. 43-05
Partnership Structures: Partner with an existing licensed Moroccan payment institution through commercial agreements. Foreign companies may provide technology platforms, processing services, or card scheme connections to licensed Moroccan entities without obtaining separate licenses.
Acquisition: Acquire an existing licensed payment institution in Morocco. This approach requires Competition Council approval if the transaction meets merger control thresholds (combined annual revenue exceeding MAD 750 million globally or MAD 250 million in Morocco for at least two parties).
Each structure presents different regulatory, capital, and operational requirements. Foreign entrants must evaluate these options based on their expansion strategy, risk tolerance, and commitment to the Moroccan market.
Data Localization and Cybersecurity Requirements
Morocco has implemented data localization requirements for payment data under Bank Al-Maghrib regulations. Payment service providers must:
Store payment transaction data on servers located in Morocco: Card data, merchant data, and transaction records must remain within Moroccan territory. Bank Al-Maghrib permits limited exceptions for cross-border processing when technically necessary for international card schemes.
Obtain DGSSI cybersecurity certification: All payment systems must receive approval from Morocco’s cybersecurity authority. The certification process evaluates:
- Network architecture and security controls
- Incident response procedures
- Business continuity planning
- Employee security training programs
Comply with PCI-DSS standards: Payment Card Industry Data Security Standard compliance is mandatory for all entities handling cardholder data. Bank Al-Maghrib requires annual PCI-DSS compliance validation by qualified security assessors.
These technical requirements create barriers to entry for foreign payment providers accustomed to centralized, cloud-based processing architectures. Companies must invest in local infrastructure or partner with Moroccan data center providers.
Anti-Money Laundering Obligations
Payment service providers in Morocco must comply with Law No. 43-05 on anti-money laundering and counter-terrorism financing. The Financial Intelligence Unit (Unité de Traitement du Renseignement Financier – UTRF) supervises AML compliance.
Key obligations include:
Customer due diligence: Payment institutions must identify and verify all customers (merchants and payment service users) using reliable documentation. Enhanced due diligence applies to politically exposed persons and high-risk customers.
Transaction monitoring: Automated systems must detect suspicious transactions. Payment institutions must file suspicious transaction reports with UTRF when transactions lack apparent economic justification.
Record retention: Customer identification records and transaction documentation must be retained for ten years following the end of the business relationship.
Training programs: Payment institutions must train employees on AML obligations and red flag indicators.
Non-compliance with AML requirements can result in administrative fines up to MAD 500,000 and potential criminal prosecution for serious violations.
Market Opportunities for Foreign Investors
The payment market liberalization creates several entry points for foreign financial technology companies:
Merchant acquiring services: The transfer of 55,000 merchant contracts creates opportunities for established international payment processors to enter Morocco through partnerships or licensing.
Value-added services: Payment institutions may offer ancillary services including loyalty programs, payment analytics, fraud prevention, and working capital financing to merchants.
E-commerce payment gateways: Morocco’s growing e-commerce sector requires specialized online payment solutions. Bank Al-Maghrib has streamlined licensing for online payment facilitators.
Mobile payment services: Mobile money and contactless payment adoption is increasing. Payment institutions may develop mobile wallet solutions and contactless acceptance infrastructure.
The January 31, 2026 deadline for contract transfers creates timing urgency for foreign companies evaluating market entry. Early entrants can establish relationships with merchants during the transition period and potentially acquire portions of CMI’s merchant base.
Regulatory Risk Factors
Foreign payment companies should consider several regulatory risks:
License modification requirements: Bank Al-Maghrib must approve material changes to payment institutions’ business models, technology platforms, or service offerings. This approval process can delay product launches.
Foreign exchange controls: Morocco maintains capital controls under Office des Changes regulations. Payment institutions must comply with currency transfer restrictions and obtain approvals for cross-border settlement flows.
Consumer protection regulations: Bank Al-Maghrib enforces strict consumer protection rules for payment services, including transparency requirements, dispute resolution procedures, and liability allocation for unauthorized transactions.
Regulatory change: Morocco’s payment services regulatory framework continues to evolve. Recent amendments have introduced licensing for payment aggregators and open banking requirements.
Navigate Morocco’s Payment Market Regulations with Specialized Legal Counsel
Payment market liberalization in Morocco creates commercial opportunities but requires careful navigation of licensing requirements, competition regulations, data protection obligations, and ongoing compliance duties. Foreign companies face particular challenges related to licensing procedures, local presence requirements, and operational constraints.
Cabinet Lafrouji Avocats provides comprehensive legal services for payment service providers:
- Licensing applications: Prepare and submit payment institution license applications to Bank Al-Maghrib, including business plans, operational manuals, and shareholder documentation
- Regulatory compliance: Establish compliance frameworks for AML, data protection, cybersecurity, and consumer protection requirements
- Partnership agreements: Structure and negotiate commercial agreements with licensed Moroccan payment institutions
- Competition law: Advise on Competition Council notification requirements for acquisitions and analyze potential competition law issues
- Contract negotiations: Represent clients in merchant acquiring agreements, processing agreements, and card scheme participation agreements
Our banking and finance practice has extensive experience advising financial institutions and technology companies on Moroccan payment services regulations.
Contact us to discuss your payment market entry strategy:
Cabinet Lafrouji Avocats
64 rue Taha Houssein
20000 Casablanca – Maroc
Telephone: +212 (5) 22 47 55 29
Email: contact@lafroujiavocats.com
Disclaimer: This article provides general information about Moroccan payment services regulations and does not constitute legal advice. Companies should consult qualified legal counsel to assess their specific licensing and compliance obligations.
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