Pre-doubtful claims in Morocco

Pre-doubtful claims are the entry point of the non-performing grid. Using the label as a synonym for the whole NPL stock flattens two worse categories that, in Morocco, carry most of the outstanding.

What Article 5 actually says

Circular No. 19/G/2002 of 23 December 2002, amended on 9 December 2004, classifies as pre-doubtful the claims that are 90 days in arrears. The same article also covers qualitative cases, where the counterparty's situation justifies classification without the day count being the only test.

Describing the bucket as 'loans 90 days past due' is therefore incomplete. A file can enter the grid because risk quality has deteriorated even if the accounting delay has not reached that threshold. The circular, not a summary, decides the boundary.

The provisioning floor is not a value

Article 13 sets a 20% minimum for pre-doubtful claims, after reserved interest and after eligible guarantees on the conditions the text sets. That minimum disciplines prudential coverage. It does not say what a creditor will collect, or what a buyer should pay.

The coverage ratio published for all non-performing claims is a different statistic. Confusing it with the 20% floor mixes a category rule and a sector ratio. Both readings are kept apart in the monitor methodology.

Weight in the stock

At end-2025, pre-doubtful claims of banks on a social basis were MAD 4.9 billion out of a stock of 102.3. That is the thin band of the stack. An analysis that stops at the 8.3% ratio does not see how small the entry bucket is next to compromised claims.

Thin at sector level does not make the category irrelevant in a given portfolio. A tape can be young, and therefore heavy in pre-doubtful claims, while the sector is not. Vintage matters more than the national average. See recovery timing and recovery rate.

What changes in 2027, and what does not

Circular No. 1/W/2025, adopted on 5 December 2025, takes effect on 1 January 2027. It does not restate the 2012–2025 stocks and it does not rewrite, for those years, the thresholds already published.

As long as the reports being read were prepared on the previous grid, a historical pre-doubtful claim is read under Article 5, not under an anticipation of the later text. A model that applies the 2027 grid to a 2024 tape invents a classification the bank did not use.

In this series

• Morocco NPL market
• NPL valuation in Morocco
• NPL severity in Morocco
• Compromised claims in Moroccan banks

This note is a method of reading a file or a published series. It is not legal, tax or investment advice, and it is not an opinion on a particular exposure. Serenor Capital does not buy claims for its own account, manage a fund, or carry on collection.

Sources and references

• Bank Al-Maghrib, Annual Report on Banking Supervision, financial year 2025 — PDF
• Bank Al-Maghrib, Circular No. 19/G/2002 of 23 December 2002 on the classification of claims and their provisioning, as amended — PDF
• Circular No. 1/W/2025, adopted on 5 December 2025, effective 1 January 2027. It does not restate the 2012–2025 figures discussed here.
• Serenor public series, banks, social basis — Morocco NPL Monitor and methodology