Morocco

Other Developments

Beyond the licensing track, Draft Law 42.25 carries detail across three other modules this cycle. On token classification, the bill would define crypto-assets as digital representations of value or rights transferable via distributed ledger technology, and would draw a distinction between utility tokens and asset-referenced tokens — a taxonomy modelled on the European Union's Markets in Crypto-Assets framework, according to secondary legal commentary (CLM-MA-004). No statutory classification scheme is in force today, so this remains prospective rather than operative. On the stablecoin side, the same draft would impose securities-style disclosure obligations, including a white paper requirement, on issuers of asset-referenced tokens (CLM-MA-005); nothing of the kind currently binds issuers inside Morocco. On-chain activity treatment is the thinnest module this cycle: a single secondary source reports that the bill explicitly excludes decentralised finance activity from its scope, but this has not been checked against the primary bill text and is carried as uncertain pending that verification (CLM-MA-006).

Tax treatment saw a parallel secondary-source claim this cycle: commentary reports a flat 15% individual capital-gains rate applying to crypto trading profits under the current Finance Law, but this rests entirely on a single T4 vendor source and has not been corroborated against a primary Direction Générale des Impôts circular (CLM-MA-007). Cross-border transfer remains governed by the same instrument underpinning the licensing gap — the Office des Changes' exchange-control regime, which the 2017 communiqué invoked as the legal basis for treating virtual-currency transactions as a breach of foreign-exchange rules (CLM-MA-008); this constraint predates and is independent of Draft Law 42.25's progress.

Two modules carried no new sourced findings this cycle. Consumer protection has no Morocco-specific crypto rule identified in the current source base, and the AML/CFT module continues to be rendered from the financial-integrity monitor's subscribed feed rather than first-party crypto research.

Cross-Monitor Connections

Two cross-monitor linkages carry forward from this cycle. The licensing and stablecoin material in Draft Law 42.25 is flagged as directly relevant to the financial-integrity monitor's tracking of Morocco's digital-asset integrity posture, given the bill's bearing on how crypto-asset service providers would be brought inside a supervised perimeter. Separately, the stablecoin and asset-referenced-token disclosure provisions are flagged as payments-adjacent and relevant to the world-payments monitor's subscribed coverage, since any future issuance regime would intersect with payment-instrument questions those readers track. Neither flag reflects a change in Morocco's substantive crypto posture on its own; both mark Draft Law 42.25 as a single instrument whose eventual enactment would ripple across sibling monitors' domains simultaneously rather than module by module.

Outlook

The near-term trajectory is one of continued drafting without a committed legislative calendar: the regulatory horizon carries Draft Law 42.25 at a consultation stage with an expected timeframe of 2027 and a multi-year uncertainty band, meaning the bill could move earlier or later without disturbing this cycle's assessment. Three questions remain open going into the next cycle: whether the bill has progressed beyond committee or technical-committee review toward a parliamentary reading since its November 2025 publication; what the primary Direction Générale des Impôts text actually says about crypto capital-gains and mining-income treatment, as opposed to secondary commentary's flat-rate claim; and whether the bill's final text in fact carries the reported DeFi carve-out, which today rests on a single unverified secondary source. Until Draft Law 42.25 is enacted, Morocco's binding crypto position stays anchored to the 2017 exchange-control communiqué, and every module built on the draft bill — licensing, token classification and stablecoin treatment alike — remains prospective rather than operative. The overall judgment for this cycle is that Morocco's regime is in transition: stable in its current, restrictive form, with visible but still unenacted momentum toward a MiCA-inspired framework.

Standing brief · as of 5 October 2026

Written before the update above. Where they differ, the update is the more recent position.

Lead Signal

Morocco's crypto regime sits at an unresolved junction this cycle. The formal prohibition on cryptocurrency ownership and trading imposed by the Office des Changes in 2017 remains legally in force, restated without qualification in the latest sourcing reviewed. At the same time, draft Bill 42.25 -- jointly prepared by the Ministry of Economy and Finance, Bank Al-Maghrib (BAM), and the Autorite Marocaine du Marche des Capitaux (AMMC) -- has advanced to the point of specifying an operative licensing architecture: virtual-asset service providers would need to be incorporated in Morocco, secure BAM approval, and then obtain an AMMC licence before operating. No enactment date has been confirmed, and the bill has not been formally submitted to Parliament as far as this cycle's sourcing shows. The result is a jurisdiction in which the letter of the law and the direction of policy travel are pointed in opposite directions: prohibition remains the binding legal reality, while three of Morocco's principal financial authorities are visibly coordinating on the instrument that would replace it. This is not evidence that the ban has been lifted, de jure or in practice -- it has not -- but it is evidence that Morocco's regulators have moved from silence to active, multi-agency drafting, which changes the calculus for anyone assessing medium-term market access risk.

Other Developments

Token classification work under Bill 42.25 mirrors the licensing bill's cautious scope-setting: the draft defines crypto-assets as DLT-based transferable digital representations of value or rights, while explicitly excluding central bank digital currencies, non-fungible tokens, and cryptocurrency mining from its coverage. That mining exclusion recurs in the on-chain activity picture, where the bill's silence is itself the finding -- no provisions have been located for staking, DeFi lending, decentralized exchange activity, node or validator operation, or tokenization more broadly, and the only on-chain-adjacent text in the draft is the express carve-out of mining. This is a materially thin evidentiary base and should be read as an absence of located coverage rather than a considered regulatory judgment that these activities are permitted or prohibited.

Stablecoin policy is comparatively more developed on paper: Bill 42.25 would place issuers of asset-referenced tokens under Bank Al-Maghrib's supervision, with a specific requirement that reserves be held in segregated accounts at Moroccan credit institutions. This is the most operationally detailed provision identified in the draft to date, and it signals that Morocco's regulators are treating stablecoin issuance as a distinct, higher-scrutiny category within the broader licensing perimeter rather than folding it into a generic VASP category.

On consumer protection, the draft states aims of protecting investors and preserving market integrity by combating fraud and money laundering in the digital-asset sector. That combined framing is worth flagging precisely because it blends investor-protection intent with anti-money-laundering language in a single clause; the AML/CFT substance of that objective is properly the remit of the financial-integrity monitor, and nothing here should be read as first-party crypto-consumer-protection rulemaking distinct from that AML/CFT track. No binding consumer-protection rules are yet in force -- the clause remains a statement of legislative intent within an unenacted bill.

Tax treatment produced no sourced material this cycle despite active search, consistent with a sector that remains formally pre-legalization. This is a sourcing gap, not a finding that no tax exposure exists or that the position is settled; the correct reading is that Morocco's tax treatment of crypto activity is presently unaddressed in available reporting, and that gap will persist until either Bill 42.25 is enacted or separate tax guidance is issued.

Cross-border transfer activity remains governed by the same 2017 exchange-control prohibition underpinning the licensing ban: the Office des Changes has stated that virtual-currency use violates exchange regulations, which functions as a de facto outbound restriction on crypto-related capital movement. This restriction is binding and currently in force, and nothing in Bill 42.25's drafting to date changes that cross-border posture.

Cross-Monitor Connections

Two overlap flags carry forward from this cycle. First, Bill 42.25's licensing framework would impose AML/CFT compliance obligations on VASPs as a condition of licensure; the substantive analysis of those obligations belongs with the financial-integrity monitor, and this monitor's consumer-protection and licensing narratives should be read as scene-setting rather than a duplicate AML/CFT assessment. Second, the stablecoin issuance and segregated-reserve regime contemplated under Bill 42.25 has payments-system implications that fall within world-payments' remit -- a BAM-supervised reserve requirement for asset-referenced tokens is, in substance, a payments-infrastructure control question as much as a crypto-licensing one, and the two monitors should be read together on this specific provision.

Outlook

The regulatory horizon tracker places Bill 42.25's enactment on a multi-year timeline, with an expected date around 2027 and considerable uncertainty attached. Until enactment, Morocco's crypto posture should be read as legally prohibitory with an actively drafted, comprehensively scoped replacement regime in progress -- not as a jurisdiction that has already begun liberalizing in practice. Open questions flagged this cycle include the absence of any confirmed parliamentary submission date for the bill, the undetermined tax treatment of crypto gains or income once (or if) the bill is enacted, and whether staking, DeFi, decentralized-exchange, or validator activity will be addressed in implementing regulations rather than the primary text. Coverage this cycle also relied entirely on T2/T3 secondary reporting; no T1 primary text of Bill 42.25 or a direct BAM/AMMC press release was retrieved, which is itself a material gap given how much of this cycle's signal rests on interpretation of the bill's provisions. Confirmation from a primary regulatory source on the bill's substantive content and legislative timeline is the single highest-value development to watch for next cycle.