Guide de Bank Al-Maghrib sur le parcours réglementaire des porteurs de projets fintech (2025) (Bank Al-Maghrib Guide on the Regulatory Pathway for Fintech Project Holders (2025))

In December 2025 Bank Al-Maghrib published a public guide setting out the regulatory pathway for fintech project holders in Morocco. The guide is an explanatory, non-binding supervisory document intended to give entrepreneurs, start-ups and established operators clarity on how fintech initiatives interact with the central bank and on the steps required for regulatory consultation, authorisation or licensing. It addresses a recurring difficulty in emerging fintech markets: would-be operators are often unsure whether their proposed activity falls within a regulated perimeter (for example, payment services, electronic money, or other activities supervised by Bank Al-Maghrib) and, if so, which licence or approval applies and how to obtain it. The guide maps the relevant regulatory categories, notably the payment-institution regime under Law No. 103-12 and its implementing circulars, and explains the process for engaging with the central bank, the documentation expected, and the criteria against which projects are assessed. By formalising an accessible entry point and consultation route, it is designed to reduce regulatory uncertainty, encourage responsible innovation, and channel fintech projects toward the appropriate licensing or supervisory track. The guide complements, rather than replaces, the binding instruments: the substantive licensing requirements remain those set out in Law No. 103-12, Circular No. 5/W/15 on licensing documentation, and the sector frameworks for payment institutions and mobile payment. It also signals Bank Al-Maghrib's broader supervisory posture toward fintech, including its openness to dialogue with innovators and its intention to provide structured guidance ahead of, or in place of, more prescriptive rulemaking where appropriate. As guidance, it does not itself create new obligations or sanctions; enforcement continues to flow from the underlying statutory and regulatory framework administered by Bank Al-Maghrib. The guide is best read as a navigational and transparency instrument that lowers the barrier to regulatory engagement for Morocco's growing fintech sector. (Original language: French.)

1. 1Sets out the regulatory pathway and consultation route for fintech project holders engaging with Bank Al-Maghrib
2. 2Helps operators determine whether a proposed activity falls within a regulated perimeter (e.g. payment services, e-money)
3. 3Maps applicable regulatory categories, including the Law No. 103-12 payment-institution regime and implementing circulars
4. 4Explains expected documentation and assessment criteria for authorisation or licensing
5. 5Non-binding guidance that complements, and does not replace, the underlying statutory and regulatory requirements
6. 6Signals Bank Al-Maghrib's supervisory openness to responsible fintech innovation