For a long time, payment terms between Moroccan businesses were almost exclusively a matter of commercial negotiation and the balance of power between partners. Law 69-21 has reshuffled the deck.

Published in the Official Bulletin on June 15, 2023, this law introduces capped payment terms, a periodic self-declaration obligation, and a system of financial sanctions. In 2026, the reform reaches maturity: after a gradual rollout begun in 2023, it now covers nearly the entire Moroccan economic fabric, including players who initially believed they were not concerned — holding companies, regulated professions, and small structures that have recently crossed the turnover threshold.

This guide provides a complete overview of the framework, its scope of application, its declarative obligations, its sanctions, and above all how to comply with it with peace of mind.

Why was this law adopted?

Excessive payment terms are, in many economies, one of the leading causes of small and medium enterprise failure. An SME that must wait 150 or 180 days to be paid by a large client effectively ends up financing that client's cash flow — sometimes at the cost of its own survival.

Morocco has not escaped this phenomenon. Several economic studies pointed out, before the law was adopted, average payment terms noticeably longer than in other comparable economies, with an effect that varied by company size: the smaller a company, the more it suffers the terms imposed by its clients, with no real bargaining power.

Law 69-21 is therefore part of a broader effort to rebalance commercial relationships, alongside other reforms aimed at structuring Morocco's business environment (the rollout of electronic invoicing, the corporate tax reform, and the digitalization of tax procedures).

Scope of application: who is affected in 2026?

The law applies to any individual or legal entity, whether governed by private or public law, carrying out a commercial activity, whose annual turnover before tax exceeds 2 million dirhams. Public enterprises operating in a commercial capacity are also covered.

The legislator chose a gradual phase-in, starting with the largest structures:

  • Annual turnover before tax above MAD 50,000,000 ➡️ effective July 1, 2023;
  • Between MAD 10,000,000 and 50,000,000 ➡️ effective January 1, 2024;
  • Between MAD 2,000,000 and 10,000,000 ➡️ effective January 1, 2025.

Since January 1, 2025, this third and final phase has been in effect: all businesses exceeding the 2-million-dirham turnover threshold are now covered by the framework, representing a very large share of the Moroccan economic fabric, including VSEs and SMEs.

The DGI's decisive clarification (March 2026)

One point had long been debated: certain categories of players believed they could escape the framework due to the nature of their activity or their legal status. The Direction Générale des Impôts (DGI) settled this question in an official position dated March 27, 2026 (ref. D 326/26/DGI): Law 69-21 provides for no sectoral exclusion.

The following are therefore explicitly subject to the framework, once their turnover exceeds the applicable threshold:

  • Holding companies, including those whose accounting turnover consists mainly of dividends received from their subsidiaries;
  • Professional civil companies (sociétés civiles professionnelles, SCP) exercising a regulated profession, whether medical professions referred to in Article 91-VI-1° of the CGI (physicians, laboratories, clinics) or professions referred to in Article 89-I-12° (lawyers, architects, engineers, consultants, etc.);
  • Non-trading individuals practicing as sole practitioners (private physicians, consultants, etc.).

This clarification has considerable practical implications. Many wealth-holding companies, law firms organized as SCPs, or clinics structured as civil companies believed themselves outside the scope. This is not the case. The turnover to be considered is understood in the commercial sense: it corresponds to the volume of business generated according to the nature of the activity, regardless of the accounting method used — for a liberal profession, this typically means fees and revenue generated in the course of professional activity.

📌 Practical implication: if you run a holding company, an SCP, or a liberal-profession practice with turnover exceeding 2 million dirhams, it is essential to check your status under this law now, rather than discovering a breach during an audit.

The three payment-term regimes

The law distinguishes three levels of terms, depending on how formalized the commercial relationship is:

  • The legal term (default) — 60 days ➡️ in the absence of any agreement between the parties, payment must be made within a maximum of 60 days from the invoice issue date.
  • The contractual term — 120 days ➡️ when business partners expressly agree to it (contract, general terms and conditions of sale, framework agreement), this term can be extended up to 120 days, with no possibility of exceeding it.
  • The sectoral term — 180 days ➡️ for certain sectors of a specific or seasonal nature, an exceptional term of 180 days may apply, under the conditions set out in the implementing texts.

An essential technical point: when the term starts running

Unlike previous practice, where the count often began upon receipt of the goods or completion of the service, Law 69-21 sets the starting point at the invoice issue date.

To prevent any artificial delay of this deadline through deliberately late invoicing, the law requires the seller to issue the invoice no later than the last day of the month in which the goods were delivered or the service performed. If no invoice is issued within that period, the count of 60, 120 or 180 days automatically starts at the end of that same month.

Concrete example: a consulting service is performed on March 5. If the invoice is issued on March 31 (the last day of the month), the 60-day payment term runs from that date, with a deadline at the end of May. If the provider is late and issues the invoice only in April, the term is nonetheless deemed to run from March 31 — the late invoicing date does not push back the deadline.

The declarative obligation: the often-underestimated component

Beyond simply respecting the payment terms, the law imposes a periodic self-declaration of supplier debts to the tax authorities, via the DGI's SIMPL platform. This component, less well known than the payment-term cap itself, is what exposes the most businesses to sanctions — often simply out of unfamiliarity.

Declaration frequency by turnover

  • Turnover > MAD 10 M ➡️ declaration already underway (since previous phases), quarterly frequency;
  • MAD 2 M < turnover ≤ 10 M, threshold exceeded in 2024 (reference fiscal year) ➡️ annual declaration before April 1, 2026, covering 2025 invoices, then quarterly from Q1 2026;
  • MAD 2 M < turnover ≤ 10 M, threshold exceeded in 2025 (reference fiscal year) ➡️ directly quarterly: Q1 2026, before April 30, 2026, then quarterly.

Three concepts should be clearly distinguished to avoid any scheduling confusion:

  • The reference fiscal year: the last closed fiscal year, used to check whether the 2-million-dirham threshold has been exceeded;
  • The year of applicability: the year during which the law actually applies to invoices issued;
  • The declaration period: the year during which the declaration must physically be filed.

What the declaration must contain

Each declaration, whether quarterly or annual, must be accompanied by a detailed statement of invoices exceeding the legal payment terms. This document is not a mere administrative formality: it must be certified by an authorized professional, whose identity depends on the declaring company's turnover:

  • Turnover ≥ MAD 50,000,000 ➡️ certified by a statutory auditor;
  • Turnover < MAD 50,000,000 ➡️ certified by a chartered accountant or an accredited accountant.

This professional certification engages the signatory's responsibility as to the reliability of the declared data. It is therefore not a mere formal check, but a genuine certification engagement, which must be based on a rigorous review of the accounts-payable ledger and payment deadlines.

A common trap: the "nil declaration"

One point deserves particular emphasis: the declaration remains mandatory even in the absence of any overdue invoice. Many businesses, convinced they are compliant with their suppliers, neglect to file a declaration simply because they have "nothing to declare." Yet failing to file — including a "nil" declaration — is in itself a sanctionable breach.

Another development worth noting: since January 1, 2025, invoices below 10,000 dirhams, previously excluded from the framework, must now be included in the declarative scope.

The sanctions regime

Law 69-21 provides for two categories of sanctions, which can be cumulative and should be clearly distinguished.

Sanctions related to actual late payment

When a business fails to settle an invoice within the applicable legal, contractual or sectoral term, a fine is owed to the Treasury, calculated on the unpaid amount:

  • for the first month of delay: Bank Al-Maghrib's key rate, currently set at 2.25%;
  • for each additional month of delay: a surcharge of 0.85% is added to the previous rate.

This fine is paid spontaneously by the debtor company, together with the filing of its declaration. An important mitigating factor: invoices subject to ongoing litigation are not subject to this fine while the dispute is being resolved.

Sanctions related to the declaration itself

Regardless of whether payment terms are respected, simply filing the quarterly or annual declaration late, or not at all, exposes the business to a flat-rate fine, the amount of which depends on its turnover:

  • MAD 2,000,000 < turnover ≤ 10,000,000 ➡️ MAD 5,000;
  • MAD 10,000,000 < turnover ≤ 50,000,000 ➡️ MAD 12,500;
  • MAD 50,000,000 < turnover ≤ 200,000,000 ➡️ MAD 50,000;
  • MAD 200,000,000 < turnover ≤ 500,000,000 ➡️ MAD 125,000;
  • Turnover > MAD 500,000,000 ➡️ MAD 250,000.

This progressive scale illustrates a clear logic on the part of the legislator: the larger the business, the more heavily a declarative breach is sanctioned, on the assumption that the largest structures have the administrative resources needed to comply without difficulty.

What this reform changes in practice for businesses

A new invoicing discipline. The law effectively imposes greater rigor in issuing invoices. A business that was in the habit of invoicing late, or in batches at the end of the month or even the end of the quarter, must review its internal processes: the invoicing date becomes a legally structuring piece of data, directly determining the start of the payment term and, ultimately, exposure to a potential fine.

A governance issue for holding companies. For groups structured around a holding company, the DGI's March 2026 clarification requires a full review of intragroup flows. Cash-pooling agreements, management-fee invoicing, or the recharging of shared costs between a parent company and its subsidiaries must now incorporate this time constraint, or risk exposing the holding company — sometimes wrongly seen as a mere wealth-holding structure — to sanctions identical to those faced by an operating company.

A new issue for liberal professions organized as companies. Law firms, architecture or engineering-consulting practices, and medical structures organized as professional civil companies must also incorporate this new framework. This often requires adapting client invoicing practices (payment terms for fees) and supplier invoicing, as well as documented tracking of deadlines, even though these professions were historically unfamiliar with this type of periodic declarative obligation.

A compliance burden that calls for professional support. The combination of rigorous term tracking, the periodic declarative obligation, and the need for external professional certification (chartered accountant, accredited accountant or statutory auditor) turns this into a genuine recurring compliance process, on a par with VAT returns or the annual tax return package. It is no longer an occasional matter, but a cyclical obligation to be built into the business's tax and accounting calendar.

Practical compliance checklist

For any business, holding company or liberal-profession practice with turnover exceeding 2 million dirhams, here are the points to check without delay:

  • Verify your liability: confirm, based on the last closed fiscal year, whether the MAD 2 M threshold is exceeded, and since which fiscal year.
  • Identify the applicable declaration frequency (quarterly or transitional annual) and the resulting precise schedule.
  • Set up monitoring of the accounts-payable ledger to isolate, at any time, invoices exceeding the payment term.
  • Review client invoicing processes to ensure invoices are issued no later than the last day of the month of delivery or performance.
  • Audit intragroup flows (for holding companies) and invoicing agreements between associated professionals (for SCPs).
  • Plan ahead for certification of the detailed statement of overdue invoices with your chartered accountant or statutory auditor, before each filing deadline.
  • Never omit the "nil" declaration, even when no delay has been identified.

Frequently asked questions

What are the legal payment terms in Morocco in 2026?
Three terms coexist: 60 days by default from the invoice date, 120 days under a contractual agreement between the parties, and 180 days exceptionally for certain specific or seasonal sectors.

Is a wealth-holding company affected?
Yes. The DGI's position of March 27, 2026 explicitly confirms that holding companies are subject to Law 69-21 once their turnover exceeds the applicable threshold, including when that accounting turnover consists mainly of dividends.

Must a physician or lawyer practicing through a professional civil company declare their payment terms?
Yes, if their turnover exceeds 2 million dirhams. The DGI has expressly included medical professions and the regulated professions referred to in the CGI within the law's scope of application.

What happens if I have no overdue invoices?
The declaration remains mandatory. Failing to file, even with no delay whatsoever, exposes the business to a fine for non-declaration.

Who can certify the statement of overdue invoices?
A statutory auditor for businesses whose turnover reaches or exceeds 50 million dirhams; a chartered accountant or an accredited accountant below that threshold.

Conclusion

Law 69-21 marks a turning point in how commercial relationships between Moroccan businesses are managed. In 2026, with its now-widespread application and the DGI's clarification regarding holding companies and regulated professions, it covers a much broader range of players than initially thought.

Complying with payment terms is no longer merely good management practice: it is a legal, documented and sanctioned obligation, now firmly embedded in every business's regular tax and accounting calendar. Support from a chartered accountant helps secure compliance and confidently anticipate each filing deadline.