In brief: Law 69-21 caps payment deadlines in Morocco at 60 days (or 120 days by agreement), requires quarterly electronic declarations for companies with turnover above MAD 2 million, and imposes fines up to MAD 250,000 for non-compliance. Each declaration must include a detailed statement of invoices, certified by a statutory auditor (turnover ≥ MAD 50 million) or a chartered accountant (turnover < MAD 50 million). The law applies progressively based on company turnover and aims to protect SME cash flow.
Payment Deadlines: Here’s What Changes Starting in 2023 in Morocco
Law 69-21, recently enacted in Morocco regarding payment deadlines, was officially published in the Official Gazette on June 15, 2023.
This law on payment deadlines aims to provide a breath of fresh air to the cash flow of Moroccan private sector companies. It particularly targets small and medium-sized enterprises by more strictly regulating payment deadlines. A key requirement: each declaration must include a detailed statement of unpaid invoices, certified by a statutory auditor or a chartered accountant depending on the company’s turnover threshold.
Companies with turnover exceeding 2 million dirhams must file a payment deadline declaration starting from the first quarter of 2025. Failure to comply with this obligation could expose these companies to penalties.
Here are the key points to remember:
- Calculation of payment deadlines: The payment deadline is calculated from the date of invoice issuance. If the invoice is not issued within the prescribed period, the payment deadline starts from the end of the month of delivery or service completion.
- Filing obligation: A quarterly electronic declaration must be filed before the end of the month following the end of each quarter. Companies with turnover between 2 and 10 million dirhams (excluding VAT) whose threshold was exceeded in 2024 must file an annual declaration for 2025 (before April 1, 2026), then quarterly from Q1 2026. If the threshold was only exceeded in 2025, no annual declaration is required — quarterly filings start directly from Q1 2026 (before April 30).
- Penalties: The law provides for financial penalties in case of non-compliance with payment deadlines and for late or non-filing of the quarterly declaration. Fines vary according to the company’s annual turnover and can reach up to 250,000 dirhams for large companies.
- Progressive implementation: The law applies progressively, based on company turnover. It came into force on July 1, 2023, for companies with turnover exceeding 50 million dirhams, and will apply from January 1, 2024, for companies with turnover between 10 and 50 million, and from January 1, 2025, for those with turnover between 2 and 10 million.
- Legal payment deadline: If not otherwise agreed, payment deadlines cannot exceed 60 days from the invoice date. For recurring transactions within a month, the payment due date is set at the end of the following month.
- Business partners: Payment deadlines between business partners must be set in advance and cannot exceed 120 days. For public establishments, the deadline is calculated from the date of supervision of service completion.
- Fines: Violations are punishable by a fine equivalent to the prevailing key rate plus 0.85% for each month of delay.
Payment Deadlines: Scope of Application of Law 69-21
This law applies to natural or legal persons whose annual turnover excluding VAT exceeds 2 million dirhams. It also applies to public enterprises operating in the commercial sector.
DGI Clarification of March 27, 2026: Holdings, Civil Partnerships and Individuals
The Directorate General of Taxes (DGI) issued an official position paper (ref. D 326/26/DGI, March 27, 2026) confirming that Law 69-21 provides no sectoral exclusion. The following entities are subject to the law when their turnover exceeds MAD 2 million:
- Holding companies, including those whose accounting turnover consists mainly of dividends
- Civil professional partnerships (SCP) carrying out activities described in Article 91-VI-1° of the General Tax Code (lawyers, architects, etc.)
- Non-commercial natural persons practicing in private offices (doctors, consultants, etc.)
The turnover to be considered is understood in the commercial sense: it corresponds to the business volume generated according to the nature of activities, regardless of the accounting method used. For the purpose of applying the law, it should correspond to the income generated through the professional activity of the entities concerned.
Source: DGI Position — Payment Deadlines: Natural Persons, Civil Partnerships and Holdings (PDF)
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What New Provisions Does This Law Introduce?
Payment Deadlines
Law 69-21 established the obligation for every trader to comply with payment deadlines, as follows:
- Standard deadline: 60 days from the invoice date;
- Agreed deadline: up to 120 days if an agreement is reached between the parties concerned;
- Exceptional deadline: a maximum of 180 days for professionals operating in specific or seasonal sectors.
Start Date for Computing Payment Deadlines
The computation begins from the invoice date.
To prevent manipulation of invoice issuance dates, the law introduces a strict rule for the invoicing obligation. Indeed, the seller must issue the invoice no later than the last day of the month of:
- Delivery of the goods,
- Performance of the service.
Failing this, payment deadlines run from the end of the month in which the delivery of goods or the performance of the service took place.
Progressive Implementation of the Law
The new law will come into force progressively according to the following schedule:
| **Turnover (excl. VAT)** | **Effective Date** |
|
Turnover > 50,000,000 |
July 1, 2023 |
|
10,000,000 < Turnover <= 50,000,000 |
January 1, 2024 |
|
2,000,000 < Turnover <= 10,000,000 |
January 1, 2025 |
N.B.: The various provisions apply only prospectively to invoices issued after the effective date.
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Payment Deadlines: Filing Obligations
In addition to establishing a payment deadline, the law introduces a filing obligation relating to supplier debts. The filing frequency depends on turnover:
- Turnover > MAD 10M: quarterly declaration, filed electronically on SIMPL before the end of the month following each quarter.
- MAD 2M < Turnover ≤ 10M, threshold exceeded in 2024 (reference year): the law applies to invoices issued in 2025. An annual declaration for 2025 must be filed before April 1, 2026, followed by quarterly declarations from Q1 2026 onward.
- MAD 2M < Turnover ≤ 10M, threshold exceeded in 2025 (reference year): the law applies to invoices issued in 2026. No annual declaration is required — quarterly filings start directly from Q1 2026 (before April 30, 2026).
Important: The declaration must be filed even when no invoices are overdue (nil declaration). Since January 1, 2025, invoices below MAD 10,000 are no longer excluded.
Need help? Upsilon Consulting prepares and certifies your payment deadline declarations. Contact us for a free assessment.
This declaration must be accompanied by a detailed statement of invoices exceeding the payment deadlines certified by:
|
Annual Turnover excl. VAT (in MAD) |
Certified by |
|
Turnover >= 50,000,000 |
|
|
Chartered Accountant or licensed accountant |
Penalties for Payment Deadline and Filing Violations
In Case of Late Payment
A fine applies to the amount not paid within the prescribed deadlines, payable to the Treasury, equivalent to:
- First month of delay: BAM reference rate (currently 3%)
- Each additional month: an additional 0.86%
The amount of the applicable fine is paid spontaneously after the above-mentioned declaration.
Furthermore, disputed invoices that have been the subject of legal proceedings do not give rise to the application of the fine.
In Case of Non-Filing
The law provides for penalties in case of late or non-filing of the above-mentioned quarterly declaration. In addition, penalties apply in case of non-payment of the fine.
|
Annual Turnover excl. VAT (in MAD) |
Fine Amount (in MAD) |
|
2,000,000 < Turnover <= 10,000,000 |
5,000 |
|
10,000,000 < Turnover <= 50,000,000 |
12,500 |
|
50,000,000 < Turnover <= 200,000,000 |
50,000 |
|
200,000,000 < Turnover <= 500,000,000 |
125,000 |
|
500,000,000 < Turnover |
250,000 |
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Analysis of the Provisions of Law 69-21 on Payment Deadlines in Morocco
With the enactment of this law, Morocco is taking a significant step toward improving its business climate. Indeed, this legislation aims to:
- Facilitate commercial transactions across the economy;
- Protect SMEs against abusive payment deadlines imposed by certain large companies.
The entry into force of this law and the severe penalties provided should strengthen the financial health of SMEs.
Progressive Implementation
One of the most notable features of the payment deadline law is its progressive implementation.
Indeed, rather than immediately imposing the law on all companies, the Moroccan authorities chose to implement it in three phases.
First, it applies to companies with turnover exceeding 50 million dirhams excluding VAT.
Then, it will be extended to companies with turnover between 10 and 50 million dirhams excluding VAT. This second phase of the payment deadline implementation came into force on January 1, 2024.
And finally, it will cover companies with turnover above 2 million dirhams excluding VAT but below 10 million dirhams excluding VAT.
This progressive approach aims to support SMEs by starting with large companies. By encouraging large companies to comply with the new regulations and pay their suppliers on time, the law should improve SME cash flow, thereby promoting the financial stability and growth of these businesses.
Clear and Flexible Payment Deadlines
Law 69-21 on payment deadlines establishes clear and flexible payment deadlines. Three deadlines are defined: 60 days from the invoice date when the deadline is not agreed between the parties, 120 days from the invoice date when the deadline is agreed between the parties, and exceptionally, 180 days under specific conditions.
A significant change from the previous legislation is that payment deadlines are no longer calculated from the receipt of goods or the performance of the service, but from the date of invoice issuance. This eliminates any ambiguity about the deadline calculation date and strengthens the position of suppliers.
A Mandatory Self-Declaration
Law 69-21 also introduces a mandatory regulatory self-declaration for companies. This means that it is the customers, not the suppliers, who must declare their contractual payment deadlines. The General Tax Directorate plays a key role in this process by serving as a third party.
This measure aims to protect SMEs by preventing them from being in a weak position against large corporate clients. Previously, in case of late payment, SMEs had to claim late penalties themselves, which could jeopardize their customer-supplier relationship. Now, customers must declare their payment deadlines, which better ensures that SMEs will be paid on time.
Periodic and Mandatory
The law requires companies to declare their payment deadlines quarterly, even if they have no overdue invoices. This regular obligation aims to integrate payment deadline declarations into companies’ standard practices, just as they do for their annual financial statements or quarterly VAT returns.
To ensure compliance, the law provides for penalties and fines for non-compliance with its provisions. This should encourage companies to comply with the law by paying their invoices on time.
In conclusion, the new law on payment deadlines in Morocco is an important step toward improving the business climate and protecting SMEs against abusive payment deadlines. Its progressive implementation, clear and flexible payment deadlines, and mandatory self-declaration system contribute to strengthening the financial stability of companies and promoting a culture of timely payment.
Frequently Asked Questions
What is the maximum payment deadline allowed under Law 69-21 in Morocco?
The standard payment deadline is 60 days from the invoice date. If the parties agree, this can be extended to 120 days. Exceptionally, a maximum of 180 days applies for seasonal or specific sectors.
Which companies must file a payment deadline declaration?
Companies with annual turnover exceeding MAD 2 million (excluding VAT) must file payment deadline declarations. For companies with turnover above MAD 10M, declarations are quarterly. For those between MAD 2M and 10M, the first filing is annual (if the threshold was exceeded in 2024) or directly quarterly (if exceeded in 2025). Even if no invoices are overdue, the declaration must still be filed.
What penalties apply for late payment or non-filing in Morocco?
Late payment triggers a fine calculated at the Bank Al-Maghrib reference rate (currently 3%) for the first month, plus 0.86% for each additional month. Non-filing penalties range from 5,000 to 250,000 dirhams depending on the company’s annual turnover.
Is the certification of payment deadlines mandatory?
Yes. Law 69-21 requires that each payment deadline declaration be accompanied by a detailed statement of unpaid invoices, certified by an accounting professional. For companies with annual turnover (excl. VAT) equal to or above MAD 50 million, this statement must be certified by a statutory auditor registered with the Order of Chartered Accountants. For companies with turnover below MAD 50 million, certification may be performed by a chartered accountant or licensed accountant. This certification ensures the reliability of reported data and engages the signatory professional’s liability. Failure to include certification exposes the company to penalties for non-compliant filing.
When did Law 69-21 come into force for SMEs?
The law applied from July 1, 2023 for companies with turnover above 50 million dirhams, from January 1, 2024 for those between 10 and 50 million, and from January 1, 2025 for companies with turnover between 2 and 10 million dirhams.
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