Insurance Complaints in Morocco: the ACAPS Framework

The ACAPS figures#

Source: ACAPS (Morocco's insurance and social welfare supervisory authority), 2023 and 2024 activity reports.

In 2024, after motor insurance come workplace accidents and occupational diseases (577 complaints) and miscellaneous risks (458). Complaints are filed by lawyers in 46% of cases and by policyholders themselves in 31%. This high share of lawyers indicates that many of the cases brought before the authority are already established disputes, often relating to compensation.

No official figures for 2025 had been published at the date this page was verified. The figures circulating for that year have not been confirmed by ACAPS.

The weight of motor insurance#

The settlement of motor claims, for both property damage and bodily injury, has dominated complaints for several years. For an insurer, this is where the issues concentrate: assessment timescales, disputed compensation offers, the application of exclusions and excesses.

ACAPS also acts upstream. Its 2024 report mentions a circular letter sent to insurers that year on the handling of compensation claims. The press also reported, in January 2026, a letter from the authority dated 29 December 2025 restating the rules applicable to certain motor insurance exclusions, notably those relating to driving licences, and to excesses in cases of shared liability.

The online complaints platform#

Launched in December 2017, the reclamation.acaps.ma platform allows a complaint to be filed using a detailed form, a tracking number to be received and email alerts on progress. Its share of filings is growing (58% in 2023, 62% in 2024).

For insurers, this means that cases arriving through the authority are structured, dated and traceable. Their internal handling must be just as much so.

The insurance mediator#

The insurance mediation scheme is based on a charter agreed between ACAPS and the FMSAR (the Moroccan Federation of Insurance and Reinsurance Companies). The insurance mediator is appointed jointly by the two institutions, for a renewable three-year term. The most recent mediator whose appointment was made public took office on 1 March 2022, under a new charter. We have not found any public activity report for this mediation scheme, nor any separate body operating under another name.

The arrangement differs from the banking sector, where the Moroccan Centre for Banking Mediation publishes its rules and its figures: see banking mediation.

What is not required, but expected#

Unlike banks, which are subject to Bank Al-Maghrib Circular No. 10/W/16 (see banking complaints), insurers are not, to our knowledge, subject to any ACAPS circular setting out the organisation of a complaints unit, response deadlines or periodic reporting of complaints to the authority. This point should be checked regularly, as regulation evolves.

A structured internal organisation is nonetheless essential, as good practice and as a risk management tool:

1. An identified complaints unit or complaints officer, independent of the handling of disputed claims.
2. Systematic acknowledgement of receipt and written internal deadlines.
3. A taxonomy distinguishing underwriting, policy administration, claims, and the specific reason.
4. Tracking of cases forwarded by ACAPS or by the mediator, with cause analysis.
5. A periodic report to management and to the risk committee.
6. Clear information for policyholders on the means of redress: complaints department, mediator, ACAPS.

The analysis method is set out in our guide to fixing the causes of complaints, and the governance framework in GRC for the financial sector.

The general consumer protection framework#

Law No. 31-08 enacting consumer protection measures (Dahir No. 1-11-03 of 18 February 2011) lays down mandatory public-policy rules from which a contract cannot derogate. In particular, it requires the supplier to inform the consumer of the essential characteristics of the service and, for distance contracts, to give an address to which complaints can be sent. How it interacts with the Insurance Code, which is a special law, calls for case-by-case legal analysis that only a lawyer can carry out. For insurers, the practical lesson is simple: make complaint channels visible and accessible, particularly in online sign-up journeys.

Checklist for an insurer#

• Complaints officer appointed, written procedure, internal deadlines set.
• Complaints coming from ACAPS and the mediator identified and tracked separately.
• Quarterly analysis of complaint reasons, with priority given to motor insurance.
• ACAPS circular letters on compensation built into claims-handling procedures.
• Means of redress stated in policies, on the website and in replies.
• Complainants' personal data protected: see data protection in insurance.
• AI triage tools properly governed: see AI and complaints.