Regulatory overview
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MoroccoMorocco is preparing a digital-asset framework through Bill 42.25, but enactment and an operational licensing pathway have not been confirmed. The proposal distinguishes services, issuance and trading, with responsibilities for AMMC and Bank Al-Maghrib. Foreign-exchange controls and official warnings remain central to structuring operations. Proposed legislation does not establish permission, and excluding certain assets from its scope does not make the corresponding activities unrestricted.
A business seeking investment through tokens in Morocco must separate two questions: the transaction’s current treatment and the proposed digital asset framework. Bill 42.25 describes a regulatory route, but a proposal does not justify budgeting for a licence as though it were already available.
Beyond asset classification, payments, participants’ residence and foreign-exchange flows matter. A tokenization project therefore needs to check the right it will issue and its financial flows against current rules, even where an activity falls outside the draft’s scope.
What Bill 42.25 proposes and what remains pending
Morocco retains a restrictive approach to virtual-currency transactions. The joint warning published by the Office des Changes identifies their unauthorised use as payment instruments and financial and money-laundering risks. This communication must be read alongside applicable foreign-exchange and financial rules; it does not establish a universal prohibition on blockchain software development or every digitally represented right.
Bill 42.25 published by the General Secretariat of Government proposes a specific framework. Article 79 links commencement to publication in the Bulletin officiel. That enactment has not been confirmed at this review's cut-off. The AMMC's 2026 priorities describe finalising the framework as continuing work, rather than an already available authorisation.
Which supervisors are involved by activity
Article 5 of the proposal would give the Autorité Marocaine du Marché des Capitaux, AMMC, responsibility for providers, utility tokens and admission to trading of asset-referenced tokens. Bank Al-Maghrib would oversee issuers, issuance and offers of the latter. This proposed allocation must not be presented as identical operational authority over every token category.
The Office des Changes oversees foreign-exchange compliance. The Autorité Nationale du Renseignement Financier, ANRF, already exists: the AMMC's 2021 report explains that Law 12-18 replaced the UTRF name and redefined its responsibilities. The digital-asset proposal does not establish this authority for the first time. The AMMC's AML guide identifies the legal framework and implementing instruments.
Which requirements the proposed entry route contains
Articles 8 to 11 of Bill 42.25 envisage a company headquartered in Morocco, paid-up capital, suitable managers and organisational, technical and financial resources. Prior AMMC authorisation would cover specified services: custody, trading, exchange, execution, placement, reception and transmission of orders, advice, management and transfers. Capital details and certain conditions would depend on implementing provisions.
These requirements support future establishment planning, not an announced licensing date or immediate operations. Nor has the eighteen-month transition proposed in Article 78 started merely because the draft was published. Before acquiring customers, planning must verify enacted wording, commencement, implementing rules, an open application process and any additional financial or foreign-exchange permissions.
Which rights and assets fall within the perimeter
Article 4 of the official proposal excludes financial instruments and equivalent digital assets, alongside unique NFTs, central-bank digital currency, mining and decentralised finance. Falling outside this proposal does not remove securities, property, contract or payment rules. Describing a platform as DeFi likewise does not establish a legal exemption.
Tokenizing securities, land or receivables requires identifying the transferred right and its issuance, registration and enforceability rules first. Holding a token does not itself establish registered ownership or insolvency protection. A technological definition of digital assets does not replace formalities applicable to the underlying asset or represented financial instrument.
How payments and foreign exchange constrain operations
The Office des Changes confirms that IGOC 2026 applies from 1 January. This instruction regulates foreign-exchange operations; it does not itself authorise digital-asset services. Article 7 of the proposal expressly preserves foreign-exchange compliance. Issuance, collection, currency conversion and cross-border transfers therefore require coordinated analysis of fund flows.
Article 2 of the proposal denies in-scope assets legal-tender and payment-instrument status, including asset-referenced tokens. Proposed stablecoin treatment must not be interpreted as general permission to settle commercial obligations. Operational design should distinguish trading, custody, customer rights and payments, while planning identification, risk, security and traceability controls.
What to resolve before structuring an issuance
Prepare a map of rights, participants and fund flows before deciding where to issue or hold assets. For a property or corporate investment, explain which contract, interest or security the investor receives and how it can be enforced; the token alone does not resolve that legal relationship.
Planning must distinguish current obligations from conditions proposed in Bill 42.25. Check its legislative status, applicable foreign-exchange rules and providers’ regulatory position before committing to a commercial date or presenting a future licence as available.
To understand how this framework applies to your project, discuss your case with our team.
Key takeaways
- Bill 42.25 is not equivalent to enacted legislation or an available licence.
- AMMC and Bank Al-Maghrib would have different activity-specific responsibilities.
- Proposed exclusions for DeFi, unique NFTs and securities provide no general exemption.
- Foreign-exchange rules require analysis independent of token and provider classification.
Blockchain development in Morocco
Regulatory milestones
Financial-intelligence reform
Law 12-18 renames UTRF as ANRF and redefines its responsibilities.
Proposed digital-asset framework
Bill 42.25’s presentation note is dated 5 August; it does not establish enactment.
IGOC 2026 applies
The new foreign-exchange instruction applies from 1 January without constituting digital-asset licensing.
Frequently asked questions
Enactment and an operational licensing procedure have not been confirmed. The draft and AMMC priorities describe the proposed framework; official publication, commencement and implementation must be verified before providing services.
No. Article 4 excludes them from the proposed perimeter under specified conditions, but does not repeal securities, property, contract, payment or foreign-exchange rules applicable to the project.
No. Bill 42.25 proposes a transition, but that period cannot be treated as running without establishing commencement of the final text.
That should not be assumed. IGOC 2026 regulates foreign-exchange transactions and must be considered alongside the project’s financing model, residence and payments.
No. AMMC’s 2021 annual report describes the Law 12-18 reform that replaced the UTRF name with ANRF. Its existence does not establish adoption of Bill 42.25.
