{"id":2603,"date":"2026-10-26T10:00:00","date_gmt":"2026-10-26T10:00:00","guid":{"rendered":"https:\/\/wladvisory.net\/?p=2603"},"modified":"2026-10-09T06:48:44","modified_gmt":"2026-10-09T06:48:44","slug":"the-crui-the-body-that-decides-in-one-meeting-a-week-the-fate-of-an-investment-project","status":"publish","type":"post","link":"https:\/\/wladvisory.net\/fr\/the-crui-the-body-that-decides-in-one-meeting-a-week-the-fate-of-an-investment-project\/","title":{"rendered":"Le CRUI : l\u2019organe qui d\u00e9cide, lors d\u2019une r\u00e9union par semaine, du sort d\u2019un projet d\u2019investissement"},"content":{"rendered":"\n

Composition, chairmanship, quorum, voting, deadlines: how the Unified Regional Investment Commission actually works \u2014 and what its internal mechanics mean for an investor.<\/em><\/p>\n\n\n\n

A single body to replace a mosaic of commissions<\/strong><\/h2>\n\n\n\n

Before 2019, an investment project could have to go before several separate sectoral commissions, each competent over one part of the file \u2014 land, urban planning, the environment, incentives \u2014 with no single body to arbitrate the whole. Law No. 47-18 put an end to this fragmentation by creating, in each region, a Unified Regional Investment Commission (CRUI), the sole decision-making body for all administrative acts a project requires[1]<\/a>. Its mandate, set by Article 29 of the law, covers four families of decisions: the transfer or lease of State-owned land, urban-planning authorizations and exemptions, environmental impact studies, and eligibility for incentive schemes.<\/p>\n\n\n\n

Composition: a regional chamber, not a technical counter<\/strong><\/h2>\n\n\n\n

The CRUI is not a small panel of experts: its composition, set by Article 31 of Law 47-18, brings together most of the territorial administration concerned by a project \u2014 governors of the prefectures and provinces concerned (or their representatives), presidents of the municipal councils concerned (or vice-presidents), the CRI director, the Secretary General of regional services, a representative of the regional wilaya, the director of the Urban Agency or their representative, heads of decentralized state departments, and representatives of the public institutions concerned by the project[2]<\/a>. The chair may also invite anyone whose expertise is deemed useful to reviewing a file. In practice, the CRUI’s composition therefore varies from one meeting to the next depending on the projects on the agenda \u2014 each local authority and each technical department sits only for the files that concern it.<\/p>\n\n\n\n

Chairmanship: long the wali’s role, now the CRI director’s<\/strong><\/h2>\n\n\n\n

The original text of Law 47-18 was explicit: “the Regional Commission is chaired by the wali of the Region,” with a mere option to delegate, on a personal basis (intuitu personae), to the CRI director[3]<\/a>. This changed with Law No. 22-24: the chairmanship of the CRUI now falls, as a matter of right, to the CRI director, with the Center’s Secretary General \u2014 a position created by the same law \u2014 standing in for the chair when absent[4]<\/a>. This is no longer a simple optional delegation but a legal transfer of the chairmanship \u2014 and this transfer does not stop at the CRUI: the same Law 22-24 also moves the chairmanship of the CRI’s Board of Directors (the public institution’s governing body, distinct from the CRUI) from the wali to the Head of Government or an authority he delegates, with the wali now sitting only as a member, for two sessions a year[5]<\/a>. Law 22-24 thus redistributes the CRI’s two chairmanships between the tiers now competent for them: that of the Board of Directors goes to the Head of Government or his delegate, and that of the CRUI to the CRI director. This is, very concretely, the most complete operational expression of the transfer of CRI oversight to the Ministry of Investment begun in 2022: both the institution’s annual governance and the weekly steering of investment files are now organized around the CRI network and the Head of Government, while the wali retains a seat as a member of the Board of Directors and remains, as documented in our Brief No.1, a central actor in the appeal procedure.<\/p>\n\n\n\n

Quorum and voting: a majority of those present, not a required consensus<\/strong><\/h2>\n\n\n\n

Article 34 sets precise operating rules: quorum is reached once at least half the members are present or represented; failing that, a second meeting is called within one week, with no quorum requirement. Decisions are taken by a majority of the members present, with the chair’s vote breaking any tie[6]<\/a>. The commission meets, as a rule, at least once a week[7]<\/a> \u2014 a weekly cadence designed to prevent a file from waiting several weeks simply to be placed on the agenda.<\/p>\n\n\n\n

Deadlines: from 30 days (2019) to a tightened regime (2025)<\/strong><\/h2>\n\n\n\n

The original 2019 text set a maximum of 30 days from the filing of the file for the CRUI to rule[8]<\/a>. Law No. 22-24, adopted in December 2024 and published on January 20, 2025, tightens this framework: 20 days for the CRUI’s decision, 10 further days for administrative finalization by the departments concerned, transmission of files by the CRI secretariat within 2 days, and members convened 5 days before the meeting. Above all, CRUI opinions, initially reasoned but not systematically binding, become fully binding[9]<\/a> \u2014 a change in nature, not merely in timing: an administration can no longer, in theory, reverse a favorable CRUI decision.<\/p>\n\n\n\n

A mandate not to be confused with that of the investment agreement<\/strong><\/h2>\n\n\n\n

The CRUI rules on the administrative acts a project requires \u2014 land, urban planning, the environment, eligibility for an incentive scheme \u2014 but it is not the body that negotiates or signs the investment agreement itself, that is, the State’s contractual commitment on the tax and customs incentives granted to a project. For large projects, this second track remains the responsibility of the National Investment Commission; Law 22-24 has, however, decentralized the signing of agreements to CRI directors, under the wali’s oversight, for projects under MAD 250 million[10]<\/a>. For an investor, this means, concretely, two distinct processes to follow in parallel, not a single end-to-end one-stop shop \u2014 we will come back to this interplay, and to the mechanisms of the Investment Charter itself, in Briefs No.6 to 9 of this series.<\/p>\n\n\n\n

The WL Advisory perspective<\/strong><\/h2>\n\n\n\n

A single body, two nuances worth naming<\/strong>: the law presents the CRUI as the embodiment of the principle ‘one body, one decision.’ In practice, this holds largely true for the administrative acts covered by Article 29 \u2014 and it is a real improvement over the mosaic of commissions that existed before 2019. Our reading, drawing on direct experience of this type of institutional mechanism, nonetheless identifies two nuances that the text itself does not spell out.<\/p>\n\n\n\n

A composition that changes every week<\/strong>: because quorum requires only half the members present or represented, and composition changes with the items on the agenda, two investors filing comparable files the same week can, entirely lawfully, have their files reviewed by noticeably different commission line-ups. This is not a flaw in the law \u2014 it is a deliberate trade-off between flexibility and administrative heaviness \u2014 but it is a source of variability that deserves to be documented rather than assumed neutral, particularly for sensitive projects where the opinion of one specific decentralized department can tip the decision.<\/p>\n\n\n\n

A double transfer of chairmanship, with real weight<\/strong>: the 2025 transfer of the CRUI chairmanship from the wali to the CRI director is, in our view, the most significant regional governance reform of recent years \u2014 more significant, in its practical effects, than the 2022 announcement of the oversight transfer, because it shifts the weekly decision-making power itself, not just the ministerial reporting line. The CRI director now combines preparing the files with chairing the body that rules on them \u2014 a concentration of roles with a genuine logic of efficiency and accountability, but one that deserves to be named as such: a significant share of regional investment decision-making power now rests, every week, with a single person. This is not a problem in itself; it is a governance point worth building into an institutional investor’s or technical partner’s regional risk analysis, alongside the strength of the file itself \u2014 and a useful point of comparison with the role the wali retains in the appeal procedure, documented in our Brief No.1.<\/p>\n\n\n\n

Decisions to publish, not just to issue<\/strong>: consistent with the finding we already made in our Brief No.1, the law precisely frames the CRUI’s decision deadlines, but no provision requires publishing \u2014 file by file or even in aggregate \u2014 the approval rate, the grounds for rejection, or the sectoral and territorial breakdown of the decisions issued each week. Since CRI-Invest already centralizes this data for the 12 CRIs, publishing a standardized quarterly report of CRUI decisions \u2014 approved, rejected, pending \u2014 would be a natural extension, at near-zero marginal cost, of the existing digital infrastructure.<\/p>\n\n\n\n

What this means for you<\/strong><\/h2>\n\n\n\n

For an investor: your file is not judged by a fixed committee but by a commission line-up that varies with the agenda \u2014 the quality and completeness of the file filed upstream with the CRI therefore matter more than ever, since they determine how each department present will review it in a single sitting. Be sure to distinguish, in your planning, the CRUI track (administrative acts) from the investment-agreement track (incentives), which follow neither the same timeline nor, above MAD 250 million, the same decision-making body. For an institution or technical partner: the shift to fully binding opinions since 2025 changes the weight of a CRUI refusal \u2014 a reasoned rejection is now harder to work around administratively, which only strengthens the value of the 45-day appeal procedure introduced by this latest decree, presented in our Brief No.1.<\/p>\n\n\n\n

\n\n\n\n

Sources<\/h2>\n\n\n\n

[1]<\/a>Law No. 47-18 on the reform of the Regional Investment Centers and the creation of the Unified Regional Investment Commissions, Articles 29 et seq.; Implementing Decree No. 2-19-67 of April 17, 2019.<\/p>\n\n\n\n

[2]<\/a>Law No. 47-18, Article 31. See also the summary of the commission’s composition published by the Deryany Law Office, “Regional Investment Centers (CRI): what the law says,” August 31, 2025.<\/p>\n\n\n\n

[3]<\/a>Law No. 47-18 (2019), Article 31.<\/p>\n\n\n\n

[4]<\/a>Law No. 22-24 amending and supplementing Law No. 47-18; House of Representatives, discussion of draft Law No. 22-24, remarks by the Minister Delegate for Investment, Mohcine Jazouli, June 26, 2024; M\u00e9dias24, “CRI reform: the changes introduced by Law 22-24,” January 20, 2025.<\/p>\n\n\n\n

[5]<\/a>Law No. 22-24 amending and supplementing Law No. 47-18; M\u00e9dias24, “CRI reform: the changes introduced by Law 22-24,” January 20, 2025.<\/p>\n\n\n\n

[6]<\/a>Law No. 47-18, Article 34.<\/p>\n\n\n\n

[7]<\/a>M\u00e9dias24, “Here is how the new-generation CRIs will work,” and institutional presentation of the Unified Regional Investment Commission (aut.gov.ma).<\/p>\n\n\n\n

[8]<\/a>Law No. 47-18, Article 34.<\/p>\n\n\n\n

[9]<\/a>Law No. 22-24 amending and supplementing Law No. 47-18, adopted in December 2024, published in the Official Gazette on January 20, 2025.<\/p>\n\n\n\n

[10]<\/a>Le360, “Territorial investment: Morocco speeds up the overhaul of its regional one-stop shops”; provisions of Law No. 22-24 on decentralized agreement-signing, 2025.<\/p>\n","protected":false},"excerpt":{"rendered":"

Composition, chairmanship, quorum, voting, deadlines: how the Unified Regional Investment Commission actually works \u2014 and what its internal mechanics mean for an investor. A single body to replace a mosaic of commissions Before 2019, an investment project could have to go before several separate sectoral commissions, each competent over one part of the file \u2014 […]<\/p>\n","protected":false},"author":2,"featured_media":2604,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[24,12,23,13,22,1],"tags":[36,37,31,35],"class_list":["post-2603","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-governance","category-investment","category-investment-climate","category-private-sector","category-public-policy","category-uncategorized","tag-commission","tag-digitalisation","tag-investment-procedures","tag-transparency"],"_links":{"self":[{"href":"https:\/\/wladvisory.net\/fr\/wp-json\/wp\/v2\/posts\/2603","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/wladvisory.net\/fr\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/wladvisory.net\/fr\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/wladvisory.net\/fr\/wp-json\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/wladvisory.net\/fr\/wp-json\/wp\/v2\/comments?post=2603"}],"version-history":[{"count":1,"href":"https:\/\/wladvisory.net\/fr\/wp-json\/wp\/v2\/posts\/2603\/revisions"}],"predecessor-version":[{"id":2605,"href":"https:\/\/wladvisory.net\/fr\/wp-json\/wp\/v2\/posts\/2603\/revisions\/2605"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/wladvisory.net\/fr\/wp-json\/wp\/v2\/media\/2604"}],"wp:attachment":[{"href":"https:\/\/wladvisory.net\/fr\/wp-json\/wp\/v2\/media?parent=2603"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/wladvisory.net\/fr\/wp-json\/wp\/v2\/categories?post=2603"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/wladvisory.net\/fr\/wp-json\/wp\/v2\/tags?post=2603"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}