E-invoicing is one of the most significant tax reforms of the decade for Moroccan businesses. The principle was laid down in the General Tax Code (Article 145-IX, from the 2018 Finance Act), but its practical rules depend on an implementing regulation. According to public statements by the Tax Authority (DGI), a draft decree is under review by the General Secretariat of the Government and a phased rollout is announced for 2026. At the time of writing we have not identified publication of the decree in the Official Bulletin, so businesses should start preparing now rather than wait.
A Two-Stage Legal Framework
The legislator first enshrined the principle of the electronic invoice in the General Tax Code, leaving the conditions and timetable to an implementing text. That text will specify the categories of businesses concerned, the implementation stages and the technical obligations. Any definitive analysis therefore remains provisional until the decree is published.
The Announced Model: “Clearance”
According to the DGI, the system relies on prior validation. Each invoice is sent to the tax authority’s platform, which checks its admissibility in real time before forwarding it to the customer with a date and acknowledgment of receipt. In practice:
- the invoice becomes structured data (UBL format, an international standard), no longer a simple PDF sent by email;
- it must be electronically signed;
- an invoice rejected by the platform is, in practice, not validly issued, with direct consequences for collection and VAT deduction.
Who Is Concerned, and When?
Rollout is expected to be gradual and differentiated by company size, similar to the phased introduction of e-filing and e-payment or of the payment-term rules. Initially, only business-to-business (B2B) transactions would be covered. Very small businesses would have a free web interface provided by the DGI, while companies with an ERP could connect through an automated interface. Certified providers may take part in validation later. A business not yet required to issue e-invoices must nonetheless be able to receive them from its suppliers.
Summary Table
| Topic | What is announced | Point of attention |
|---|---|---|
| Legal basis | Article 145-IX of the General Tax Code + implementing decree | Decree not published to our knowledge |
| Initial scope | B2B transactions | B2C not envisaged at this stage |
| Model | Prior validation by the DGI (clearance) | Rejected invoice = invalid invoice |
| Format | Structured UBL data, electronic signature | A PDF alone is no longer enough |
| Timetable | Phased rollout announced for 2026 | Exact dates set by the decree |
Legal and Contractual Issues
Beyond technology, the reform touches several legal areas. For tax purposes, the validated invoice conditions VAT traceability and deduction. Contractually, general terms of sale, invoicing clauses and the starting point of payment terms (Law 69-21) should be aligned with the invoice validation date. On evidence, electronic signatures fall under Law 43-20. Finally, the link with tax audits makes the quality of invoicing data decisive.
Practical Points of Vigilance
- Map your invoicing flows (customers, suppliers, ERP, billing tools).
- Check with your software vendor or accountant that the structured format and electronic signature are supported.
- Update contracts and general terms: mandatory mentions, invoice date, rejection procedure.
- Clean up customer and supplier records (ICE common business identifier, company name, addresses).
- Appoint an internal lead and train accounting and sales teams.
- Follow publication of the decree in the Official Bulletin and DGI communications to learn your timetable.
Conclusion
E-invoicing will not be a mere IT upgrade: it changes the legal value of the invoice and its tax and contractual effects. Businesses that anticipate will limit the risks of rejection, late payment and tax reassessment. This article provides a general overview and does not constitute legal advice. Westfield law firm assists businesses in analysing these obligations and adapting their contracts; please feel free to contact us.