Principal agent of a payment institution in Morocco: what a partner needs to know
In short
- The payment institution is the entity licensed by Bank Al-Maghrib to offer payment services and hold payment accounts. At Chari Money, that is Chari Money.
- The partner that wants to offer these services under its brand does not become a payment institution: it must be approved by Bank Al-Maghrib, through the granting of principal agent status.
- Each new use case requires the prior approval of the Banking Supervision Directorate.
- Payment account funds are deposited in a global, separate and individualized account, and ring-fenced in the institution's accounts (law 103-12, article 17).
Why this status exists
A business that wants to offer a wallet, transfers or bill payment to its users enters the field of payment services. In Morocco, that field is reserved: article 18 of law 103-12 prohibits anyone not licensed as a credit institution or a payment institution from carrying out these operations on a regular basis.
Two routes are then open: apply for its own license, or rely on an institution that is already licensed. The second route does not mean no framework at all. With Chari Money, the partner wishing to use the financial services on a white-label basis must be approved by Bank Al-Maghrib, through the granting of principal agent status. That condition, published across our site, is what this article explains. We quote the texts without interpreting them: only your advisor can give an opinion on your situation.
What law 103-12 calls a payment institution and a payment service
Law 103-12 on credit institutions and similar bodies sets the vocabulary.
| Notion | What the text says |
|---|---|
| Payment institution (art. 15) | It offers one or more of the payment services referred to in article 16, and may also carry out foreign exchange operations in compliance with the texts in force. |
| Payment services (art. 16) | Fund transfers; cash deposits and withdrawals on a payment account; execution of payment operations through any means of remote communication, where the operator acts only as an intermediary between the payer and the supplier; direct debits, card payments and transfers involving funds held in a payment account. |
| Payment account (art. 16) | Any account held in the name of a payment services user and used exclusively for payment operations. |
| Payment account funds (art. 17) | Deposited in a global, separate and individualized account with a credit institution authorized to receive sight deposits; distinctly identified and ring-fenced in the payment institution's accounts. |
| Reserved activity (art. 18) | Prohibited, on a regular basis, for anyone not licensed as a credit or payment institution. |
Article 16 also specifies what is not a payment service: payments by check, by bill of exchange, by postal order issued or paid in cash, or by any other similar paper instrument. On its page on payment systems and means of payment, Bank Al-Maghrib presents payment institutions as the category authorized to hold payment accounts and offer payment services.
For an overview of the texts, see our guide to fintech regulation in Morocco and our article on the payment institution in Morocco.
Principal agent status at Chari Money
Chari Money, a payment institution licensed by Bank Al-Maghrib, operates a white-label fintech infrastructure. The partner that uses it takes principal agent status. In practice, as Chari Money describes it:
- the principal agent is an authorized partner that represents Chari Money and operates on its behalf;
- it offers financial services to its customers, under its brand;
- it manages its own sub-agents or customers under its supervision;
- this status is granted upon Bank Al-Maghrib's approval.
In the API, this status has a direct translation: the principal agent's account is the one debited for certain operations, such as a telecom top-up paid by the partner, and it is the one funded with float. Our guide to launching a fintech in Morocco places this status in the partner's full journey.
A prior approval per use case
The second pillar is less well known: launching any new use case requires the prior approval of the Banking Supervision Directorate, evidenced by a non-objection document.
A use case is a precise combination: which service, for which users, on which channel. A few examples of situations that call for a new approval:
- You launched a wallet for your couriers and want to open it to your customers.
- You add bill payment or telecom top-ups to an existing wallet.
- You want to distribute your services through a network of points of sale.
- You add cards linked to the accounts.
In each of these cases, the technology can be ready in the sandbox well before the approval. That is normal: the sandbox is a technical step and is not an authorization to launch.
What the status does not do
- It does not make the partner a payment institution. The license remains Chari Money's.
- It does not cover every service at once. Each use case follows its own approval.
- It does not replace due diligence. KYC/KYB onboarding of customers remains at the heart of the setup; see our guide to KYC and KYB in Morocco.
- It does not concern a simple merchant. A business that only wants to be paid by its customers does not need this status: it goes through a payment platform for merchants, such as ChariPay, operated by Chari Money.
How to check a licensed institution
Before relying on an institution, a partner checks its license. Under article 48 of law 103-12, 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. The licensing decision is also published in the Official Bulletin (article 34). We copy no list: the official publication prevails.
For a merchant choosing a payment provider, the same question arises from another angle; ChariPay's PSP in Morocco page explains what to check on the merchant side.
Partner checklist
- Describe the use case precisely: service, users, channels, limits.
- Prepare the company's KYB documents and the customer KYC policy.
- Sign the agreement, then go through onboarding and compliance leading to approval.
- Integrate and test in the sandbox, without confusing validated tests with authorization.
- Launch only after approval for that use case, and prepare a new approval for each extension.
Next step
To check whether your project falls under principal agent status, see our compliance page and describe your use case to the team from the partners page. The partner API documentation gives you a parallel view of the integration.
Sources
- Bank Al-Maghrib - Law No. 103-12 on credit institutions and similar bodies, consolidated version (PDF, French), articles 15, 16, 17, 18, 34 and 48 - read on October 2, 2026
- Bank Al-Maghrib - Payment systems and means of payment, regulation (French) - read on October 2, 2026
Frequently Asked Questions
- What is a principal agent?
- At Chari Money, a principal agent is an authorized partner that represents Chari Money and operates on its behalf. It offers financial services and manages its own sub-agents or customers under its supervision. This status is granted upon Bank Al-Maghrib's approval, and any new use case requires the prior approval of the Banking Supervision Directorate.
- Does a principal agent become a payment institution?
- No. The payment institution is the entity licensed by Bank Al-Maghrib: in Chari Money's model, that is Chari Money. The partner operates under principal agent status, approved by Bank Al-Maghrib, without itself holding the payment institution license.
- What does law 103-12 say about payment services?
- Its article 16 lists the payment services: fund transfers, cash deposits and withdrawals on a payment account, remote payment operations where the operator acts only as an intermediary, direct debits, card payments and transfers involving funds held in a payment account. Its article 18 reserves these operations, on a regular basis, for licensed institutions.
- Where are payment account funds held?
- Article 17 of law 103-12 provides that funds recorded in payment accounts are deposited in a global, separate and individualized account with a credit institution authorized to receive sight deposits, and are distinctly identified and ring-fenced in the payment institution's accounts.
- Is a new approval needed to add a service?
- Yes. With Chari Money, launching any new use case requires the prior approval of the Banking Supervision Directorate. Adding bill payment or cards to a wallet that is already live is therefore prepared as a new file, even if the technical integration is ready.
- How do you check that a payment institution is licensed?
- Under article 48 of law 103-12, Bank Al-Maghrib draws up and keeps up to date the list of licensed institutions, and the initial list and its changes are published in the Official Bulletin. The official publication prevails; a list copied elsewhere goes stale.