Morocco Framework Law 99-12: environment charter, SNDD and companies

What is Morocco’s Framework Law 99-12 on the environment?

Framework Law No. 99-12 is the Moroccan text that sets the fundamental objectives of State action on the environment and sustainable development. It defines principles, rights and duties, the commitments of each actor, including private companies, and announces the environmental liability and enforcement regimes.

Its full title is loi-cadre n° 99-12 portant charte nationale de l’environnement et du développement durable (Framework Law No. 99-12 on the National Charter for the Environment and Sustainable Development). It was enacted by Dahir (royal decree) No. 1-14-09 of 6 March 2014 and published in the Official Bulletin No. 6240 of 20 March 2014, official French translation edition, pages 2496 to 2500. The Ministry of Justice legal portal (Adala) and the Ministry in charge of the environment publish copies. Only the Official Bulletin is authoritative. Quotations in this article are our own translation.

A framework law is not a directly applicable law like Law No. 11-03 on environmental protection. It sets direction: what the State, local authorities, public bodies, companies, associations and citizens must aim for, and it asks the government to bring existing laws into line with its principles (Article 19). None of its 35 articles sets a fine.

Two principles in Article 2 concern companies directly. The prevention principle calls for tools to assess impacts regularly and for concrete measures to remove them or reduce their effects. The responsibility principle requires any person, natural or legal, public or private, to repair damage caused to the environment.

What does Article 21 of Framework Law 99-12 require from companies?

Article 21 commits private companies, as well as public establishments and state-owned enterprises, "especially those carrying out an industrial and commercial activity", to respect the principles and objectives of the framework law. It sets five commitments, with no size threshold, no prescribed method and no set frequency.

The law does not say how to prove these commitments. That is exactly what a European customer, a lender or an auditor will ask for: not a quotation of the article, but evidence of what is done. The table turns each commitment into verifiable evidence.

Three points to avoid misreading it. First, "commit to" is not decorative wording: combined with the responsibility principle and the duty in Article 4, it becomes the reference point when damage or a dispute occurs. Second, Article 21 mentions suppliers: a Moroccan company asking its own suppliers for environmental data is applying national law, not an imported fashion. Third, transparent communication is about environmental management: it assumes data that is actually kept, not statements of intent.

ISO 14001:2026 (formerly ISO 14001:2015), published in April 2026, covers the second and third commitments well: environmental analysis, compliance obligations, objectives, monitoring. It covers neither public reporting nor, on its own, supplier requirements. The link between the system and ESG data is explained in our article ISO 14001 and ESG, and how to keep the aspects and legal register in our environmental aspects register checklist.

Which concrete obligations follow from Framework Law 99-12?

The enforceable obligations come from the sector laws that the framework law asks to complete, and from the environmental police it created. For a plant, the practical question is not "do we comply with the framework law?" but "do we comply with the texts the environmental police enforces?".

Texts enforced by the environmental police

Decree No. 2-14-782 of 19 May 2015, published in Official Bulletin No. 6366 of 4 June 2015, organises the police created by Article 35 of the framework law. It was amended by Decree No. 2-25-432 of 3 October 2025, published in official French translation in Official Bulletin No. 7480 of 5 February 2026 (Arabic text: No. 7447 of 13 October 2025). Both texts are listed on the Ministry’s governance page.

Law No. 49-17 on environmental assessment, enacted by Dahir No. 1-20-78 of 8 August 2020, brings in the strategic environmental assessment required by Article 27 of the framework law and creates an environmental audit for existing units. Its Article 32 makes its entry into force depend on the publication of its implementing texts, at which point it repeals Law No. 12-03. On 11 November 2026, the Ministry’s environmental assessment page lists no implementing decree for Law 49-17: check which of the two laws applies to your project on the date of your application.

How does an inspection work?

Environmental police inspectors act unannounced, at the request of the environment authority, or under the inspection plans. Since the 2025 decree, the Ministry’s regional services draw up regional inspection plans, from which the Ministry builds the national plan; these plans set priority sectors and select the installations to inspect according to environmental stakes and risk assessment.

Under these plans, inspectors work within an inspection commission empowered to record and report offences, including after an incident. The Ministry keeps a database fed by inspection reports and court decisions, and draws up an annual report on the police’s activity. A company should therefore be able to show, on the day of an unannounced visit, its permits, discharge measurements, waste tracking slips and corrective actions.

What the framework law announces without setting it

Several articles announce regimes whose content depends on other texts: environmental liability with financial guarantees "where relevant" (Article 34), environmental taxation made of ecological taxes and fees on highly polluting or resource-intensive activities (Article 30), the ecolabel (Article 31), financial and tax incentives (Article 28) and the National Fund for the Environment and Sustainable Development, whose resources also support "assistance to companies" (Article 29). Before citing any of these in a report or a funding application, check the implementing text in force in the Official Bulletin; the framework law alone is not enough.

What is the SNDD, and where does the SNDD 2035 stand?

The national sustainable development strategy (stratégie nationale de développement durable, SNDD) is the tool that Article 14 of the framework law requires the government to adopt. The first SNDD, with a 2030 horizon, was adopted by the Council of Ministers on 25 June 2017; its overhaul, the SNDD 2035, is being finalised according to the Ministry.

The framework law gave the government one year to adopt the strategy (Article 14), then two years for public policies to align with it (Article 16). The SNDD 2030 was presented to the Government Council on 1 June 2017 and adopted by the Council of Ministers on 25 June 2017, according to the Ministry’s SNDD 2035 page. It aims to build a green and inclusive economy in Morocco by 2030, with 7 challenges, 31 strategic axes and 137 objectives, according to the evaluation document published by the Ministry.

The SNDD 2030 evaluation started after the Monitoring Committee meeting of 26 May 2021. It found that the strategy created momentum within the administration, but that monitoring tracked actions completed rather than objectives reached, and that some measures, based on older sector strategies, had become obsolete. As of 11 November 2026, neither the Ministry’s website nor the Head of Government’s website announces the adoption of the SNDD 2035: the “SNDD 2035” column therefore describes a draft, which we will update when the adopted text is published.

For a company, the SNDD is not binding like a regulation. It shows the direction of future laws and public programmes. Among its objectives, the SNDD 2030 included:

• objective 8, improving environmental reporting, with a measure to require, by regulation, sustainability reports from listed companies and local authorities;
• objective 10, institutionalising corporate social and environmental responsibility (CSR) and socially responsible investment, with a measure to support companies towards a CSR approach based on ISO 26000 and an indicator target of 100 companies;
• objective 16, drafting new laws, including one on the publication and third-party review of non-financial data by listed companies.

These measures appear in the full SNDD document published by the Ministry. The direction has materialised for listed issuers: the AMMC, Morocco’s capital markets authority, requires an ESG report within the annual financial report, under Annex III.2.M of its Circular No. 03/19 (see our page on ESG and CSR in Morocco). For other companies, the pressure comes mainly from customers, lenders and banks.

What does State exemplarity mean for companies and suppliers?

State exemplarity is the first strategic axis of the SNDD 2030: the administration first applies to itself what it asks of economic actors. It covers sustainable public procurement, the State’s own environmental footprint and its social responsibility, so it directly affects companies that sell to the administration.

The first six objectives of the SNDD 2030, listed in the annex of its executive summary (October 2017), deal with this exemplarity: public buildings, waste, water and energy in administrations, the State as a responsible employer, transparency, sustainable and responsible public procurement (objective 5), and mobility. The full strategy document provides, under objective 5, for allowing the State to favour companies with a CSR approach when awarding public contracts (measure 5.2).

This axis took the form of the administration exemplarity pact on sustainable development (pacte de l’exemplarité de l’administration en matière de développement durable), adopted on 22 February 2019 by the Strategic Committee for Sustainable Development chaired by the Head of Government. Each ministry was to draw up a plan for 2019–2021, and at least 10% of the administration’s vehicle purchases were to go to the "green" fleet from 2019, according to the Head of Government’s statement.

The Ministry’s later evaluation proposes a revised pact in five areas: water, energy, sustainable purchasing and consumption, waste, and sustainable mobility, with the aim of cutting the administration’s carbon emissions. Recommended actions include carbon footprints of the administration, sustainability clauses in public tender specifications, and an obligation to justify any non-use of those clauses. These are roadmap recommendations; the roadmap lists the update of the 2013 public procurement decree among the regulatory changes needed. The text in force is Decree No. 2-22-431 of 15 Chaabane 1444 (8 March 2023) on public procurement, which repealed Decree No. 2-12-349 of 2013. It does not make sustainability clauses mandatory: its first article asks the contracting authority to take into account, as appropriate, environmental dimensions, sustainable development goals, energy efficiency and the preservation of water resources; its Article 21 allows, where a technical offer is required, performance in environmental protection and sustainable development, renewable energy, energy efficiency and the preservation of water resources to be added to the eligibility criteria. These are options, not obligations. As of 11 November 2026, a draft decree amending and supplementing Decree No. 2-22-431 is among the texts open for public comment on the website of the Secretariat General of the Government; it is not in force.

How do you turn Framework Law 99-12 into a company ESG approach?

Start from Article 21 and make it measurable. A company that can prove its five commitments already holds most of the environmental part of its CSR approach, its answers to ESG questionnaires and the file for a possible label.

The framework law has one advantage for foreign buyers and investors: it is a Moroccan law, passed by Parliament, that any director can cite to a board. It gives a national legal basis to what European customers ask under their own rules, and to what the CGEM assesses for its CSR label. Six steps anchor it in day-to-day operations:

1. Map the obligations. List the texts that apply to the site (Laws 11-03, 12-03 or 49-17, 13-03, 28-00, 81-12 where relevant, sector texts) with their requirements and evidence. This is the basis for any environmental police visit.
2. Assess impacts every year. Keep the aspects and impacts analysis current and link it to energy, water, waste and emissions indicators.
3. Set reduction targets. Quantified, dated targets with a base year: the direct translation of "reduce adverse effects to a strict minimum".
4. Manage suppliers. Environmental clauses, questionnaire, assessment of high-risk suppliers: Article 21 asks for it explicitly.
5. Publish what you track. A report, a web page or questionnaire answers, consistent with each other and drawn from the same data.
6. Prepare evidence for public buyers. If you sell to the State, gather now what sustainability clauses could require.

Before your next management review, check these points:

• Framework Law No. 99-12 and its Article 21 are in the legal register, with the sector laws that apply to the site.
  
• The environmental impact analysis was reviewed less than a year ago and its results are quantified.
  
• Each environmental target states a base year, a deadline and a unit.
  
• Contracts or purchasing terms include an environmental clause for significant suppliers.
  
• Permits, discharge measurements and waste tracking slips are available on the day of an unannounced inspection.
  
• The law applying to impact studies (Law 12-03 or Law 49-17) was checked on the date of the latest project.
  
• Information published or sent to customers comes from the same data as internal reporting.
  
• If the company sells to the administration, evidence of its CSR approach is ready to be produced.
  

To go further, third-party recognition of a CSR approach in Morocco goes through the CGEM CSR label, explained in our CGEM CSR label and ISO 26000 guide. Companies that want to link their commitments to the Sustainable Development Goals can use ISO/UNDP 53001:2026, covered in our ISO 53001 guide. On energy, two texts extend Article 7 of the framework law on renewables and energy efficiency: the mandatory energy audit and Law 82-21 on electricity self-generation. Climate adaptation, another aim of Article 1, is covered in our ISO 14090 and ISO 14091 guide.

What does Framework Law 99-12 not say?

It sets no threshold, report format, indicator or deadline for companies. It creates no label, is not a permit and replaces no sector law: citing it in an environmental policy proves nothing if the implementing texts are not met.

Nor does it require a carbon footprint. It calls for stronger climate mitigation and adaptation (Article 1) and for promoting renewables and energy efficiency (Article 7), with no calculation method. When a customer, lender or bank asks for your emissions, the method comes from their request: see our page on carbon footprint and ISO 14064.

Finally, cite the Official Bulletin, not a copy. The French version published by the Ministry leaves out two passages found in Official Bulletin No. 6240 (page 2500): in Article 34, compensation for damage caused "to individuals and property", and in Article 35, "administrative enforcement" among the environmental police’s missions, alongside prevention, control and inspection.