What is Morocco’s mandatory energy audit?
It is an energy audit that Law 47-09 on energy efficiency imposes on large energy consumers, carried out by an approved audit body and repeated at least every five years. It ends with a report and an energy efficiency plan that the company sends to the authorities and then reports on every year.
Law 47-09, promulgated by Dahir 1-11-161 of 29 September 2011, defines an energy audit (Article 1) as the technical and economic studies, investigations and performance checks of equipment and processes that identify the causes of excessive energy use and propose a corrective action plan. Its Chapter IV makes the audit mandatory and periodic above a consumption threshold set for each sector (Article 12).
Decree 2-17-746 of 10 April 2019, published in Official Bulletin 6774 of 2 May 2019, implements that chapter. It took effect on the first day of the seventh month after publication (Article 20); AMEE describes the framework as in force since the end of 2019. A search of the Ministry of Justice legal portal on 11 November 2026 shows no other text on the mandatory energy audit.
Three players are involved:
- the government authority in charge of energy approves audit bodies and receives audit reports;
- AMEE (Agence marocaine pour l’efficacité énergétique) receives declarations and annual data, keeps the database of companies subject to the audit and checks audit quality;
- the approved energy audit body carries out the audit and hands the report to the company.
For a foreign group with plants in Morocco, this is a site-level legal obligation: it applies whatever energy management policy the group runs elsewhere.
Who must carry out a mandatory energy audit in Morocco?
Any company or establishment whose total final energy consumption exceeds the threshold for its sector. For industry, including energy production, the threshold is 1,500 toe a year; it is 500 toe for the tertiary sector, energy transmission and distribution, and individuals (Decree 2-17-746, Article 2).
Sector | Total final energy consumption threshold | Reference |
|---|---|---|
Industry, including energy production | Above 1,500 toe a year | Decree 2-17-746, Art. 2 |
Tertiary sector (as defined in Article 1 of the decree) | Above 500 toe a year | Art. 2 |
Energy transmission and distribution | Above 500 toe a year | Art. 2 |
Individuals | Above 500 toe a year | Art. 2 |
Other sectors | Threshold to be set by joint order of the energy minister and the sector minister | Art. 2 |
How do you know whether you are above the threshold?
Add up one year of purchased fuels and electricity, converted to toe with the coefficients in the decree’s annex. Article 1 excludes what you do not buy: electricity from your own solar panels does not count towards the threshold, even though it belongs in your energy balance.
Some annex coefficients: 1 GWh of electricity = 86 toe; 1 tonne of fuel oil = 0.96 toe; 1 tonne of diesel = 1.04 toe; 1 tonne of LPG = 1.13 toe; 1 tonne of petroleum coke = 0.72 toe; 1 tonne of coal = 0.66 toe. Example: a site that buys 10 GWh of electricity (860 toe) and 700 tonnes of fuel oil (672 toe) consumes 1,532 toe and is above the industrial threshold.
Two points to confirm with AMEE before concluding:
- the calculation boundary: the decree refers to “companies and establishments”. A group with several plants needs to know whether the threshold applies site by site or to the company as a whole;
- the sector: a mixed activity, or a logistics platform attached to a manufacturer, may fall under a different threshold.
As soon as the threshold is exceeded, the company must declare it to AMEE and start the audit immediately (Article 4).
What must a company do, and by when?
Declare to AMEE, appoint an energy manager, have the audit carried out by an approved body, send the report and plan within 30 days, then report every year. The table follows the decree.
Step | What the decree requires | Deadline | Decree 2-17-746 |
|---|---|---|---|
Declaration | Declare that the threshold is exceeded to AMEE and start the audit immediately | As soon as the threshold is exceeded | Art. 4 |
Energy manager | Appoint a qualified energy manager, the auditor’s counterpart, then in charge of following the plan | Before the audit | Art. 6 |
Audit | By an approved body, to the Moroccan standards in force for the sector, covering all activities, processes, buildings and vehicle fleets | No numeric deadline after the declaration | Art. 4, 5 and 7 |
Submission | Two copies of the report, summary of results and energy efficiency plan, by registered letter, to the energy authority | 30 days after receipt from the audit body | Art. 7 |
Quality check | AMEE checks data, results and recommendations and may ask for further investigations or measurements | Request within 30 days; company reply within 3 months | Art. 8 |
Persistent shortcomings | New audit by another approved body, at the company’s expense | 6 months after AMEE’s letter | Art. 8 |
Plan follow-up | Report on implementation of the energy efficiency plan, in two copies, to the energy authority | Every year | Art. 9 |
Data | Energy data questionnaire prepared by AMEE | Every year | Art. 4 |
Next audit | New energy audit | No later than 5 years after the last report was sent | Art. 4 |
The decree does not set a date in the year for the questionnaire and the annual report: ask AMEE for the calendar and add it to your regulatory watch.
Who carries out the audit, and what is ACG’s role?
Only an energy audit body approved by the government authority in charge of energy may carry out the mandatory audit (Law 47-09, Article 14; Decree, Article 5). ACG is not an approved audit body: we prepare the company, its data and its plan; the approved body audits and signs the report.
The law sets the approval conditions (Article 14): a company under Moroccan law, not in receivership or liquidation, with technical references, the human, technical and financial resources required, an audit procedures manual approved by the authorities, and full guarantees of integrity and independence. The decree adds:
- approval is granted after the opinion of a committee of the energy authority, the sector ministry and AMEE, for one or more sectors; it is personal, non-transferable and valid for five renewable years (Articles 11 to 14);
- the team includes at least two energy auditors, or one auditor and two supervised staff (Article 17);
- each energy auditor holds an engineering, master’s or doctoral degree in mechanical, energy, thermal, electrical, chemical, process, electrotechnical or electromechanical engineering, with three years of energy audit experience or, failing that, a diploma in energy auditing (Article 17);
- measuring instruments are calibrated to the Moroccan standards in force (Article 12);
- the list of approved bodies is kept up to date and published on the websites of the energy authority and AMEE (Article 19).
Check that the body you choose is approved for your sector: the approval decision states the sectors covered (Article 13).
Keeping preparation and audit separate serves you twice: the law requires auditor independence, and you want a report that holds the first time, since AMEE can ask for additional work and, if shortcomings persist, a new audit by another body (Article 8).
What does the audit cover, and which method applies?
The audit covers all activities, industrial processes, buildings and vehicle fleets operated, and the company’s entire energy consumption (Decree, Article 4). It follows the Moroccan standards in force for the sector concerned (Article 7).
The decree names no standard. Internationally, the reference is ISO 50002-1:2025, Energy audits — Part 1: General requirements with guidance for use (formerly ISO 50002:2014, withdrawn in June 2025), with ISO 50002-2:2025 for buildings and ISO 50002-3:2025 for processes. The IMANOR catalogue lists NM ISO 50002-1, NM ISO 50002-2 and NM ISO 50002-3; their pages showed no adoption date on 11 November 2026. State in your terms of reference which standard the audit body will apply.
The auditor will ask for invoices and meter readings, production and operating data, an inventory of energy-intensive equipment (furnaces, boilers and steam, compressed air, refrigeration, motors, pumps, lighting, fleets), access for measurement campaigns, and available maintenance and production staff. The more of this is ready, the more audit time goes into finding savings.
Mandatory audit or ISO 50001: what is the difference?
The mandatory audit is a regulatory snapshot repeated at least every five years; ISO 50001:2018, Energy management systems — Requirements with guidance for use (which replaced ISO 50001:2011, amended by ISO 50001:2018/Amd 1:2024), sets up a continual improvement cycle. A certified system exempts the covered activities from the audit while the certificate is valid (Decree, Article 3).
Mandatory energy audit | Certified ISO 50001 system | |
|---|---|---|
What | Studies, investigations and checks that identify excessive energy use and propose an action plan (Law 47-09, Art. 1) | Management system: policy, energy review, significant energy uses, EnPIs, baseline, objectives, action plans, internal audit, management review |
Who must do it | Industry above 1,500 toe a year; tertiary, energy transmission and distribution, individuals above 500 toe (Decree, Art. 2) | Voluntary; audit exemption for covered activities (Art. 3) |
Who performs or attests | Energy audit body approved by the energy authority (Art. 5) | Certification body, under the Moroccan standards in force and Law 12-06 (Art. 3) |
Frequency | New audit no later than 5 years after the last report was sent (Art. 4) | Certification, surveillance and recertification audits on the certification body’s cycle |
Proof | Report, summary and energy efficiency plan sent within 30 days; annual implementation report (Art. 7 and 9) | Valid certificate whose scope covers the activities subject to the decree |
Still due | Annual data questionnaire to AMEE (Art. 4) | Annual data questionnaire to AMEE (Art. 3 and 4) |
On expiry | New audit | Back under the decree as soon as the certificate expires (Art. 3) |
AMEE presents the exemption as applying to companies with an energy management system certified to NM ISO 50001, the Moroccan adoption of ISO 50001:2018; the IMANOR catalogue also lists its Amendment 1.
How to choose:
- ISO 50001 makes sense when energy is a large cost, when you already run ISO 9001:2026 (formerly ISO 9001:2015), ISO 14001:2026 (formerly ISO 14001:2015) or ISO 45001:2018, or when customers and lenders expect continuous energy and carbon management;
- the audit alone may be enough for a site just above the threshold with little sub-metering, which first wants to know where its savings are;
- the two often follow each other: a first audit identifies significant uses and savings, and the ISO 50001 energy review builds on it.
Watch the scope: the exemption only covers activities within the certificate. A certificate limited to one workshop or one plant does not exempt the others. Certification itself is covered on our QHSE and ISO systems page.
How do you set the energy baseline and EnPIs?
With ISO 50006:2023, Energy management systems — Evaluating energy performance using energy performance indicators and energy baselines (which replaced ISO 50006:2014). The baseline fixes consumption over a representative period; EnPIs relate it to what drives it, so that real progress can be measured.
Three rules avoid arguments with the auditor or AMEE:
- normalise the indicator: raw consumption falls when output falls, so relate it to its drivers (tonnes produced, degree-days, operating hours);
- choose a representative period: usually a full year of normal production, with exceptional shutdowns excluded or documented;
- write the adjustment rule: what triggers a baseline recalculation (new line, product change, site extension).
How does the audit feed your decarbonisation plan?
Law 47-09 requires the audit recommendations to become an energy efficiency plan, with an annual implementation report (Law, Article 13; Decree, Articles 7 and 9). That plan is also the first chapter of your decarbonisation plan.
Build it action by action: expected saving in energy and then in tonnes of CO2e with documented emission factors; investment and lead time quoted by your suppliers; owner, deadline and indicator linked to the relevant EnPI; and the intended financing route, which may include a contract with an energy services company, an activity governed by Decree 2-24-153 of 22 October 2024 implementing Law 47-09.
The same energy data feed your greenhouse gas inventory: fuels in scope 1 and purchased electricity in scope 2 under ISO 14064-1:2018. See our ISO 14064 carbon footprint page, our ISO 14064-1 guide and, for targets and trajectory, decarbonisation strategy. For exporters of CBAM goods, the same meters support installation-level emissions data: see CBAM for exporters.
What happens after the audit: checks and penalties?
AMEE checks audit quality and monitors implementation of the recommendations (Decree, Articles 8 and 10). Under Law 47-09, the authorities may serve formal notice on a company that has not carried out the audit or does not implement its plan (Article 15); failing to carry out the audit is punishable by a fine (Article 23), doubled for a repeat offence within five years (Article 27).
Is your mandatory energy audit file ready?
Check these points before consulting approved audit bodies or starting an ISO 50001 project.
How does ACG support you?
ACG prepares, structures and trains; an approved body carries out the regulatory audit and a certification body certifies the ISO 50001 system. The firm has delivered 502 projects, brings together 10 in-house consultants and more than 100 qualified external experts, and has trained more than 120,000 people.
We work mainly with industrial sites: see industry and energy. An energy management system fits into what you already run: ISO 14001 and the integrated QHSE management system. Your teams can train through our training catalogue (energy audit, ISO 50001). For the wider climate and ESG picture, see ESG and CSR. To check whether your plant is subject to the audit, describe your site.