1. Introduction

Competition law in surveillance storage interoperability in Morocco concerns the regulation of competitive relationships between businesses that manufacture, supply, operate, store, manage and maintain surveillance technologies.

The subject covers the ability of different surveillance systems to communicate, exchange, retrieve and process recorded information without being unnecessarily restricted by proprietary technology, contractual restrictions or discriminatory access conditions.

It is particularly important in markets involving:

CCTV and IP-camera manufacturers.

Video surveillance storage providers.

Cloud-based surveillance platforms.

Digital evidence storage and retrieval services.

Smart-city surveillance infrastructure.

Biometric identification and access-control systems.

Public security and private security technology providers.

AI-based video analytics and monitoring services.

For example, suppose a Moroccan shopping centre purchases surveillance cameras from Company A and cloud-storage services from Company B. If Company A deliberately prevents its cameras from transferring recordings to competing storage providers, the shopping centre may become dependent on Company A's entire technological ecosystem.

Such conduct may raise competition concerns involving technological lock-in, refusal of interoperability, exclusionary conduct, tying, discriminatory access and abuse of dominant market position.

The central legal objective is to protect competition while ensuring cybersecurity, personal-data protection, confidentiality and the integrity of surveillance evidence.

An important qualification: Morocco does not have a clearly established body of published court judgments specifically addressing competition disputes over CCTV-storage interoperability. Accordingly, the Moroccan legal framework is examined alongside relevant comparative judicial precedents. Foreign judgments below are persuasive analytical examples, not binding Moroccan authorities.

2. Legal framework in Morocco

A. Law No. 104-12 on Freedom of Prices and Competition

Morocco's principal competition legislation is Law No. 104-12 on Freedom of Prices and Competition, as amended by Law No. 40-21.

The legislation provides the foundation for examining restrictive agreements, abuse of dominant positions and economic concentrations.

Article 6 – Anti-competitive agreements

Article 6 prohibits agreements and concerted practices that have the object or potential effect of preventing, restricting or distorting competition.

In surveillance-storage markets, potentially problematic agreements include:

Agreements requiring camera manufacturers to use only one storage provider.

Exclusive distribution agreements preventing access to competing platforms.

Agreements between storage providers to divide customers or territories.

Agreements restricting independent maintenance providers from accessing technical interfaces.

Agreements preventing the transfer of surveillance recordings between competing systems.

Not every exclusive agreement is unlawful. Its purpose, market effects, duration, market coverage and possible efficiencies must be examined.

Article 7 – Abuse of dominant position

Article 7 addresses the abuse of a dominant market position.

A dominant surveillance technology provider might abuse its position by:

Refusing interoperability without objective justification.

Charging excessive prices for technical integration.

Discriminating between affiliated and independent storage providers.

Restricting access to essential technical interfaces.

Imposing unreasonable switching conditions.

Making access to camera technology conditional on purchasing its cloud-storage services.

Dominance alone is not unlawful. The relevant issue is whether the undertaking exploits or abuses its market power.

Article 8 – Concentrations

Merger and acquisition transactions involving surveillance technology companies may also require competition scrutiny.

For example, if a dominant camera manufacturer acquires a major cloud-storage provider, the resulting undertaking may have incentives to exclude rival storage businesses.

The assessment should consider market concentration, barriers to entry, technological control, customer dependence and potential foreclosure.

B. Law No. 24-96 on Telecommunications

Law No. 24-96 is relevant where surveillance-storage interoperability depends on telecommunications networks, connectivity infrastructure or network access.

The ANRT has regulatory responsibilities concerning telecommunications interconnection, infrastructure sharing and certain disputes involving anti-competitive practices.

Its authority is particularly relevant when surveillance providers depend on telecommunications operators to transmit video recordings between cameras, storage facilities and monitoring centres.

C. Law No. 09-08 on Personal Data Protection

Surveillance recordings can contain identifiable personal information.

Law No. 09-08 regulates the processing of personal data and establishes obligations concerning lawful purposes, proportionality, security and confidentiality.

Interoperability must therefore not become an excuse for unrestricted sharing of surveillance footage.

D. Constitutional protection of privacy

Article 24 of the Moroccan Constitution protects the right to privacy.

Consequently, competition-based interoperability must be balanced against privacy, data security and legitimate surveillance purposes.

E. Law No. 40-21

Law No. 40-21 amended Morocco's competition legislation and strengthened the institutional and enforcement framework.

It is important for surveillance-storage markets because modern surveillance services increasingly depend on digital platforms, data infrastructure, technical partnerships and interconnected business ecosystems.

F. Role of the Competition Council

The Moroccan Competition Council examines restrictive practices, abuse of dominance and economic concentrations.

Its role includes:

Investigating anti-competitive agreements.

Examining exclusionary conduct.

Reviewing relevant mergers and acquisitions.

Protecting competitive market structures.

Promoting transparency and effective competition.

The ANRT also has sector-specific responsibilities for telecommunications disputes, including interconnection and infrastructure-sharing matters.

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3. Meaning of surveillance-storage interoperability

Surveillance-storage interoperability refers to the technical and commercial ability of surveillance equipment and storage systems operated by different providers to work together.

It includes five principal dimensions.

1. Hardware interoperability

Cameras manufactured by different companies should be capable of connecting with compatible recording and storage equipment.

2. Software interoperability

Surveillance software should be able to communicate with different video-management systems through documented and secure interfaces.

3. Cloud-storage interoperability

Customers should be able to transfer surveillance recordings between competing cloud-storage providers without unreasonable technical or contractual restrictions.

4. Data portability

Customers should be able to retrieve recordings, metadata, timestamps and relevant audit information in usable formats.

5. Security interoperability

Different surveillance systems should exchange information through secure authentication, encryption, access controls and audit mechanisms.

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4. Relevant competition problems in Moroccan surveillance-storage markets

A. Technological lock-in

Technological lock-in occurs when customers become dependent on one supplier because their surveillance equipment cannot practically operate with competing storage services.

For example:

A Moroccan company purchases 200 surveillance cameras from a dominant manufacturer. The manufacturer configures its software so that recordings can only be stored on its proprietary cloud platform.

The customer faces substantial switching costs if it attempts to change providers.

This may create competition concerns where the restriction is imposed by a dominant undertaking and substantially excludes rival storage providers.

B. Refusal of interoperability

A dominant manufacturer may refuse to disclose necessary technical specifications or provide access to application programming interfaces (APIs).

A refusal may be problematic where:

The requested interface is objectively necessary for effective competition.

The refusal is likely to eliminate effective competition in a neighbouring market.

The refusal cannot be objectively justified.

The restriction harms innovation or customer choice.

However, competition law does not automatically require every company to disclose its proprietary technology.

C. Exclusive storage arrangements

A camera manufacturer may enter into agreements with storage providers requiring customers to purchase storage exclusively from one designated company.

Such arrangements may restrict market access for competing storage providers.

Under Article 6 of Law No. 104-12, the assessment should consider whether the arrangement has an anti-competitive object or effect.

D. Discriminatory technical access

Suppose a dominant surveillance platform provides its affiliated storage business with complete technical documentation but refuses to provide equivalent information to independent storage companies.

This may disadvantage independent competitors.

The competition authority should examine whether the difference in treatment has objective technical or security justification.

E. Excessive switching charges

A surveillance provider may impose excessive charges for:

Exporting recorded video.

Downloading archived footage.

Transferring metadata.

Migrating customer databases.

Converting proprietary video formats.

Disconnecting storage subscriptions.

Such charges can make switching commercially impractical and reinforce customer dependence.

Where imposed by a dominant undertaking, they may constitute evidence of abusive conduct.

F. Data and storage exclusivity

Storage companies may negotiate agreements with camera manufacturers, security contractors and public infrastructure operators.

These arrangements become problematic when they prevent competing businesses from accessing important distribution channels or customers.

Competition analysis must distinguish legitimate commercial exclusivity from arrangements that foreclose competition.

5. Six important judicial precedents and their application

The following judgments provide useful comparative principles for analysing interoperability disputes in Morocco. They do not establish that identical conduct is automatically unlawful under Moroccan law.

Case 1. Microsoft Corp. v Commission (2007)

Highly relevant interoperability precedent

Citation: Case T-201/04, General Court of the European Union, judgment of 17 September 2007.

Facts:

Microsoft held a dominant position in the market for PC operating systems.

The European Commission found that Microsoft had refused to provide competitors with certain interoperability information necessary for their work-group server operating systems to communicate effectively with Windows PCs.

The Commission also examined Microsoft's tying of Windows Media Player with its Windows operating system.

Legal issue:

Whether a dominant undertaking could abuse its market position by withholding interoperability information and restricting competition in related markets.

Judgment:

The General Court largely upheld the Commission's findings concerning Microsoft's refusal to provide interoperability information and the tying infringement.

Application to Morocco:

This judgment is particularly relevant to surveillance-storage interoperability.

Imagine that a dominant Moroccan surveillance platform refuses to provide independent cloud-storage providers with the technical specifications needed to retrieve recordings from its cameras.

If this refusal satisfies the relevant conditions for abuse of dominance, Article 7 of Law No. 104-12 may become applicable.

The judgment demonstrates that interoperability restrictions can become a competition problem when they prevent competitors from developing viable competing products.

Case 2. Oscar Bronner GmbH & Co. KG v Mediaprint (1998)

Citation: Case C-7/97, Court of Justice of the European Union, judgment of 26 November 1998.

Facts:

Oscar Bronner operated a newspaper and requested access to Mediaprint's extensive newspaper home-delivery distribution system.

Mediaprint controlled the established distribution infrastructure.

Legal issue:

Whether a dominant undertaking could be compelled to provide competitors with access to infrastructure it had developed.

Judgment:

The Court established strict conditions for treating refusal of access to infrastructure as an abuse of dominance.

Among the important conditions were:

The facility must be indispensable for competing in the relevant market.

The refusal must be capable of eliminating all effective competition in the downstream market.

The refusal must lack objective justification.

The possibility of economically viable alternatives is important.

Application to Morocco:

A surveillance-storage company cannot automatically demand access to every proprietary camera network or cloud-storage infrastructure.

However, where a dominant undertaking controls an indispensable technical facility and refuses access under the strict conditions established by the relevant law, the refusal may attract competition scrutiny.

This judgment helps prevent competition law from becoming a general compulsory-sharing mechanism.

Case 3. IMS Health GmbH & Co. OHG v NDC Health GmbH & Co. KG (2004)

Citation: Case C-418/01, Court of Justice of the European Union, judgment of 29 April 2004.

Facts:

IMS Health developed a pharmaceutical sales-data system based on a particular geographical segmentation structure known as the 1,860-brick structure.

NDC Health sought to use that structure to compete in the pharmaceutical data-services market.

IMS Health relied on intellectual property rights to oppose its use.

Legal issue:

Whether refusal to license protected intellectual property could constitute abuse of a dominant position.

Judgment:

The Court identified exceptional conditions under which refusal to license intellectual property could constitute an abuse.

These included the importance of the requested product or service, elimination of competition in a secondary market, and prevention of a new product for which there was potential consumer demand, without objective justification.

Application to Morocco:

A surveillance technology company may own proprietary software, recording formats or storage interfaces.

The existence of intellectual property rights does not automatically remove the conduct from competition-law scrutiny.

Nevertheless, compulsory access should remain exceptional and must satisfy the applicable legal requirements.

Case 4. Slovak Telekom a.s. v European Commission (2021)

Citation: Case C-165/19 P, Court of Justice of the European Union, judgment of 25 March 2021.

Facts:

Slovak Telekom was an established telecommunications operator controlling important network infrastructure.

The European Commission found that it had engaged in exclusionary practices involving access to its local network infrastructure.

Legal issue:

Whether discriminatory or restrictive access conditions imposed by a dominant infrastructure operator could constitute abuse of dominance.

Judgment:

The Court upheld the relevant findings concerning abusive conduct and clarified the relationship between regulatory access obligations and competition-law enforcement.

Application to Morocco:

This judgment is relevant where a dominant Moroccan telecommunications or surveillance infrastructure provider controls access necessary for competing storage services.

Examples include:

Restricting access to transmission infrastructure.

Offering inferior technical conditions to independent providers.

Creating unreasonable access delays.

Imposing discriminatory integration charges.

The judgment supports scrutiny of access conditions that disadvantage competing providers.

Case 5. Magill TV Guide Ltd v Commission (1995)

Citation: Joined Cases C-241/91 P and C-242/91 P, Court of Justice of the European Union, judgment of 6 April 1995.

Facts:

Television broadcasters controlled copyright-protected programme listings.

Magill sought to publish a comprehensive weekly television guide combining information from different broadcasters.

The broadcasters refused to license the relevant information.

Legal issue:

Whether the exercise of intellectual property rights could constitute an abuse of dominant position when it prevented the emergence of a new product.

Judgment:

The Court upheld the exceptional finding of abuse concerning the broadcasters' refusal to license their programme listings.

Application to Morocco:

A surveillance-storage provider may prevent competitors from developing new services by refusing access to information or interfaces that are exceptionally indispensable.

For instance, a third-party business might want to develop a unified surveillance-management service capable of integrating several camera manufacturers.

A refusal that prevents the emergence of such a service may require competition-law examination.

However, Magill does not establish a general right to obtain proprietary surveillance data.

Case 6. European Commission v Google and Alphabet – Android (2022)

Citation: Case T-604/18, General Court of the European Union, judgment of 14 September 2022.

Facts:

The European Commission investigated Google's contractual arrangements involving Android mobile devices.

The proceedings concerned restrictions imposed on manufacturers and mobile-network operators, including arrangements involving the pre-installation of applications and restrictions affecting competing services.

Legal issue:

Whether contractual restrictions imposed by a dominant technology platform could protect its market position and restrict competition in related markets.

Judgment:

The General Court largely upheld the Commission's finding of abuse, although it adjusted the fine.

Application to Morocco:

This judgment provides useful guidance for surveillance platforms that bundle:

Camera hardware.

Video-management software.

Cloud-storage subscriptions.

AI-based monitoring tools.

Technical maintenance services.

A dominant provider may not use contractual conditions to exclude competing storage providers or protect its market position unfairly.

The relevant assessment depends on market power, competitive effects and objective justification.

6. Moroccan regulatory and judicial precedents

Although the six judgments above are comparative authorities, Morocco also has relevant telecommunications competition precedents.

1. Médi Télécom v Maroc Télécom – Refusal of colocation (2004)

Authority: ANRT, Morocco.

Maroc Télécom refused a request by Médi Télécom for colocation at a particular site, relying on insufficient space and technical feasibility concerns.

The ANRT examined the complaint and recognised that access to colocation was important for interconnection and effective competition.

Where physical colocation was impossible, an alternative solution involving virtual interconnection was considered.

Relevance: This is a particularly useful Moroccan regulatory precedent for disputes involving access to surveillance transmission infrastructure, shared facilities and technical integration.

It demonstrates the importance of considering reasonable technical alternatives rather than permitting infrastructure owners to exclude competitors automatically.

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2. Maroc Télécom – Discriminatory fixed-to-mobile discounts (2001)

Authority: ANRT, Morocco.

Maroc Télécom offered discounts to customers making calls from its fixed network to its own mobile network, while competing mobile operators did not receive equivalent treatment.

The ANRT considered the discriminatory arrangement an abuse of Maroc Télécom's dominant position in the fixed-line market and intervened.

Relevance: The principle is relevant to surveillance-storage ecosystems.

For example, a dominant camera manufacturer could provide preferential integration prices to its affiliated cloud-storage business while imposing significantly higher charges on independent providers.

The competitive impact of such discrimination would need to be established in the relevant market.

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3. Commercial Court of Appeal of Casablanca – Decision No. 3680 (2024)

Citation: Commercial Court of Appeal, Casablanca, Decision No. 3680, 3 July 2024, Case No. 2024/8202/1668.

Facts and legal issue:

The dispute concerned civil liability and compensation arising from alleged anti-competitive practices in the fixed high-speed ADSL internet market.

The proceedings involved the evidential significance of a final decision by the telecommunications regulator and the need to establish actual loss.

Legal significance:

The decision addressed the distinction between establishing wrongful conduct and proving the existence and amount of compensable damage.

A regulatory finding of anti-competitive conduct does not necessarily establish every element of a damages claim.

Application to Morocco's surveillance-storage market:

A surveillance-storage provider claiming that a dominant competitor prevented interoperability should establish:

The alleged anti-competitive conduct.

Its actual commercial loss.

The causal relationship between the conduct and the loss.

The basis for calculating the compensation claimed.

This is important for independent storage companies seeking damages after discriminatory technical-access restrictions.

Jurisprudence

These Moroccan precedents are useful, but they should not be misrepresented as judgments specifically deciding CCTV-storage interoperability.

7. Essential facilities and surveillance-storage interoperability

The essential facilities doctrine is relevant where one undertaking controls infrastructure that competitors cannot reasonably duplicate or replace.

In surveillance-storage markets, potentially important facilities include:

Proprietary video-storage interfaces.

Camera authentication systems.

Large-scale surveillance archives.

Essential transmission infrastructure.

Technical protocols needed to retrieve recorded footage.

Critical cloud-based video-management infrastructure.

However, an important distinction must be maintained.

A facility is not essential merely because it is convenient, commercially attractive or widely used.

The Bronner principles provide a restrictive comparative test for compulsory access.

Proposed legal assessment

For Morocco, these considerations can inform the application of Article 7 of Law No. 104-12.

8. Interoperability and personal-data protection

Competition law cannot be applied independently of Moroccan privacy legislation.

Surveillance recordings may contain:

Faces and identifiable images.

Vehicle registration numbers.

Employee movements.

Customer activities.

Access-control information.

Biometric information.

Sensitive security-related recordings.

Under Law No. 09-08, surveillance operators must comply with applicable data-processing requirements.

The CNDP's requirements include:

Lawful and legitimate processing.

Defined processing purposes.

Proportionality of collected information.

Appropriate security measures.

Confidentiality obligations.

Appropriate notification or authorisation procedures.

Compliance with applicable rules for international data transfers.

The CNDP specifically recognises video surveillance as a processing activity requiring the appropriate notification procedure under its Decision No. 350-2013, subject to the decision's scope and applicable exceptions.

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Competition versus privacy

Consider this situation:

A competing cloud-storage provider requests access to recordings held by a surveillance company.

The original company refuses, arguing that the recordings contain personal information.

The refusal should not automatically be considered anti-competitive or automatically justified.

The parties should examine whether secure interoperability can be achieved through:

Customer-authorised data transfers.

Encryption.

Restricted access permissions.

Data minimisation.

Secure API connections.

Access logs.

Appropriate contractual safeguards.

A legitimate privacy obligation should not be used as a pretext for excluding competitors.

Equally, competition law should not force businesses to disclose personal information unlawfully.

9. Role of the ANRT in infrastructure interoperability

The National Telecommunications Regulatory Agency (ANRT) has an important role when surveillance-storage services rely on telecommunications infrastructure.

Its responsibilities include addressing disputes relating to interconnection and infrastructure sharing within its statutory jurisdiction.

The relevant framework includes Law No. 24-96 and the associated implementing regulations.

Potential areas of intervention include:

A. Network access

Ensuring that eligible operators receive access under appropriate conditions.

B. Non-discrimination

Preventing unjustified differences in technical or commercial access conditions.

C. Infrastructure sharing

Examining disputes concerning shared telecommunications infrastructure.

D. Interconnection disputes

Resolving qualifying disagreements concerning interconnection arrangements.

E. Competition protection

Addressing relevant anti-competitive practices within its jurisdiction.

The ANRT's published regulatory framework specifically recognises its competence in interconnection, infrastructure-sharing disputes and certain anti-competitive telecommunications practices.

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An important jurisdictional distinction is that a dispute involving a standalone CCTV cloud-storage platform will not automatically fall within the ANRT's telecommunications jurisdiction. The nature of the service and the statutory basis for intervention must be examined.

10. Anti-competitive contractual practices

Surveillance-storage interoperability is also affected by contractual arrangements.

The following practices deserve particular scrutiny.

Example

Suppose Company A controls 65% of a narrowly defined Moroccan surveillance-camera market and 75% of the compatible storage market.

It requires all commercial customers to purchase storage from its affiliated company.

Independent storage providers cannot integrate their services because Company A refuses access to the necessary interface.

This situation raises several possible concerns:

Abuse of dominance under Article 7.

Exclusionary contractual arrangements.

Possible tying or bundling.

Restrictions on technical access.

Foreclosure of competing storage providers.

The market-share figures alone do not establish an infringement. The authority must assess the relevant markets, competitive constraints, entry barriers and actual or likely exclusionary effects.

11. Merger control and surveillance-storage consolidation

The surveillance-storage industry may experience consolidation through acquisitions involving:

Camera manufacturers.

Cloud-storage operators.

Telecommunications providers.

Security-management software companies.

AI video-analysis businesses.

Digital infrastructure companies.

A merger can create vertical foreclosure risks.

For example, a major camera manufacturer may acquire a competing storage platform and then restrict rival storage providers' access to its equipment.

The Competition Council may need to consider:

Horizontal concentration.

Vertical integration.

Control over technical standards.

Access to essential inputs.

Potential foreclosure.

Effects on innovation.

Consumer switching opportunities.

The purpose of merger review is not to prevent all integration. It is to prevent transactions that significantly damage competitive market conditions under the applicable Moroccan framework.

12. Government procurement and public surveillance infrastructure

Moroccan public authorities may procure surveillance-storage solutions for:

Airports and transport terminals.

Public roads and highways.

Government buildings.

Educational institutions.

Hospitals.

Municipal security systems.

Smart-city projects.

Competition problems may arise when public procurement specifications favour a particular proprietary technology without objective justification.

For example, a tender may require compatibility exclusively with one manufacturer's storage platform even though competing systems can satisfy the security and operational requirements.

Potential concerns include:

Discriminatory technical specifications.

Unjustified proprietary requirements.

Restricted participation by competing suppliers.

Exclusive maintenance contracts.

Artificially high switching costs.

Long-term technological dependency.

Public authorities should adopt neutral, proportionate and objectively justified interoperability requirements.

13. Remedies for anti-competitive interoperability restrictions

Where an infringement is established, appropriate remedies may include:

Remedies must be proportionate and should not unnecessarily compromise intellectual property rights, cybersecurity or personal-data protection.

14. Challenges in enforcing interoperability competition law in Morocco

A. Technological dependence

Smaller Moroccan storage businesses may depend on international camera manufacturers and proprietary technologies.

B. Proprietary standards

Different surveillance manufacturers use different formats, protocols and technical specifications.

C. Limited technical expertise

Competition investigations involving sophisticated cloud-storage systems require technical and economic expertise.

D. Cybersecurity concerns

Opening technical interfaces can create vulnerabilities if authentication, encryption and access controls are inadequate.

E. International data transfers

Cloud-storage providers may host surveillance recordings outside Morocco, creating additional compliance obligations under Law No. 09-08.

F. Market concentration

A small number of suppliers may control important technological components, creating barriers for independent businesses.

G. Lack of directly applicable judicial precedents

Morocco's published competition jurisprudence does not yet provide a substantial body of judgments specifically addressing interoperability between surveillance cameras and competing storage systems.

15. Recommendations for strengthening Moroccan competition policy

Morocco could strengthen competition in surveillance-storage markets through the following measures.

1. Develop interoperability guidelines

The Competition Council could provide guidance on when proprietary technical restrictions constitute exclusionary conduct.

2. Encourage open technical standards

Public and private procurement should encourage widely recognised interoperability standards wherever technically appropriate.

3. Introduce fair data-portability arrangements

Customers should have reasonable access to their surveillance recordings in usable formats.

4. Strengthen competition investigations

The authorities should develop expertise in cloud infrastructure, APIs, video analytics and digital platform economics.

5. Monitor exclusive agreements

Long-term exclusivity agreements should be examined where they may substantially foreclose rival suppliers.

6. Improve regulatory cooperation

The Competition Council, ANRT and CNDP should coordinate within their respective legal powers.

7. Protect smaller technology providers

Independent software developers and storage businesses should have meaningful opportunities to compete.

8. Promote cybersecurity-compliant interoperability

Interoperability should be based on secure technical architecture rather than unrestricted data disclosure.

16. Comparative case-law principles

The six comparative judicial decisions can be summarised as follows:

These authorities provide a comparative framework, not a substitute for the requirements of Moroccan legislation.

17. Conclusion

Competition law in surveillance-storage interoperability in Morocco is an emerging area involving competition regulation, telecommunications infrastructure, intellectual property, cybersecurity and personal-data protection.

Law No. 104-12, particularly Articles 6 and 7, provides the principal framework for addressing restrictive agreements and abuse of dominant positions. Law No. 24-96 becomes relevant where telecommunications interconnection or infrastructure sharing is involved, while Law No. 09-08 protects individuals whose personal information is processed through surveillance systems.

The comparative judgments in Microsoft, Bronner, IMS Health, Slovak Telekom, Magill and Google Android provide useful guidance on interoperability restrictions, essential facilities, intellectual property and exclusionary conduct.

Morocco's ANRT precedents involving colocation and discriminatory telecommunications practices also demonstrate the importance of fair infrastructure access.

Ultimately, Morocco should pursue a balanced interoperability policy that protects competition, enables technological innovation, reduces customer lock-in and safeguards personal information without imposing unnecessary compulsory disclosure of proprietary technology.

18. Additional legal provisions and authorities for research

Overall legal assessment: Surveillance-storage interoperability should be treated as a developing digital competition issue in Morocco. The strongest legal arguments will arise where a dominant undertaking uses control over essential technical interfaces, infrastructure or contractual arrangements to exclude competing providers without objective justification.