Recognition and Enforcement of Foreign Judgments in Morocco

A company has obtained a judgment abroad against a debtor, and that debtor has assets in Morocco; or a foreign civil judgment concerns property or an obligation located in Morocco; or a family court decision was issued abroad. In each case, the same question arises: how can this judgment produce effects in Morocco?

The answer is the exequatur procedure. This guide explains its general framework, which applies — with nuances depending on the subject matter — to civil, commercial and family judgments. It does not replace analysis of a specific file. Moroccan law applies to the procedure regardless of the parties' nationality.

A foreign judgment is not, in principle, directly enforceable in Morocco simply because it was issued abroad. A Moroccan decision recognising its enforceability is generally needed: this is exequatur.

It helps to distinguish recognition (admitting the effects of the foreign judgment, such as its authority) from enforcement (allowing it to be carried out in Morocco, for example through a seizure). In practice, the exequatur procedure opens the way to these effects; the judge does not re-try the case on the merits but checks certain conditions.

This guide concerns decisions handed down by a foreign court. If what you hold is a decision from an arbitral tribunal, a different framework applies — see our guide to enforcing a foreign arbitral award in Morocco.

Exequatur is also a later, separate stage from building the case that produced the judgment. If, while the foreign proceeding is still running, you need testimony or documents located in Morocco, that is a distinct judicial-assistance question addressed in our guide to obtaining evidence located in Morocco for foreign proceedings.

It is a further step still from where the case was heard in the first place. Whether the parties could validly agree that a foreign court would decide the dispute — and whether that clause holds before a Moroccan court — is a question that arises before any judgment, addressed in our guide to whether a foreign jurisdiction clause is effective in Morocco.

From 24 August 2026, civil procedure is governed by Law 58.25, which replaces the former code. For the exequatur of foreign judgments, the application is brought before the president of the competent Court of First Instance, who rules on recognising the enforceability of the judgment.

This is the durable framework for any application filed from that date; when acting, it is prudent to verify the exact court and the arrangements applicable to the nature of the judgment concerned.

The judge does not re-examine the case on the merits: they review a set of conditions provided by Law 58.25. In practice, the judge checks in particular:

• that the foreign court did not rule on a matter within the exclusive jurisdiction of the Moroccan courts;

• the absence of fraud in the choice of the foreign court;

• the regularity of the summons and representation of the parties (respect for defence rights);

• that the judgment is final and has acquired res judicata under the law of the court that issued it;

• the absence of conflict with a Moroccan decision that is already enforceable;

• the absence of conflict with Moroccan public order;

• compliance with the international conventions ratified by Morocco.

If one of these conditions is missing, exequatur may be refused.

Because the regularity of the summons is one of these conditions, how the defendant was served abroad often matters here — the service of foreign judicial documents in Morocco follows its own framework, best handled correctly before judgment rather than defended at the exequatur stage.

The general exequatur framework can concern a civil judgment (obligations, liability, property), a commercial judgment (for example an order to pay a debt) or a family judgment (status, divorce). The same review of conditions applies, but the concrete analysis can vary.

Jurisdiction, the assessment of public order, ancillary consequences and the existence of an international convention may differ by subject matter. For enforcing a commercial judgment ordering payment, the link with the enforcement routes is central; our guide on commercial law in Morocco gives useful background.

So it should not be assumed that all categories work identically: the nature of the judgment guides the analysis.

Judgments that dissolve the marital bond follow a special regime under Law 58.25. For the part relating to the dissolution of the marriage, the exequatur order is not open to appeal by the parties: only the Public Prosecutor may challenge it, and only on grounds of public order. Ancillary consequences (financial questions, children) may follow a separate analysis.

This summary does not replace the detail: our dedicated guide on the recognition of a foreign divorce judgment in Morocco covers the procedure, civil-status transcription and the points specific to divorce.

The public-order check does not mean the Moroccan judge re-tries the case: it verifies that recognising the foreign judgment does not conflict with essential principles of the Moroccan legal order. It is a control condition, not a re-examination of the merits.

In addition, a bilateral or multilateral convention ratified by Morocco may change the ordinary rules for judgments from certain countries. For example, a bilateral convention may exist with France; for Spain, Belgium, the Netherlands, Germany, the United Kingdom, the United States or the Gulf countries, the existence or content of a treaty should not be assumed: the applicable convention must be checked according to the country and the judgment concerned.

Obtaining exequatur is often not an end in itself. Once enforceability is recognised, the judgment can be enforced in Morocco through the applicable routes (for example, for an order to pay, the ordinary enforcement measures).

It is therefore useful to anticipate the intended goal — recovering a sum, producing a civil-status effect, having a legal situation recognised — because that goal determines the steps to plan for after exequatur.

Because recognition and enforcement take time, and assets can be disposed of in the meantime, protecting the debtor's Moroccan assets in advance may call for a separate conservatory attachment in Morocco.

If the debtor is in a collective (insolvency) procedure, individual enforcement is stayed and the claim must be declared in the procedure rather than enforced; a judgment, even after exequatur, does not remove that step.

This procedure often concerns people or companies established outside Morocco. Before starting, it helps to gather: the judgment, evidence of its finality, the summons or service records, the certified Arabic translation, the documents relating to the parties and the subject, and the intended legal effect in Morocco.

Part of the preparation can be handled remotely, and a power of attorney may be used for certain acts where the law permits, though some steps may require an act carried out locally. For a foreign lawyer or company, working with local counsel in Morocco is often the necessary way to carry out these acts before the Moroccan courts; our guide on finding a lawyer in Morocco explains how credentials and remote work generally function.

The procedure is technical and depends on precise conditions. A foreign judgment lawyer in Morocco becomes useful above all where the judgment's finality, the summons of the opposing party, the application of a convention, the commercial or family nature of the judgment, or later enforcement raise a difficulty.

A lawyer can identify the applicable procedure, assess jurisdiction, review the foreign judgment and the evidence of finality and service, coordinate the certified translation, spot missing documents, analyse a public-order question, assess the impact of a convention, prepare and follow the exequatur application, and then coordinate the enforcement steps.

For foreign counsel or an international company, Moroccan local counsel is often the necessary relay for acts before the Moroccan courts. The aim remains to analyse, advise and represent according to the facts, the documents and the applicable law — with no guarantee of outcome and no promise that exequatur will be granted.

Law 58.25 on civil procedure — provisions on the recognition and exequatur of foreign judgments (in particular Articles 452 to 454), applicable from 24 August 2026; text published in the Official Bulletin and available via the Ministry of Justice's Adala portal.

Bilateral or international conventions ratified by Morocco — to be checked according to the country where the judgment was issued.

Because the rules can change, it is prudent to check the state of the law at the date of the step.