Payment institution in Morocco: what law 103-12 says, what it may do and who licenses it

A payment institution in Morocco is, under law 103-12, a body treated as similar to credit institutions that offers one or more payment services: fund transfers, cash deposits and withdrawals on a payment account, remote payments where the operator acts only as an intermediary, direct debits, card payments and transfers involving funds held in a payment account. Only banks can be authorized to receive funds payable on demand from the public, and neither checks nor credit are payment services. The license is granted by the Wali of Bank Al-Maghrib and published in the Official Bulletin. We quote the law article by article without interpreting it: this article is not legal advice.

What is a payment institution in Morocco?

Law No. 103-12 on credit institutions and similar bodies lists payment institutions among the bodies treated as similar to credit institutions (Article 11). It then defines them by what they do: payment institutions are those that offer one or more of the payment services listed in Article 16, and they may also carry out foreign exchange operations, in compliance with the laws and regulations in force (Article 15).

The difference from a credit institution fits in one sentence. A credit institution is defined by its activities: receiving funds from the public, carrying out credit operations, and providing customers with means of payment or managing them (Article 1). A payment institution is defined by the payment services of Article 16 alone, to which foreign exchange operations may be added.

One more word, because commercial offers tend to blur the terms. "PSP" (payment service provider) describes a commercial role: the company that lets you get paid. "Payment institution" describes a legal status, defined by law 103-12, which a legal entity obtains through a license from Bank Al-Maghrib. The license attaches to that status, and that status is what you should look at when you hand your collections to someone. An app's name tells you nothing about the legal framework it operates in; the entity that holds your account does.

The payment services in Article 16

Article 16 of law 103-12 lists the payment services, in this order (quotations in this article are our translations; the official text is in French):

• fund transfer operations;
• cash deposits and withdrawals on a payment account;
• the execution of payment operations by any means of remote communication, provided that the operator acts solely as an intermediary between the payer and the supplier of goods and services;
• the execution of standing or one-off direct debits, card payment operations and transfers, when they involve funds held in a payment account.

The same article defines the payment account as "any account held in the name of a payment services user and used exclusively for payment operations." Keep the two conditions exactly as written: an account held in the user's name, and a use limited to payment operations only. That is the framework of the payment account in Morocco that licensed institutions hold. We quote the text without interpreting it or drawing any promise from it.

Notice the nature of this list, too: it names operations, never products or brands. It says which operations fall under the status, and nothing more.

A payment account is easier to understand once you see one at work, and it costs nothing: Start in test mode. Three fields (name, work email, company), an activation link received by email to choose your password, then the portal, where you create your own test key after re-authenticating and make a first payment with the test card, with no real money involved. It is free, with no time limit and no approval to wait for: your business verification (KYB) only gates the move to production.

What a payment institution does not do

Three limits stand out in the text. The first comes from Article 12: banks alone can be authorized to receive funds from the public that are payable on demand or have a term of two years or less. The second comes from Article 16 itself, whose point 2 excludes from payment services any operations made by check, by bill of exchange, by postal money order issued or paid in cash, and by any similar paper-based instrument. The third comes from the list: credit is not on it, and credit operations are one of the activities that define a credit institution (Article 1).

The law creates no "online bank" category: the categories are the ones the text names, and an app or a brand, however polished, does not create a status of its own. What this means for a merchant who needs to collect payments is covered in what an online bank does and does not do for merchants.

A concrete example, our own: ChariPay is a Moroccan payment platform, a PSP operated by Chari Money, a payment institution licensed by Bank Al-Maghrib. ChariPay is not a bank: your payment account is held by Chari Money.

That leaves a question every merchant asks: if only banks can be authorized to take funds payable on demand, what happens to the money recorded in a payment account? It falls under Articles 2 and 17 of the law, which we cover separately in how payment account funds are safeguarded.

Licensing by Bank Al-Maghrib: Article 34

Article 34 of law 103-12 sets the rule: before doing business in Morocco, any legal entity considered a payment institution within the meaning of Article 15 must first be licensed by the Wali of Bank Al-Maghrib, after consulting the Credit Institutions Committee (comité des établissements de crédit). The licensing decision is published in the Official Bulletin.

Three elements of the text are directly useful to a merchant:

1. 1Who is licensed: a legal entity (personne morale), identified by its registered name, never a trade name or an app.
2. 2When: the license comes first; it must exist "before doing business in Morocco."
3. 3Where to read it: the decision is published in the Official Bulletin, and Bank Al-Maghrib keeps the list of licensed institutions (next section).

The documents and information to be provided are set by circular of the Wali of Bank Al-Maghrib (Article 34 again), and the central bank gathers its circulars, including the one setting the terms for providing payment services, on its "Conditions d'exercice (agrément)" page, cited in our sources. We summarize none of it here: on procedure, the official text prevails.

Operating without a license: what Article 18 provides

Article 18 of law 103-12 prohibits "any person not licensed as a credit institution or a payment institution from carrying out, on a regular professional basis, the operations referred to in Articles 1 and 16," subject to the exceptions the same article provides. We do not go through those exceptions, and we do not assess any specific setup: for your situation, only your advisor can give an opinion.

Three expressions frame the rule as written: "not licensed," "on a regular professional basis," and "the operations referred to in Articles 1 and 16," meaning the activities of a credit institution and the payment services listed above.

For a merchant, the practical consequence is one question to ask before handing your collections to anyone: which licensed entity carries out the operations, and in what capacity? The answer should name a legal entity, not just a brand. Platforms that collect payments on behalf of other sellers raise questions of their own, covered in collecting on behalf of others.

How many payment institutions are licensed, and where to find the list

The law entrusts the list to the central bank: Bank Al-Maghrib draws up and keeps up to date the list of licensed credit institutions and similar bodies, and the initial list and its changes are published in the Official Bulletin (Article 48).

On its Structure of the banking system page, consulted on October 2, 2026, Bank Al-Maghrib states that at the end of 2024, 93 credit institutions and similar bodies were licensed in Morocco, 18 of them payment institutions. The same page offers a downloadable list drawn up as of December 31, 2019; more recent licenses and changes to the list are published in the Official Bulletin. We copy no name: a copied list goes stale, the official publication prevails.

Three precautions when reading these figures:

• "at the end of 2024" is not "today": a license granted since then is not counted;
• the downloadable list stops at December 31, 2019: for a more recent license, the Official Bulletin is the place to look;
• the 93 cover every category of credit institution and similar body; payment institutions account for 18 of them.

To check a specific entity step by step, follow the method on our PSP in Morocco page.

Where ChariPay fits

ChariPay is a Moroccan payment platform, a PSP operated by Chari Money, a payment institution licensed by Bank Al-Maghrib. The license is held by Chari Money, the payment institution that operates ChariPay, licensed by Bank Al-Maghrib under law 103-12.

In other words, ChariPay is the platform (portal, API, payment pages) and Chari Money is the licensed entity. For any check, Chari Money's name is the one that matters; our page on who operates ChariPay introduces the company. ChariPay is not a bank: your payment account is held by Chari Money. It complements your bank; it does not replace it. The commercial role (collecting, tracking, paying out) is described on our PSP in Morocco page.

The market itself is changing. With card acquiring in Morocco opening up, a topic we cover in a dedicated article, the question "who holds the license?" matters all the more: it is the first one to ask any provider, before price.

Frequently asked questions

What is the difference between a payment institution and a bank?

A bank is a credit institution (Article 10). It can be licensed for all or part of the activities referred to in Articles 1, 7 and 16, payment services included, and banks alone can be authorized to receive funds from the public that are payable on demand or have a term of two years or less (Article 12). A payment institution is a body treated as similar to credit institutions that offers payment services (Articles 11 and 15).

Can a payment institution take deposits?

Article 12 reserves for banks the ability to be authorized to receive funds from the public that are payable on demand or have a term of two years or less. Article 16, on the other hand, lists among payment services "cash deposits and withdrawals on a payment account." What the law says about funds recorded in a payment account falls under Articles 2 and 17, covered in our article on how those funds are safeguarded.

Can a payment institution extend credit or issue a checkbook?

Credit is not among the payment services listed in Article 16: credit operations are one of the activities that define a credit institution (Article 1). Checks, for their part, are expressly excluded from payment services by the same Article 16. The ChariPay payment account, for example, has neither overdraft nor credit: an outgoing operation that exceeds the available balance is blocked.

Who grants a payment institution's license in Morocco?

The Wali of Bank Al-Maghrib, after consulting the Credit Institutions Committee, under Article 34 of law 103-12. The license must come first: a legal entity considered a payment institution must hold it before doing business in Morocco. The licensing decision is published in the Official Bulletin, and Bank Al-Maghrib draws up and keeps up to date the list of licensed institutions (Article 48).

How many licensed payment institutions are there in Morocco?

On its Structure of the banking system page, consulted on October 2, 2026, Bank Al-Maghrib states that at the end of 2024, 93 credit institutions and similar bodies were licensed in Morocco, 18 of them payment institutions. More recent licenses and changes to the list are published in the Official Bulletin: for a specific entity, the official publication prevails.

Can you provide payment services without a license?

Article 18 of law 103-12 prohibits any person not licensed as a credit institution or a payment institution from carrying out, on a regular professional basis, the operations referred to in Articles 1 and 16, subject to the exceptions the text provides. We do not assess any specific setup: for your situation, only your advisor can give an opinion.

Is ChariPay a payment institution?

ChariPay is a Moroccan payment platform, a PSP operated by Chari Money, a payment institution licensed by Bank Al-Maghrib. The license is held by Chari Money, the payment institution that operates ChariPay, licensed by Bank Al-Maghrib under law 103-12. ChariPay is not a bank: your payment account is held by Chari Money.

Next step

First, remember who holds the license: Chari Money, the payment institution that operates ChariPay, licensed by Bank Al-Maghrib under law 103-12. Then watch the platform at work, with no real money: Start in test mode; your business verification only gates the move to production. To go further, read how payment account funds are safeguarded.

Sources

• Bank Al-Maghrib — Law No. 103-12 on credit institutions and similar bodies, consolidated version as of March 31, 2022 (PDF, in French), Articles 1, 7, 10, 11, 12, 15, 16, 18, 34 and 48 — read on October 2, 2026
• Bank Al-Maghrib — Conditions d'exercice (agrément), licensing conditions — read on October 2, 2026
• Bank Al-Maghrib — Structure of the banking system — read on October 2, 2026