CSR in Morocco in 2026-2027: What Changes for Exporters

What changed on the EU side in 2026?

Mandatory sustainability reporting has narrowed to very large companies, and the Commission has set what they can ask of their suppliers. Three texts shape this new framework, which the Commission summarises in its staff working document SWD(2026) 500 of 3 July 2026.

Your customers in scope are therefore fewer, but they are often the largest retailers and manufacturers, the ones that buy from Moroccan exporters. The published texts set the calendar:

• wave 2: companies still in scope draw up their first report on financial years starting on or after 1 January 2027, published in 2028;
• third-country groups: a group with net turnover in the EU above EUR 450 million in each of the last two financial years, and an EU subsidiary or, failing that, a branch with net turnover above EUR 200 million, has that entity publish its sustainability report for financial years starting on or after 1 January 2028 (Article 40a of the Accounting Directive);
• delegated acts: published in the Official Journal on 21 September 2026, Delegated Regulation (EU) 2026/1563 (revised ESRS) and Delegated Regulation (EU) 2026/1560 (voluntary standard and cap) apply to financial years starting on or after 1 January 2027.

What does the value-chain cap change for your customer questionnaires?

It sets a ceiling. According to the Commission document, companies with 1,000 employees or fewer in the value chain of a company subject to the CSRD have the right to decline to provide information beyond the voluntary standard. Each data point covered by the cap is listed in Annex II of that standard, with a shorter list for companies with 10 employees or fewer.

Three points to keep in mind:

• there is a single criterion: headcount. A company with more than 1,000 employees and turnover below €450 million falls outside the CSRD, but is not protected by the cap;
• the cap applies to sustainability reporting. A customer may question you on another basis: its purchasing policy, its climate targets, a supplier rating platform or, tomorrow, due diligence;
• establishment outside the EU makes no difference. Directive (EU) 2026/470 defines a protected undertaking by its headcount and its place in the value chain alone, with no condition on where it is established: a Moroccan supplier with 1,000 employees or fewer is protected.

The useful reflex: for each questionnaire, ask what each question is based on, answer from a core data set aligned with the voluntary standard, and keep a record of what you sent, to whom and when. For a European buyer, the logic is symmetrical: questionnaires built on the voluntary standard get comparable answers. Our ESG and CSR hub sets out the method.

Is EU due diligence coming later?

Yes, in 2029, and for a limited number of groups. According to the Commission, the Corporate Sustainability Due Diligence Directive (CSDDD), as amended by Omnibus I, covers EU companies with at least 5,000 employees and €1.5 billion in worldwide net turnover, and non-EU companies generating at least €1.5 billion in the EU.

• Member States must publish their transposition measures by 26 July 2028 and apply them from 26 July 2029;
• the reporting obligations of Article 16 apply to financial years starting on or after 1 January 2030;
• the Commission announces protective measures for SMEs and small partners: limits on information requests, guidelines and voluntary model contract clauses;
• the main guidelines are expected by 26 July 2027 at the latest.

For a Moroccan supplier to one of these groups, this means contract clauses and targeted questions on human rights and the environment. These are exactly areas 1, 2, 3 and 8 of the CGEM CSR charter (charte RSE): human rights, working conditions, environment, suppliers and subcontractors.

What is changing for the CGEM CSR label?

The framework has been republished, and the CGEM, the General Confederation of Moroccan Enterprises, is preparing its next steps. The facts published on cgem.ma as at 5 November 2026:

• 2026 award rules are online for the Label RSE de la CGEM, the Confederation’s CSR label. They confirm the essentials: eligibility for CGEM members active for three years, prior assessment by a body accredited by the CGEM at the company’s expense, an award committee, a three-year label with a follow-up at 18 months, renewal through a new assessment;
• the 20th anniversary of the CSR charter, celebrated on 15 June 2026: 21 companies recognised, 10 newly labelled and 11 renewed, for 152 labelled companies at that date;
• the priorities of the CSR and Diversity Commission (Commission RSE et Diversité): a review of the label after 20 years to analyse and adapt the labelling process, greater international visibility for the label, an ESG watch covering the European Union and the OECD, and practical ESG compliance guides;
• SMEs: the Label PME Responsable (Responsible SME label), launched in 2025, is to be adapted further to their issues, with regional workshops and a gradual support scheme. The Rendez-vous de la RSE, a series of CSR meetings launched on 22 April 2026 in Casablanca by Maroc PME, Morocco’s national SME promotion agency, with the CGEM and other partners, are being held in several regions;
• ESG skills: the CGEM and the International Labour Organization (ILO) ran a training course on integrating ESG criteria for fifteen companies from 10 to 14 November 2025.

The message is consistent: the CGEM is bringing its label closer to international ESG expectations. For an exporter, that is one more reason to build a single approach that serves both the label and its customers. The full workings of the label are described in our guide to the CGEM CSR label and ISO 26000.

What should you do in 2027 if you export to the European Union?

Put the requests in order, then invest once in evidenced data. The timetable leaves no respite: CSRD questionnaires from large customers now, due diligence clauses from 2029, the follow-up assessment at 18 months for labelled companies.

• List your European customers and check which ones remain subject to the CSRD after Omnibus I.
  
• For each questionnaire received, note the basis invoked and the questions that go beyond the voluntary standard.
  
• Check your headcount against the 1,000-employee threshold and note the calculation method used.
  
• Build a single CSR database, linked to evidence: CNSS social security declarations, energy, water, waste, occupational accidents, training, purchasing.
  
• Map that database to the nine areas of the CGEM CSR charter.
  
• Identify your customers affected by due diligence and anticipate their contract clauses.
  
• Decide with general management whether to aim for the CSR label or the Responsible SME label in 2027.
  

The method for preparing the file is in our CGEM CSR label application checklist.