Hub And Spoke Arrangements Under Moroccan Law

Hub and spoke arrangements sit at an increasingly contested intersection of competition law. They involve indirect coordination between competitors—the spokes—operating at the same level of the supply chain, through a common intermediary—the hub—which typically operates at a different level. The hub acts as a conduit for commercially sensitive information, enabling competitors to align their conduct without any direct contact between them. The concern is that the arrangement produces the same competitive harm as an outright horizontal cartel while preserving the formal appearance of independent bilateral relationships.

Moroccan competition law does not expressly define or regulate hub-and-spoke arrangements as a distinct legal category. Nor has the Moroccan Competition Council (MCC) issued specific guidance addressing the assessment of such indirect coordination structures under the Moroccan Competition Law. Hence, legal qualification remains inherently fact-specific and must be