Bank Al-Maghrib climate risk directive: what borrowers must provide

What do the Bank Al-Maghrib climate risk directives require?

Three directives of Bank Al-Maghrib, Morocco’s central bank and banking supervisor, govern banks’ climate risks: 5/W/2021 covers how they manage them, 1/W/2025 how they disclose them and 2/W/2025 how they report on large borrowers. They are addressed to credit institutions, but their effects reach every company those banks finance.

For directive 2/W/2025, the deadline is therefore January 2027 for banks and January 2029 for requirements that apply to their subsidiaries.

The Credit Institutions Committee gave a favourable opinion on these texts on 22 January 2025, according to Bank Al-Maghrib’s annual report on banking supervision for 2025. The report links them to the reforms supported by the IMF’s Resilience and Sustainability Facility (RSF) and announces technical notices to complete them.

The same report states that directive 2/W/2025 was signed in January 2025, without giving the day, and sums up the information requested as “qualitative and quantitative data” on how banks monitor their large borrowers’ exposure; it gives neither the definition of large borrowers nor the detailed list of data. As at 11 November 2026, the full text of directives 1/W/2025 and 2/W/2025 is not published on bkam.ma: the regulatory compendium stops at end-2023, the site’s search returns only reports, and Bank Al-Maghrib’s annual report (2025 financial year) merely mentions them. For the details, ask your bank, to which these directives are addressed.

Why is your bank asking for your carbon data?

Because since 2021 directive 5/W/2021 has required banks to assess the climate risk of their counterparties and reflect it in lending decisions, and directive 2/W/2025 now requires them to report on it for their largest clients. Your emissions and the exposure of your sites become credit data.

The 2021 text, reproduced in Bank Al-Maghrib’s regulatory compendium, spells out what reaches the borrower:

• Each transaction is analysed (Article 11): the bank assesses these risks before, during and after financing, and may add environmental covenants and monitor them.
• Ratings and pricing (Article 13): climate and environmental factors enter the internal rating of counterparties, the lending policy and pricing.
• Portfolio footprint (Article 14): the bank seeks to measure the environmental footprint of its loans, using public data among other sources.
• Mitigation plans (Article 15): reduce exposure to high-footprint counterparties and help clients lower their impact.
• Reporting to Bank Al-Maghrib (Article 19), with qualitative and quantitative information on the main exposures.

The text separates physical risks (floods, drought, rising temperatures) from transition risks (regulation, technology, investor and consumer preferences).

Who is affected in Morocco, and what about exporters and African businesses?

Any company that borrows from a Moroccan bank, with an intensity that depends on its weight in the loan book: the climate rating applies to all, the reporting of directive 2/W/2025 to large borrowers.

• Large companies and groups: first in line for the data collection of directive 2/W/2025, under a threshold still to be read in the text.
• Mid-sized companies and SMEs: affected through ratings and pricing as soon as their bank builds climate into its lending policy, with shorter questionnaires.
• Exporters: a cement maker or fertiliser producer that already calculates its emissions for the EU CBAM or for a European customer reuses the same base. The bank adds a question buyers rarely ask: the physical exposure of its sites.
• Across Africa: directive 5/W/2021 also applies to the subsidiaries and controlled entities of Moroccan banks abroad, subject to host-country law. A business in West or Central Africa financed by one of these subsidiaries may receive the same requests, on the longer timetable set for subsidiaries.

For foreign buyers and investors, this means a Moroccan supplier or partner with bank debt will increasingly hold documented climate data that can be shared.

How do these directives connect with IFRS S2?

Directive 1/W/2025 aligns banks’ disclosures with the ISSB standards, including IFRS S2 for climate, and a bank cannot describe its portfolio’s exposure without its borrowers’ data.

As early as 2021, Article 18 of directive 5/W/2021 required annual disclosure in line with the TCFD recommendations, which IFRS S2 builds on. Our guide to IFRS S2 requirements explains what banks disclose. In Morocco, no published rule imposes IFRS S2 on non-financial companies: they meet its logic through their bank.

What should you prepare before your next bank meeting?

One climate file, sent to all your banks, your group and your customers, rather than an improvised answer to each questionnaire.

1. This quarter: list the requests from your banks, customers and group, and identify the shared data.
2. Before the end of the half-year: build a documented [GHG inventory](/en/consulting/carbon-footprint-iso-14064) covering Scopes 1, 2 and 3, with sourced emission factors and the same boundary for every request.
3. In parallel: map the risks of each site (water, heat, flooding, coastline) and your transition risks, using the method on our climate risk and IFRS S2 page.
4. Before your annual credit review: write a two-page climate fact sheet: emissions, targets, reduction plan, planned investment.
5. For a large financing: have the inventory verified by an independent body; see our ISO 14064-3 verification guide.
6. Every year: update figures and plan, and ask your bank whether you count as a “large borrower”.

• One internal owner answers every climate request.
  
• Scope 1, 2 and 3 emissions come from a single documented inventory.
  
• Each site has been reviewed for physical risks.
  
• The climate fact sheet is ready before the annual credit review.