Morocco — E-Invoicing / Facturation Électronique (DGI)

Morocco is moving towards mandatory electronic invoicing (facturation électronique / la facture électronique / الفوترة الإلكترونية), administered by the Direction Générale des Impôts (DGI). The legal hook is Article 145-IX of the Code Général des Impôts (CGI), which empowers the administration to require an IT-based invoicing system meeting technical criteria set by regulation. The operative detail — formats, thresholds, the platform, and the go-live dates — is to be fixed by an implementing decree (décret d'application) that, as of the last research update, had not yet been published in the Bulletin Officiel.

This skill replies in the user's language. Moroccan users mix English, French, and Darija — keep the native terms (DGI, ICE, IF, TVA, SIMPL, facturation électronique, CTC) and explain them once.

READ THIS FIRST. Mandatory B2B/B2C e-invoicing in Morocco is an announced roadmap, not a regime in force. Do not tell a user they "must e-invoice from [date]" — the start dates, scope thresholds, and even the final clearance model are pending the décret d'application. What is already binding is (a) the paper/PDF invoice-conformity rules under CGI Art. 145, and (b) the SIMPL télédéclaration/télépaiement obligations. Anchor advice on those.

|---| | Topic | E-invoicing / facturation électronique | | Authority | Direction Générale des Impôts (DGI), tax.gov.ma | | Currency | MAD (dirham) | | Legal basis | CGI Art. 145-IX (e-invoicing enabling provision); CGI Art. 145 (invoice mentions); Art. 146, 192, 198 ter (sanctions) | | Status | Roadmap — pending. Implementing decree NOT yet published; go-live dates UNCONFIRMED | | Announced model | Continuous Transaction Control (CTC) / pre-clearance — verify in final decree | | Announced formats | UBL / CII (e.g. UBL 2.1) — verify | | Platform | DGI national platform built by xHub, integrated with Simpl-TVA; public brand name (e.g. fatourati.gov.ma) NOT confirmed — verify | | Already in force | SIMPL télédéclaration & télépaiement (mandatory for enterprises since 2017); ICE on invoices | | Sequencing (announced) | Large companies (B2B) first → SMEs → small enterprises → B2C — verify dates | | Quality tier | Research-verified — pending sign-off by a Moroccan expert-comptable | | Tax year | 2026 | | Version | 1.0 | | Last research update | Mid-2026 |

Conservative defaults

• Default to "pending / verify." If a user asks "when does it start" or "what format," answer with the announced position and immediately flag that the décret d'application is not yet published. Never present a date as settled law.
• Default to current-law conformity. Whatever happens with e-invoicing, an invoice that already satisfies CGI Art. 145 (ICE, IF, sequential numbering, TVA breakdown) is the safe baseline. Advise the user to fix paper/PDF conformity first.
• Default to escalation for go-live decisions. Onboarding to a clearance platform, choosing an OD/PDP-style provider, or changing the invoicing workflow is a reviewer decision once the decree lands — flag to an expert-comptable.
• Never invent thresholds. The turnover/headcount cut-offs for each wave are decree-defined and not yet public. Do not guess MAD figures.

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2. Current Invoicing Rules (in force today)

These apply now, on paper or PDF, regardless of the e-invoicing roadmap. A "regular invoice" (facture régulière) is the precondition for the customer's right to deduct TVA and expenses (CGI Art. 146 / Art. 106). A missing or defective mention is the single most common reason the DGI rejects deductible TVA on audit.

Mandatory mentions (mentions obligatoires) — CGI Art. 145

The seller must show:

1. Seller identification — raison sociale / name, address, and the seller's Identifiant Fiscal (IF), Taxe Professionnelle (TP) number, Registre de Commerce (RC) number where applicable, and the ICE.
2. ICE — Identifiant Commun de l'Entreprise. A 15-digit common business identifier. The seller's ICE has been mandatory on invoices since 2016 (CGI Art. 145-VIII). The client's ICE is mandatory in B2B transactions (since January 2019). Both ICEs on a B2B invoice is the rule.
3. Customer identification — name/raison sociale, address, and (B2B) the customer's ICE.
4. Sequential invoice number (numérotation chronologique et continue) — no gaps; a single uninterrupted series.
5. Date of issue.
6. Description of goods/services, quantity, unit price HT (hors taxe).
7. Total HT, the TVA rate(s) and TVA amount broken down by rate (ventilation de la TVA par taux), and the total TTC (toutes taxes comprises).
8. Terms / mode of payment (modalités de paiement) where required.

Native-term note: HT = hors taxe (net of VAT); TTC = toutes taxes comprises (VAT-inclusive); TVA = taxe sur la valeur ajoutée. Rates from 2026 are principally 20% and 10% (7% and 14% phased out — see morocco-vat).

Self-employed / auto-entrepreneur note

An auto-entrepreneur (statut AE) still issues conforming invoices and carries an ICE. AE invoices are typically out of scope for TVA where the person is not TVA-registered, but the Art. 145 identification and numbering rules still apply. See ma-auto-entrepreneur for the regime and morocco-vat for TVA treatment.

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3. The E-Invoicing Roadmap (status: UNCONFIRMED)

Everything in this section is announced / expected, drawn from DGI communications, the PLF (projet de loi de finances) 2026 process, and Big-4 / vendor commentary. None of it is settled until the décret d'application is published in the Bulletin Officiel. Treat all dates as provisional.

Legal mechanism

• CGI Art. 145-IX is the enabling provision: it lets the DGI mandate an IT-based invoicing system meeting technical criteria, with the specifics delegated to a regulatory text.
• As of the last research update, the draft implementing decree had been transmitted within government (reported as sent to the Secrétariat Général du Gouvernement) but was not yet published. Until publication, no mandatory e-invoicing obligation is legally effective. (verify current status against the Bulletin Officiel and tax.gov.ma before advising.)

Expected model — Continuous Transaction Control (CTC / pre-clearance)

• Commentary points to a clearance / CTC model: each invoice would be validated by the DGI platform before it is legally valid, rather than a post-audit model where invoices are exchanged freely and checked later.
• The DGI was reported to have considered both post-audit and CTC; CTC / pre-clearance is the most-cited expectation but is not formally confirmed in a published text. (verify.)

Expected platform

• A national DGI platform, developed by Moroccan firm xHub (Casablanca Technopark), integrated with the existing Simpl-TVA environment.
• A confirmed public-facing brand/URL (some sources speculate names such as fatourati.gov.ma) is NOT verified. Do not state a platform URL as fact.

Expected formats

• Structured formats aligned to international standards — UBL (e.g. UBL 2.1) and/or CII — for interoperability. (verify exact format and version in the technical spec / decree.)

Expected sequencing (waves)

• A phased rollout by size/type is expected: large companies (B2B) first, then SMEs, then small enterprises, then B2C last. Specific dates and the turnover/headcount thresholds for each wave are decree-defined and not yet public — do not quote figures.

What this means for a freelancer

A typical self-employed person or micro-business sits in the later waves (small enterprise / B2C), so even on the most aggressive announced timeline they are unlikely to be in the first cohort. The honest position: the obligation is coming, the exact date for your tier is unknown, prepare but do not panic.

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4. Penalties

Two layers: invoice-conformity penalties that exist today, and future e-invoicing-specific penalties that the decree may add.

In force today (CGI)

• Missing / wrong ICE — penalty reported as MAD 100 per omission, capped around MAD 5,000 per fiscal year (CGI Art. 198 ter). (verify amounts against current Loi de Finances.)
• Insufficient / irregular invoicing — sanction reported in the range MAD 2,000 to MAD 50,000 (CGI Art. 146). (verify.)
• Fictitious / fake invoices (factures fictives) — MAD 5,000 to 50,000 and potential criminal exposure (imprisonment) under CGI Art. 192. Serious; escalate.
• Practical worst case: loss of deduction. On audit the DGI routinely rejects the customer's TVA and expense deduction on a non-conforming invoice (no ICE/IF, broken numbering). This is usually costlier than the fixed fine.

Future (e-invoicing-specific) — NOT yet set

• The implementing decree is expected to introduce specific sanctions for failure to issue cleared e-invoices, use of a non-compliant format, or non-transmission to the platform. These do not exist as published, quantified penalties yet. Do not state amounts. (verify on decree publication.)

All penalty figures above are from secondary/research sources and require confirmation against the live CGI and the latest Loi de Finances by a Moroccan expert-comptable before being relied on.

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5. What To Do Now

Practical, low-regret steps for a self-employed person — none of which depend on the decree landing:

1. Get and use your ICE. Confirm your 15-digit ICE is obtained and printed on every invoice. Verify it (and your B2B clients' ICEs) where possible.
2. Make invoices Art. 145-conforming today. Seller IF/TP/RC/ICE, client ICE (B2B), continuous sequential numbering with no gaps, dates, descriptions, HT / TVA-by-rate / TTC breakdown. This is the baseline that survives any reform.
3. Use structured invoicing software, not loose Word/Excel. Pick a tool that keeps an unbroken numbering series and can export structured data. Vendors are already marketing "DGI 2026 ready / e-facture" software — treat such claims as marketing, not certification, until the DGI publishes conformity criteria.
4. Keep your SIMPL access live. Télédéclaration/télépaiement via SIMPL (portail.tax.gov.ma) is already mandatory for enterprises. Ensure credentials, email, and bank mandate work — the e-invoicing platform is expected to sit alongside this environment.
5. Watch the Bulletin Officiel and tax.gov.ma for the décret d'application and the DGI technical specification. The decree is the trigger event; nothing is mandatory before it.
6. Identify your likely wave. Large B2B is first; a freelancer is almost certainly later. Don't onboard to a clearance platform prematurely.
7. Escalate the go-live decision to a Moroccan expert-comptable once the decree is published — format choice, provider selection, and workflow change are professional-review items.

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6. Reference + Test Suite

Reference

• CGI Art. 145 — mandatory invoice mentions (incl. Art. 145-VIII ICE).
• CGI Art. 145-IX — e-invoicing enabling provision (decree pending).
• CGI Art. 146 / Art. 106 — regular-invoice precondition for deduction.
• CGI Art. 192, 198 ter — invoice-related sanctions.
• Décret d'application (CGI 145-IX) — PENDING publication in the Bulletin Officiel; verify.
• PLF / Loi de Finances 2025–2026 — roadmap context; verify final wording.
• SIMPL — DGI télédéclaration/télépaiement portal (portail.tax.gov.ma).
• DGI: tax.gov.ma. Cross-skills: morocco-vat, ma-auto-entrepreneur, ma-bookkeeping, ma-income-tax.

Test suite

T1 — "When is e-invoicing mandatory for me?" → State it is an announced roadmap, decree pending, dates UNCONFIRMED; freelancers are in later waves; do not quote a date. PASS only if no date asserted as fact.

T2 — "Is fatourati.gov.ma the official platform?" → Platform is a DGI/xHub build integrated with Simpl-TVA; the public brand/URL is not confirmed. Do not assert the name.

T3 — "What must be on my invoice today?" → ICE (seller, + client if B2B), IF, TP/RC, sequential number, date, description, HT, TVA per rate, TTC, payment terms.

T4 — "I forgot my client's ICE on a B2B invoice." → Non-conforming; risks client's TVA/expense deduction on audit + ICE-omission penalty (~MAD 100/omission, verify). Reissue correctly.

T5 — "Which format — UBL or CII?" → Announced UBL/CII; exact format/version verify in the DGI technical spec; not yet binding.

T6 — Auto-entrepreneur asks if e-invoicing applies. → Same roadmap; AE still must issue Art. 145-conforming invoices with ICE now; later wave for clearance. Cross-ref ma-auto-entrepreneur.

T7 — "What's the penalty for a fake invoice?" → CGI Art. 192: MAD 5,000–50,000 plus possible imprisonment; serious; escalate. Verify amounts.

T8 — Vendor says software is "DGI 2026 certified." → No published conformity criteria yet; treat as marketing; verify after decree.

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PROHIBITIONS

• NEVER assert an unconfirmed go-live date as fact. The décret d'application is pending; all dates are provisional until published in the Bulletin Officiel.
• NEVER state the clearance model (CTC/pre-clearance) as legally settled — it is the expected model, not confirmed in a published text.
• NEVER assert a platform name/URL (e.g. fatourati.gov.ma) as official — not confirmed.
• NEVER quote wave thresholds (turnover/headcount) — decree-defined, not public.
• NEVER state e-invoicing-specific penalty amounts — not yet published.
• NEVER accept an invoice without IF/ICE as conforming.
• NEVER tell a freelancer to onboard to a clearance platform before the decree — that is a reviewer decision.
• NEVER compute amounts — defer arithmetic to the engine; this skill states rules and status only.

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Disclaimer

This skill is research-verified from DGI communications, the Loi de Finances / PLF 2025–2026 process, and Big-4 / vendor commentary, and is pending sign-off by a qualified Moroccan expert-comptable. Morocco's mandatory e-invoicing regime is an announced roadmap: the implementing decree was still pending at the last research update, so dates, scope, formats, the platform, and e-invoicing-specific penalties are subject to change and must be verified against the Bulletin Officiel and tax.gov.ma before being relied on.

Outputs are for informational and computational purposes only and do not constitute tax, legal, or financial advice. All outputs must be reviewed and signed off by a qualified professional before filing or acting upon. The most up-to-date, verified version of this skill is maintained at openaccountants.com.