Mandatory Energy Audit Preparation in Morocco: Data, Auditor, Filing

Where does mandatory energy audit preparation start?

With a dated applicability note, followed by the two steps that Decree 2-17-746 attaches to crossing the threshold: declaring it to AMEE, the Moroccan Agency for Energy Efficiency, and appointing an energy manager. Mandatory energy audit preparation starts well before you contact approved audit bodies.

Morocco’s Law 47-09 on energy efficiency makes the audit compulsory for large energy users, and Decree 2-17-746 sets the thresholds: 1,500 toe a year for industry, 500 toe for the tertiary sector. Thresholds and the legal timetable are covered on our mandatory energy audit and ISO 50001 page. This article covers internal preparation, in the order we run it with industrial sites.

The decree requires the energy manager to be qualified in the field. He or she is the audit body’s contact throughout the audit, then follows up the energy efficiency plan (Article 6). A maintenance or utilities engineer works better than a part-time administrative role.

What data should you collect, and in what form?

A single register, by energy carrier and by month, over three years where available, in which every figure points to its source: invoice, delivery note, meter reading. AMEE checks the data used to prepare the audit report (Decree, Article 8), so a figure nobody can trace will be challenged.

Each line records the energy carrier, the period, the quantity and its original unit, the source document, the annex coefficient, the result in toe and whether the energy was purchased or generated on site. Production data and equipment inventories follow the same logic, in line with ISO 50001:2018 — Energy management systems (which replaces ISO 50001:2011).

Energy carriers that get left out of the toe calculation

The decree’s annex also covers biomass, waste and natural gas:

For natural gas, 900 toe per cubic metre makes no physical sense: the intended unit is most likely one million cubic metres. Have AMEE confirm the unit before converting your readings.

What AMEE’s declaration form asks for

AMEE publishes an online “Formulaire de déclaration énergétique” (energy declaration form), headed “Déclaration annuelle” (annual declaration), accessed on 11 November 2026. Among other things it asks for:

• the sector, annual production, the energy manager and purchased electricity, in kWh and in toe;
• each fuel in its own unit: kilograms for most (heavy fuel oil grades F2 and F7, propane and butane listed separately), litres for diesel, Nm3 for natural gas;
• thermal, hydro or renewable on-site generation, in MWh a year, with installed capacity;
• any energy audit already carried out (by whom, when) and any ISO 50001 certification, with its expiry date;
• decarbonisation actions, then totals in kWh and toe and whether the site is “Assujettie à l’audit obligatoire” (covered by the mandatory audit).

Your register therefore has to keep both units. Diesel is declared in litres but converted into toe from tonnes: record the density stated by your supplier. Ask AMEE whether the form also counts as the threshold declaration, and keep a copy of every submission.

How do you set the audit scope?

Broadly. The audit covers all activities, industrial processes, buildings and vehicle fleets operated, and total energy consumption (Decree, Article 4), whereas the threshold counts purchased energy only (Article 1).

Two cases need a written answer from AMEE before anything is removed from the scope: a company with several establishments, and a fleet run by a haulier, which you do not literally “exploitez” within the meaning of Article 4.

How do you choose an approved audit body and write the terms of reference?

Start from AMEE’s published list, check the approval, the team and the equipment against documents, then compare offers against identical terms of reference that fix the standard, the audit level and the deliverables.

AMEE’s published list (Decree, Article 19), accessed on 11 November 2026 in its version of 13 January 2026, shows for each body its company name, manager, the sector covered by the energy audit (industry, tertiary or both) and contact details. It shows neither the approval date nor its expiry. So ask for:

• the approval decision, which states the sectors covered (Article 13). Approval is valid for five years and renewable on an application filed six months before expiry (Article 14);
• the named auditors: at least two energy auditors, or one auditor and two supervised staff, holding a degree in a listed engineering discipline, with three years’ energy audit experience or an energy audit diploma, and experience in your sector (Article 17);
• calibration certificates for measuring instruments and the audit procedures manual approved by the energy authority (Article 12);
• a statement of independence, since the law requires the body to offer guarantees of integrity and independence (Article 14): does it sell or install the equipment it might recommend?

The decree requires the Moroccan standards in force for the sector (Article 7) without naming one. The international reference is ISO 50002-1:2025 — Energy audits — Part 1: General requirements with guidance for use (formerly ISO 50002:2014, withdrawn in June 2025). Its iso.org page distinguishes three audit levels: walk-through, detailed survey and analysis, and comprehensive engineering analysis. The decree sets no level, so your terms of reference must.

If you are also preparing a greenhouse gas inventory, ask for savings in tonnes of CO2e with sourced, dated emission factors, following ISO 14064-1:2018, which is under revision (draft ISO/WD 14064-1.2 at stage 20.60 on iso.org as of 11 November 2026). See our ISO 14064-1 guide.

How does the audit run, and how should you review the report?

The approved body runs the audit and signs the report; your job is to make the plant readable: people available, normal production during measurements, access to equipment.

Schedule measurements around production: measuring a furnace that is shut down tells nobody anything. Prepare work permits, lock-outs and safety escorts for the auditors.

Review the draft report before it is finalised:

• does consumption match your register?
• does the report separate what was measured from what was estimated?
• does each recommendation state the energy use targeted, the expected saving in energy and toe, and how the investment was estimated?

Point out factual errors without asking for conclusions to change: the auditor’s independence is a condition of its approval, and a complacent report will not survive AMEE’s review.

What happens after the audit: filing, review and follow-up?

Within 30 days of receiving the documents from the audit body, send two copies of the report, the summaries of results and the energy efficiency plan by registered mail with acknowledgement of receipt to the government authority in charge of energy (Decree, Article 7). The rest is a calendar to keep.

1. Day 0: record the date you receive the audit body’s documents; it starts the 30-day period.
2. Day 30 at the latest: registered mail; the authority forwards a copy to AMEE within 10 days of receiving it (Article 7).
3. Within 30 days of receipt of the documents: AMEE may request additional investigations, studies or measurements (Article 8).
4. Within three months of that request: you send AMEE the results.
5. Within six months of a reasoned letter from AMEE, if shortcomings persist: a new audit by another approved body, at your expense.
6. Every year: a report on implementing the plan, in two copies, to the energy authority (Article 9), and energy data to AMEE (Article 4).
7. No later than five years after filing: a new audit (Article 4), unless a certified energy management system covers the activities concerned (Article 3).

The receipt from step 2 sets the deadline for step 7: file it with the report. To qualify for the exemption, ISO 50001:2018 certification must cover the activities subject to the audit before that deadline; energy performance indicators are built with ISO 50006:2023 (which replaces ISO 50006:2014).

Law 47-09 provides for a formal notice (Article 15) and then a fine (Article 23) where no audit is carried out, and its inspectors check the mandatory documents (Article 19). The energy efficiency plan becomes the first chapter of your industrial decarbonisation plan.

Which mistakes should you avoid, and is your preparation complete?

Four mistakes come up again and again: a threshold calculated without supporting documents; gas, biomass or mobile-equipment fuel left out; on-site generation excluded from the audit; a report filed away without recording the date it was received.

Before you sign the order with the approved audit body:

• For each energy carrier, the register holds the original unit, the source document, the annex coefficient and the result in toe.
  
• AMEE has confirmed the unit for natural gas in the annex, if you use gas.
  
• On-site generation is metered: type, annual output, installed capacity.
  
• Fleets, mobile equipment and ancillary buildings are in scope; doubtful cases have a written answer from AMEE.
  
• The AMEE form uses the same figures as the register, and a copy is filed.
  
• The approval decision covers your sector and remains valid throughout the audit.
  
• Named auditors, their qualifications and calibration certificates have been received.
  
• The terms of reference specify ISO 50002-1:2025, the relevant Part 2 or 3 and the audit level per energy use.
  
• The contract covers the additional investigations AMEE may request.
  
• Measurements are scheduled during normal production, and registered mail is ready.