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Rapport ESG obligatoire (Circulaire AMMC n° 03/19, section 3 - Rapport ESG, annexe III.2.M)

ESG reporting in Morocco is already mandatory for listed issuers - the gap is quality, not existence.

IMPORTANT CORRECTION to the common belief that ESG reporting is voluntary in Morocco: since the 2019 AMMC circular, ESG reporting is REGULATORY, not optional. Issuers making a public offering (excluding the SME compartment) must include an ESG report in their annual financial report, covering environmental, social and governance issues and the company's responses. It operates on a COMPLY-OR-EXPLAIN basis with a materiality principle, and no single reference framework is imposed (GRI is the de facto standard used). First reports were published in 2020. Compliance is now near-universal (94 issuers concerned in 2023, only 3 non-publishing - ~97% compliance). The AMMC, with IFC support, built an ESG report quality-assessment tool and has signalled that recommendations will be followed by REGULATORY TIGHTENING.

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