Pioneering industrial solar self-generation in Morocco

Morocco still relies heavily on non-renewable fuels in the energy sector, leading to high greenhouse gas emissions, and this dependence continues to grow. In response, the country is seeking to expand renewable energy activities, including solar rooftop installations across industrial and commercial sectors. Beyond the climate action set out in its NDC as an unconditional target, Morocco has stated that achieving its conditional target will require support through carbon or climate finance.

ACS therefore began developing SR500 in 2023 to participate in carbon markets under A6.2. The core technology consists of industrial- scale solar PV systems installed mainly for self‑consumption, enabling Moroccan companies to reduce greenhouse gas emissions by replacing fossil‑based grid electricity with self‑generated solar PV installations onsite. As one of the first developers of a large‑scale solar self‑generation activity under A6.2, ACS had to operate without any established model to follow. At the time, neither Morocco nor other countries had profound experience with projects of this kind.

SR500 targets companies that would not make such an investment under business‑as‑usual conditions. The main barriers identified and demonstrated in the MADD were limited access to capital, high upfront investment costs and investment risk. For industrial or commercial entities, opportunity costs were another crucial factor, as many prefer to invest in production improvements rather than in solar PV, which is often perceived as offering lower and slower returns. A detailed and robust financial model was therefore essential in demonstrating that carbon revenues are decisive for ensuring financial viability and enabling implementation.

ACS conducted a conservative internal-rateof- return-based investment analysis and included, among other things, the probability of key parameters varying by no more than 10 per cent in the financial model. During the authorisation phase, the FOEN additionally demanded a sensitivity analysis to test whether additionality would still hold when key parameters varied. Ultimately, a Forward Action Request (FAR) will require ACS to redo the financial additionality assessment whenever key parameters change.

Zaineb Kouzibri noted that ACS had already fulfilled this requirement before the first verification, by repeating the financial additionality test using the latest parameters, in response to new government decisions and other evolving conditions. This was particularly relevant because Morocco published new injection tariffs at the end of February 2026. At the same time, solar panel prices had risen significantly – by around 20 to 25 per cent – due to market developments, imminent import tariffs that already had an impact of around 15 per cent, as well as exchangerate pressures. Even with an injection tariff now in place, the tests and the revised analysis confirm that the activity remains additional, since the tariff is very low and applies only to a limited share of annual production.

Another important point that had to be dealt with in the MADD was that Morocco’s solar potential is often overestimated in simplified assessments. Solar software, literature and online sources cite radiation levels of up to 1,700 kWh per kW installed, suggesting high returns on investment and payback periods of around four years. In practice, however, many parameters affect real performance. Dust and dirt caused by adverse weather conditions require much more frequent cleaning of the panels than in many parts of Europe. In some Moroccan regions, this may be needed weekly – but in reality, it happens less frequently and thus reduces the full potential of energy production. In addition, high summer temperatures – especially in southern areas such as around Marrakesh – reduce panel efficiency once temperatures rise above around 35–36°C. These circumstances affect both output and activity economics. Based on real installations and actual output data, it was clarified that the average output is less than 1,200 kWh.

For the calculation of baseline greenhouse gas emissions, the MADD uses the grid emission factor published by the Moroccan government, based on tools approved under the UNFCCC framework, which is now to be published annually. The factor applied is 0.740. Since the factor published by the European Union is higher – around 0.900 – the approach taken for SR500 was conservative.

In Morocco’s latest NDC, published in September 2025 for the 2026–2035 period, the country aims to reach 21.6 per cent installed renewable energy capacity under its unconditional target and 31.4 per cent under its conditional target by 2035. SR500 falls under the conditional target, because it is listed by the country as a conditional measure under "Project 14 – Programme for the installation of renewable energy (PV) for auto-consumption in the industrial sector by 2035". The MADD demonstrates that additionality is preserved through defined eligibility criteria that ensure that installations are not mandated and not publicly subsidised, and go beyond baseline deployment. This activity encourages the installation of 1,500 MW of rooftop solar PV in the commercial and industrial sector by 2035. In that sense, SR500 accelerates decarbonisation beyond Morocco’s unconditional trajectory.

Finally, beyond emission reductions, the MADD also documented how SR500 can generate broader co-benefits, including job creation and improved industrial competitiveness.

The validation and authorisation processes were described by the ACS team as very thorough. Every number and every assumption had to be justified during the validation, usually with official or publicly available evidence. AENOR, the validation body, focused strongly on references and sources, especially for the financial model, the emission factor, the baseline scenario and the emission reduction spreadsheets. Since validation is based on forward-looking estimates and future figures cannot yet be confirmed, the assumptions need to be realistic, credible and robust.

The validators pointed out that, during the validation phase, close communication with the two partner countries was essential – not only when dealing with a new technology, but also more generally to stay informed about updates to requirements, regulations, new obligations or national funding schemes, as well as about research needed or already existing to clarify a specific methodological aspect of an activity. Regarding the Swiss requirements, Asis Arranz Arbex noted that the FOEN regularly updates its guidance and requirements for validation and verification bodies, as well as project proponents. These updates are published on the official website and are sometimes shared through direct communication, presentations or supporting documents. The FOEN allows this information to be passed on to project developers so that they can anticipate new requirements and incorporate the necessary measures correctly in their MADD.

During the authorisation phase, both Switzerland and Morocco raised questions similar to those asked during validation in order to obtain a complete picture of the activity. As Zaineb Kouzibri explained, many of these could be addressed by building on the responses already provided to AENOR. While the core design of the activity remained unchanged, it can be stated that the process significantly strengthened the high integrity of SR500.

While the initial methodological approach in the SR500 MADD was largely based on Clean Development Mechanism tools – standardised procedures under the Kyoto Protocol – for the demonstration of additionality, several rounds of findings led to improvements, in particular with regard to benchmark analysis, barrier analysis, common-practice considerations, and the supporting evidence for costs, loans and market conditions.