CRI Invest and Rokhas: two digital platforms, two different audiences, one crossing point for the investor

CRI-Invest is aimed at investors and project sponsors; Rokhas is aimed at every profile, from the private individual building a house to the company declaring its activity. Understanding this difference in audience keeps an investor from overestimating — or underestimating — what each platform does for them.

A misconception to correct right away: the CRI does not hold a monopoly on business creation

In practice, the CRI remains the most used channel for incorporating a company in Morocco — that is what our Briefs No.1 and No.2 document. But contrary to a widespread belief, it has never, as a matter of law, been a compulsory step: no provision of Law No. 47-18 or any other text requires incorporating a company physically at the CRI[1]. What Law No. 88-17 on the electronic creation and support of businesses, and its Implementing Decree No. 2-22-92, changed starting in 2024 is the emergence of a fully dematerialized channel as an alternative to the physical counter: a project sponsor can now incorporate their company online, without traveling, via the directentreprise.ma platform, under the joint supervision of the Ministries of Justice, Finance, and Industry and the General Secretariat of the Government[2]. This online channel thus coexists with the CRI counter rather than replacing it, and its roll-out remains gradual, jurisdiction by jurisdiction, as the necessary joint orders are published.

The right instinct on paperwork: work with a licensed professional rather than improvise

We deliberately do not detail, in this Brief, the document-by-document list for an incorporation file — that list evolves and differs by legal form chosen. Our recommendation is a methodological one: incorporating a company involves acts that Moroccan law reserves to clearly identified professions, and engaging one of these professionals markedly reduces the risk of error or an incomplete file. These include the chartered accountant, a profession regulated by Law No. 15-89 and organized by the Order of Chartered Accountants[3]; the licensed accountant, a profession organized by Law No. 127-12 as amended and supplemented by Law No. 53-19[4]; and, depending on the nature of the acts to be drawn up or authenticated, the notary or the lawyer. This list is not exhaustive and deserves to be supplemented case by case according to the legal form and sector of the project.

This is precisely the coordinating role WL Advisory plays for the investors it supports: as PMO (Project Management Officer) of the investment journey, our firm does not replace the regulated professions mentioned above, but orchestrates their involvement, secures the timeline, and interfaces with the administrations concerned — from the CRI counter to platforms like Rokhas — throughout the project, rather than on a one-off basis.

Rokhas: a different platform, for a different purpose, under different oversight

Once the company is created, a project involving construction, land subdivision, a declaration of economic activity, or the occupation of municipal public land follows a separate track: the Rokhas.ma platform, which dematerializes the receipt, review and issuance of urban-planning authorizations and certain economic authorizations. It rests on its own legal basis — Decree No. 2-18-577 of June 12, 2019 approving the general building regulations, joint Orders No. 337-20 and No. 338-20 of January 21, 2020 setting out the required documents and the dematerialized procedure, and Ministry of the Interior circular No. D-2314 of April 23, 2020 organizing the dematerialized management of authorizations via Rokhas.ma[5]. It is precisely this circular, issued by the Ministry of the Interior, that organizes the dematerialized management of these authorizations via Rokhas.ma — which establishes, through the regulatory text itself, that oversight of the platform lies with the Ministry of the Interior, not the Ministry of Investment under which the CRI network falls. The primary basis for this requirement is, moreover, not specific to Rokhas: Article 40 of Law No. 12-90 on urban planning provides that “no construction may proceed without a building permit having been obtained”[6], a general obligation that applies to anyone who builds, with no distinction as to investor status — Rokhas is merely the dematerialized channel for this pre-existing obligation, not a mechanism created for investors. The scope covered by the platform — building permits, land subdivision and parcelling, occupancy permits, declarations of classified economic activities, occupation of public land, work on public utility networks, and outdoor advertising — thus remains municipal in nature, independent of a project’s “investment” status.

Two digitization logics that intersect without merging

CRI-Invest and Rokhas both serve the State’s stated digitization goal, but they do not cover the same scope or sit under the same oversight. CRI-Invest is the platform of the CRI network, whose oversight passed to the Ministry of Investment starting in 2022, as documented in our Brief No.1[7]; it centralizes, at the regional level, the tracking of an investment file and the acts reviewed collectively by the CRUI — State-owned land, urban-planning exemptions, impact studies, eligibility for incentives, documented in our Brief No.3. Rokhas, by contrast, remains under the oversight of the Ministry of the Interior (Directorate General of Local Authorities) and operates at the municipal level, to handle — whether or not it is an investment project — the final urban-planning administrative act itself, in particular the building permit issued by the municipality. The two platforms are therefore not housed under the same institutional oversight: we found no source confirming that CRI-Invest would be administered by the Ministry of the Interior.

No text today legally links the two tracks: Law No. 47-18 (CRI-Invest) and Law No. 12-90 / Decree No. 2-18-577 (Rokhas) form two separate legal regimes, passed and published independently of one another, with no provision referring from one to the other. An urban-planning exemption obtained from the CRUI under Article 29 of Law 47-18 therefore does not exempt a project from the building-permit application proper, which remains governed by the general-law regime of Law 12-90 and is filed, as for any project, via Rokhas.

Two platforms, two audiences: what each one’s regulatory framework says

CRI-Invest’s regulatory framework is built, from beginning to end, around the notion of investment: Law No. 47-18 tasks the CRI with contributing “to the development of investment” and to “business support”[8], structures one of its two operational divisions around the “Investor’s House”[9], and entrusts the CRUI with reviewing files relating to “investment projects”[10]. At no point does the text define a procedure open to a project sponsor with no investment purpose at all: the audience targeted by the legal framework is, by design, the investor or the company.

Rokhas’s regulatory framework follows the opposite logic: the building-permit requirement set by Article 40 of Law No. 12-90 is general and applies to anyone who builds, with no reference to investor status or project amount. Decree No. 2-18-577 and joint Orders No. 337-20 and No. 338-20, which set out the required documents and the dematerialized procedure on Rokhas.ma, implement this same general-law obligation, without creating a separate regime for investors or referring back to Law 47-18. The audience covered by this framework is therefore, by design, broader than that of CRI-Invest: it includes any sponsor of a construction project or classified economic activity, whether or not it constitutes an investment within the meaning of Law 47-18.

This Brief’s title should therefore be read precisely: it is not that CRI-Invest and Rokhas target the same audience under their respective founding texts — they do not — it is that one and the same investor, when their project has a construction or urban-planning component, ends up having to follow both regimes, each for the matter it covers. Any project sponsor falling solely under the general-law regime of Law 12-90, with no component falling under Law 47-18, has, by contrast, no legal reason ever to go through CRI-Invest.

The WL Advisory perspective

A misconception to correct, not a rule that changed: the CRI has never, as a matter of law, been a compulsory step for incorporating a company — it is its position as the most-used channel in practice that fed this confusion, not the text of the law. What Law 88-17 adds, then, is not the lifting of an obligation, but a fully dematerialized alternative that makes this choice more visible. In practice, the CRI retains a real advantage for any project that combines business creation with investment-related administrative acts, since it remains the entry point into the CRUI track documented in our Brief No.3 — but a straightforward project sponsor, with no land or incentive component, stands to gain from knowing about the online alternative.

Two different audiences, not two counters for the same profile: the mistake to avoid is not only believing that Rokhas and CRI-Invest are interchangeable, but believing that they address the same audience. CRI-Invest’s founding text (Law 47-18) is built around investment and the enterprise; Rokhas’s founding text (Law 12-90 and its implementing decrees) sets a general building-permit requirement that applies to anyone, with no reference to investor status. An investor should therefore not expect to find, on Rokhas, treatment designed for their profile: under the text that founds it, they are one project sponsor among others, on the same footing as a private individual building their house.

Ignoring Rokhas risks stalling at the municipality after succeeding at the CRI: an investor can obtain a favorable CRUI opinion on their project and then run into a municipal track they had not anticipated in order to secure their building permit — a track designed for the general public, not for their investor profile. Our recommendation, drawn from direct experience with this type of file: build Rokhas into the planning from the upstream phase, on the same footing as the CRUI track, rather than discovering this second platform after a favorable regional decision.

Two oversight bodies, two separate legal regimes, no textual bridge: CRI-Invest falls under the Ministry of Investment, Rokhas under the Ministry of the Interior — two different oversight bodies, contrary to a belief sometimes heard that the two platforms would be hosted by the same department. This is not merely an administrative detail: Law 47-18 and Law 12-90 are two legal regimes passed independently, with no provision referring from one to the other. An investor should therefore never assume that a favorable decision obtained under one exempts them from the steps required under the other, nor that a technical convergence between the two platforms would already be generalized across the 12 CRIs in the absence of any text organizing it.

A licensed professional upstream, more useful than a detailed checklist: rather than a document checklist that evolves with each new text, our standing recommendation is to engage, from the project-structuring stage, a chartered accountant, a licensed accountant, or, depending on the acts to be drawn up, a notary or a lawyer — professions whose legal framework guarantees the reliability of the file filed, whether at the CRI or on Rokhas.

End-to-end steering, more useful than fragmented support: beyond each professional taken in isolation, it is the overall coordination between the CRI, the CRUI, Rokhas and the licensed professionals that determines how smoothly a project actually runs. This is the role WL Advisory plays in practice for the investors it supports, as PMO of the end-to-end investment journey.

What this means for you

For an investor: do not assume that the CRI is, or has ever been, a compulsory step for incorporating your company — assess whether the online route under Law 88-17 suits your project. Keep in mind that Rokhas is not a platform designed for your investor profile: its founding text (Law 12-90) is a general-law regime you share with any construction project sponsor, and it will process your file with no particular regard for the CRUI track you may have followed elsewhere. Anticipate, from the structuring phase onward, that any urban-planning component of your project will go through Rokhas in addition to, not instead of, the CRUI track — the two legal regimes do not exempt each other. Get support from a licensed professional (chartered accountant, licensed accountant, notary or lawyer depending on the acts involved) rather than putting together a file on your own — WL Advisory can provide, as PMO, end-to-end coordination between these parties and the administrations concerned, including for the Rokhas component. For an institution or technical partner: the absence of a textual bridge between Law 47-18 and Law 12-90 is a concrete advocacy point for eventually simplifying the investor’s end-to-end journey.

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Sources

[1]Law No. 47-18 on the reform of the Regional Investment Centers, Articles 4 and 18 — the CRI is defined there as a support counter, not as a legally compulsory step for the incorporation act itself.

[2]Law No. 88-17 on the electronic creation and support of businesses; Implementing Decree No. 2-22-92, adopted in the Council of Government on March 28, 2024; Médias24, “Online business creation: what the implementing decree provides for,” March 29, 2024.

[3]Law No. 15-89 regulating the chartered-accountant profession and establishing an Order of Chartered Accountants.

[4]Law No. 127-12 on the organization of the licensed-accountant profession and the establishment of the Professional Organization of Licensed Accountants, as amended and supplemented by Law No. 53-19.

[5]Decree No. 2-18-577 of June 12, 2019 approving the general building regulations; joint Orders No. 337-20 and No. 338-20 of January 21, 2020; Ministry of the Interior circular No. D-2314 of April 23, 2020.

[6]Law No. 12-90 on urban planning, Article 40.

[7]Statements by the Ministry of the Interior before Parliament, November 12, 2022, on the transfer of CRI oversight.

[8]Law No. 47-18 on the reform of the Regional Investment Centers, Article 4.

[9]Law No. 47-18, Article 18.

[10]Law No. 47-18, Article 29.