Prior Notice Obligations for Single-Purpose E-Money Business Operations

September 4, 2026

On August 6, 2026, the National Bank of Cambodia (“NBC”) issued Notification No. 14.026.1075 regarding the prior notification obligations applicable to businesses issuing single-purpose electronic money (“Single-Purpose E-Money”) through mobile applications or membership cards.

Single-Purpose E-Money refers to e-wallet accounts that allow customers to deposit funds and make payments exclusively for goods or services provided by the same business that issued the electronic money. This arrangement may be used by businesses such as coffee shops, restaurants, transportation companies, entertainment centers, fuel stations, and similar enterprises.

Under the applicable regulatory framework, legal entities other than licensed banking and financial institutions and payment service institutions are generally prohibited from issuing electronic money. However, exemptions exist to support small and medium-sized businesses and encourage innovation. In such cases, issuers must comply with specified conditions and submit prior written notification to the NBC as following:

• Maximum account balance: Each individual e-wallet account must not exceed KHR 200,000 or its equivalent.
• Aggregate balance limit: The total balance of all e-wallet accounts issued by a business must not exceed KHR 800,000,000 or its equivalent.
• Single-purpose use: The e-money must be used exclusively for payments of goods or services provided by the same business entity.

Businesses that are not licensed banks, financial institutions, or payment service institutions but are currently issuing e-wallet accounts must submit a written notification to the NBC within 90 days from the date of the Notification. Failure to comply may result in legal action by the NBC.

The NBC further reminds the public that such e-wallet accounts are not savings accounts, and issuers are prohibited from paying interest on balances maintained in these accounts. Customers are therefore advised to remain aware of the applicable balance limits and the risks associated with using e-wallet accounts offered by businesses that are not licensed financial or payment service institutions.