Morocco’s Critical Minerals Position
Morocco holds approximately 70% of the world’s known phosphate reserves and is rapidly developing copper, cobalt and manganese extraction capacity. In 2025, the Ministry of Energy Transition and Sustainable Development introduced comprehensive ESG requirements for new mining concessions, fundamentally reshaping investment due diligence for international mining companies.
New ESG Requirements for Mining Concessions
Miners seeking exploration permits or exploitation authorizations under the Mining Code (Law 33-13) must now submit an ESG Management Plan alongside their technical dossier. This plan must address: environmental baseline assessment and progressive rehabilitation commitments, water usage and circular economy measures (critical in arid southern regions), community benefit-sharing mechanisms for host communities, and supply chain due diligence aligned with OECD Guidance for Responsible Minerals Sourcing.
EU CSDDD Compliance for Export-Oriented Projects
Mining projects targeting European buyers must additionally prepare for the EU Corporate Sustainability Due Diligence Directive (CSDDD) requirements taking effect progressively from 2026. EU importers of Moroccan minerals will need documented supply chain due diligence from their Moroccan suppliers, creating compliance obligations that run through the entire extraction and processing chain.
Investment Structuring Considerations
Foreign mining investors typically structure their Moroccan operations through a Moroccan SA or SARL holding the mining permit, with a technical services agreement providing management and technical expertise. The OCP Group model of integrated extraction-processing-logistics is increasingly the benchmark for institutional investors evaluating Moroccan mining assets.
Our firm advises international mining companies on regulatory compliance, permit structuring and ESG governance in Morocco.
