Contents
A highly exposed sector
According to figures reported by Le Brief in August 2026, Morocco's call centre sector employs between 90,000 and 120,000 people directly, counts more than 600 licensed centres, and depends on the French market for roughly 80% of its activity. Two trends increase its exposure to the AI Act:
- Growing use of AI in customer service: chatbots, voicebots, transcription, conversation analytics, agent assistance.
- France's ban on unsolicited telemarketing calls, passed on 30 June 2025 and in force since 11 August 2026, which is pushing the sector towards higher-value services that are often automated.
Why a Moroccan provider is in scope
Article 2 of the AI Act covers not only operators established in the EU, but also providers and deployers established in a third country where the output produced by the AI system is used in the Union. A voicebot run from Casablanca that answers the customers of a French telecom operator falls squarely into this case.
Two roles matter:
- The provider develops the system, or has it developed, and places it on the market under its own name.
- The deployer uses the system under its own authority in the course of its business.
A BPO can be either, or both, depending on whether it builds its own tools or uses those of its client or a software vendor.
The timeline, as amended in 2026
| Date | Obligation |
|---|---|
| 2 February 2025 | Prohibited practices and the AI literacy obligation |
| 2 August 2025 | Obligations for providers of general-purpose AI models |
| 2 August 2026 | Transparency obligations (Article 50), including for chatbots |
| 2 December 2026 | End of the grace period for marking AI-generated content, for systems placed on the market before 2 August 2026; new ban on AI-generated non-consensual intimate content and child sexual abuse material |
| 2 December 2027 | Requirements for Annex III high-risk systems (originally 2 August 2026) |
| 2 August 2028 | Requirements for high-risk systems embedded in regulated products (Annex I) |
The postponement was enacted by Regulation (EU) 2026/1744, known as the "Digital Omnibus on AI", published in the Official Journal on 24 July 2026 and in force since 27 July 2026. It also softened the AI literacy obligation: companies must now take measures to support AI literacy among their staff.
Typical BPO use cases under the AI Act
| Use case | Likely classification | What to do |
|---|---|---|
| Chatbot or voicebot answering EU customers | Limited risk: transparency (Article 50) | Clearly tell people they are interacting with AI, from the start of the exchange |
| AI-generated voices or content delivered to EU customers | Transparency (Article 50) | Mark generated content and disclose deepfakes |
| Emotion analysis of customers during calls | High risk (emotion recognition, Annex III), plus mandatory information of the people exposed | Assess real necessity, inform, document, prepare for December 2027 |
| Detecting agents' emotions | Prohibited in the workplace within the AI Act's scope, except for medical or safety reasons | Avoid: the legal and social risk outweighs the expected benefit |
| Automated agent evaluation (quality, scheduling, bonuses) | High risk where the AI Act applies (employment, Annex III); always governed by Article 11 of Moroccan Law 09-08 | Keep a human decision for anything affecting the contract or pay |
| Processing credit, life or health insurance files for an EU client | Potentially high risk for the client (Annex III) | Clarify in the contract who is provider or deployer, and which obligations flow down |
These classifications are indicative: each system must be assessed on its actual use and the provider's role.
And Moroccan law?
The AI Act does not replace Morocco's Law 09-08. Data processed in Morocco remains subject to the formalities of the CNDP, the national data protection authority. Article 11 of Law 09-08 also prohibits basing a decision with legal effects solely on the result of automated processing designed to assess a person's personality, which directly targets automated agent-evaluation tools.
AI Act fines
- Up to €35 million or 7% of worldwide annual turnover for prohibited practices.
- Up to €15 million or 3% for most other breaches.
- Up to €7.5 million or 1% for supplying incorrect information.
For SMEs, the lower of the two amounts applies. Beyond fines, the most immediate risk for a BPO is commercial: its European clients are now writing these requirements into tenders and contracts.
Action plan for a Moroccan BPO
- List every AI system used, developed or supplied by the client.
- Identify those whose output is used in the EU.
- Classify each system: prohibited, high risk, transparency, minimal.
- Bring chatbot and voicebot transparency into line immediately.
- Stop any use of agent emotion detection.
- Clarify roles and obligations in client contracts.
- Prepare high-risk systems for 2 December 2027, ideally within an ISO/IEC 42001 AI management system.
Further reading
- 4 min read
- 4 min read
- 4 min read
- 7 min read
- 7 min read
Frequently asked questions
Does a Moroccan call centre have to comply with the EU AI Act?
Yes, when the output of its AI systems is used in the European Union, for example a chatbot or voicebot answering EU customers. Being established in Morocco does not take it out of the regulation's scope.
Do the AI Act's high-risk obligations apply from 2026?
No. Regulation (EU) 2026/1744 postponed them to 2 December 2027 for Annex III systems, and to 2 August 2028 for systems embedded in regulated products. Transparency obligations have applied since 2 August 2026.
Must a chatbot disclose that it is AI?
Yes. Since 2 August 2026, an AI system intended to interact with people must be designed to inform them that they are interacting with AI, unless this is obvious to a reasonably well-informed person.
Can a call centre analyse its agents' emotions?
Emotion recognition in the workplace is among the practices prohibited by the AI Act, except for medical or safety reasons. Even where the regulation does not apply directly, this use should be avoided.
General information, not legal advice.
Report an errorReferences (5)
- Règlement (UE) 2024/1689 du 13 juin 2024 établissant des règles harmonisées concernant l'intelligence artificielle (AI Act). (opens in a new tab)
- Règlement (UE) 2026/1744 modifiant le règlement (UE) 2024/1689 (« Digital Omnibus sur l'IA »), JOUE du 24 juillet 2026, en vigueur le 27 juillet 2026. (opens in a new tab)
- Conseil de l'Union européenne (29 juin 2026). Intelligence artificielle : feu vert final à la simplification des règles.
- Loi n° 09-08 relative à la protection des personnes physiques à l'égard du traitement des données à caractère personnel (Dahir n° 1-09-15 du 18 février 2009), notamment articles 4, 11, 43 et 44. (opens in a new tab)
- Le Brief (22 août 2026). Centres d'appels : que disent vraiment les chiffres ?