Law Digest 2026

Telecommunications

The TRC has issued a warning to the public regarding individuals or service providers offering paid account protection or page protection services on social media.

These service providers claim that they can guarantee that a user’s social media account or page will not be disabled, suspended, deleted, or otherwise lost, in exchange for a fee. Some further claim to have direct connections with the platform companies or access to special technical tools to appear more credible.

Below are the key highlights.

The TRC’s Position

The TRC has clarified that:

• Any representation guaranteeing the protection of an account or page for a fee constitutes the dissemination of false information, which could satisfy the elements of criminal fraud and give rise to liability under applicable Cambodian law.
• Such schemes are typically designed to induce fear in users, leading them to pay money or disclose sensitive information (e.g., phone numbers, email addresses, passwords, OTP codes, or page administration rights).
• The resulting harm may include permanent loss of account/page control, unrecoverable financial loss, theft of personal or financial data, and further downstream fraud perpetrated against the victim’s contacts using the compromised account.

The TRC’s Recommendation

To reduce these risks, the TRC recommends that users:

• Never disclose passwords or OTP codes to third parties.
• Never pay for guaranteed account/page protection or restoration services.
• Avoid granting admin/editor rights to unfamiliar persons.
• Avoid clicking suspicious links or installing applications from unverified sources.
• Enable two-factor authentication and clearly designate authorized page administrators.

The TRC reiterated that the use of social media accounts and pages in Cambodia must comply with applicable Cambodian laws and the terms of use and community standards of the relevant platform company, which constitute a binding agreement between the user and that platform.

Reporting Channel

Suspected fraudulent activity may be reported to the TRC via hotline (6789), email, or the TRC’s official Facebook page. All reports will be treated confidentially.

Investment

This instruction, which entered into effect on August 27, 2026, requires investors in the manufacturing sector to implement actual investment capital equal to or above the minimum threshold set out in the Negative List of Sub-Decree No. 139 dated June 26, 2023 on the Implementation of Cambodia’s Law on Investment, within three years.

Implementation timeline

• Newly registered QIPs (registered after the guidance takes effect): The three-year period runs from the date of issuance of the registration certificate.
• Previously registered projects: The three-year period runs from the date this notification was issued on August 27, 2026.

The CDC clarified that the term “investment capital” refers to the value of the investment, expressed in Cambodian riel or a foreign currency, excluding the value of any land and working capital.

Failure to meet the above investment capital implementation requirement within the three-year period may result in measures being imposed by the CDC, including the possible withdrawal of investment incentives, such as tax breaks and import duty exemptions.

Labor

This notification, which takes effect immediately, requires all entities intending to employ foreign workers in 2027 to submit their foreign employee quota applications through the Foreign Workers Centralized Management System (“FWCMS”) during the period September 1 to November 30, 2026 via https://fwcms.mlvt.gov.kh.

For entities established after November 30, 2026, the quota application may be submitted immediately upon commencement of operations.

To facilitate the automatic generation of Cambodian and foreign worker lists, entities are required to link the Labor Centralized Management System with the FWCMS, which will enable the automatic generation of foreign worker records.

Moreover, all foreigners residing or working in Cambodia are required to apply for a work permit through the FWCMS within 90 days from the date of their first entry into Cambodia.

Employers who employ foreign workers but fail to apply for the 2027 quota, as well as foreign workers who fail to obtain a work permit within the prescribed deadline, may be subject to fines and other enforcement measures imposed by labor inspectors in accordance with the applicable laws.

Taxation

This notification is a reminder that the deadline to declare and pay immovable property tax and unused land tax for 2026 is September 30, 2026.

According to the GDT, a number of property owners have not yet fulfilled their tax obligations. In addition, some property owners have not registered their properties or updated their property information, while others have identified inaccuracies in their property records after receiving the GDT’s tax reminder notices.

To ensure accurate tax administration and timely compliance, all property owners should:

• Register or update their property information with the competent provincial or district tax branch where the property is located, or directly with the GDT, where applicable.
• Declare and pay the immovable property tax and unused land tax by September 30, 2026 through authorized commercial banks or, where available, via the GDT Taxpayer App for properties that have previously been declared.

Property owners who fail to submit their tax declaration or make payment by the prescribed deadline will be subject to administrative penalties, including additional tax and interest, in accordance with the Law on Taxation.

Property owners should review their property records to ensure that all registration and ownership information is accurate and up to date before the filing deadline. Any discrepancies should be corrected promptly with the GDT to avoid delays in filing or potential administrative penalties.

This Prakas establishes measures and procedures governing tax liability in cases of business transfers, share transfers, and mergers. It applies to taxpayers under the self-assessment regime conducting business in the Kingdom of Cambodia.

Taxpayers involved in a business transfer, share transfer, or merger must:

• Notify the GDT and update the relevant information within 15 working days after the date of the transfer agreement or the approval by the Ministry of Commerce.
• Comply with tax registration requirements when two or more entities merge or consolidate into a new entity.
• Submit relevant documents directly to the GDT or via the GDT HomeTax digital platform.

Liability principles

• Sole proprietorships and general partnerships: The owner of a sole proprietorship and general partners in a partnership assume unlimited liability for tax debts. This liability extends beyond business assets to personal assets.
• Limited partners: Limited partners are liable only up to the amount of their agreed capital contribution.
• Shareholders: Shareholders are liable for a company’s tax debts in proportion to their shareholding and limited to the value of their investment. However, in the case of tax fraud or tax evasion, the limited liability shield is pierced, and shareholders are liable for the resulting tax liabilities in proportion to their shareholding.

Business transfers

Sole proprietorships or partnerships:

• If the transferor applies for tax clearance, the transferee is liable only for the tax debts incurred after the transfer date.
• If the transferor does not apply for tax clearance, the transferee is liable for all tax debts incurred before and after the transfer date.

Legal entities:

• When the transferor ceases operations: If the transferor intends to liquidate, it will normally apply for tax clearance during the liquidation process. In this case, the transferor remains liable for all tax debts up to the transfer date; the transferee is liable thereafter. If the transferor fails to apply for tax clearance, the transferee then assumes all tax debts incurred, both before and after the transfer date.
• When the transferor continues operations: The transferor remains liable for debts up to the transfer date, regardless of clearance. The transferee is liable only for debts incurred after the transfer date.

Business transfers are not subject to value added tax (“VAT”) if notification and information updates are completed and the business continues under the transferee. Otherwise, the transfer is subject to 10% VAT.

Share transfers

• Legal entities: Shareholders acquiring, increasing, or decreasing shares are liable for tax debts in proportion to their shareholding, based on the principle of limited liability.
• Partnerships: Partners acquiring transferred interests are liable for tax debts in proportion to the interest received.
• Mergers

In the case of a merger of two or more legal entities, the resulting or continuing entity is liable for all of the merged entities’ tax debts.

Litigation

This Prakas addresses what happens to seized property while criminal proceedings are still ongoing. It sets out rules for the temporary disposition of seized property through means other than public auction by a number of different measures, depending on the property’s nature and circumstances.

The measures are intended to preserve the property and, where applicable, maintain its economic value and business operations while the relevant legal proceedings are ongoing. They follow the principles below with regard to managing the seized property temporarily.

• Use for the public benefit: The seized property can be managed, maintained, or used for public purposes.
• Preservation of value: Measures should safeguard the economic benefit or integrity of the property.

Any decision concerning the temporary disposition of seized property must be made by an order of the competent prosecutor or court, and specify one or more of the following measures:

• Continuation of existing contracts relating to seized property that is used for commercial activities, provided that such contracts do not transfer ownership of the seized property.
• Where the seized property consists of shares or other financial instruments, appointment of a government entity or representative to exercise the related rights to safeguard the economic value of the seized property;
• Continuation of business operations involving an ongoing entity or commercial activity, including maintaining the existing management structure, restructuring the management, or appointing a temporary administrator or other recognized expert to manage the business.
• Appointment of a representative to protect rights relating to the seized property in legal proceedings involving third parties.
• Other appropriate arrangements based on the specific nature or circumstances of the seized property.

The temporary disposal implementation committee under the MOJ is responsible for monitoring and evaluating the implementation of the temporary disposition measures and may provide recommendations to the competent prosecutor or court where necessary to ensure the property is effectively managed and its associated economic value and economic interests are preserved.

Real Estate

To improve the efficiency of public service delivery and enhance citizen satisfaction, the MLMUPC has announced measures to assist property owners who face difficulties in receiving or transferring land title certificates, as follows:

• If the property owner is ill or disabled and cannot collect the certificate in person, the MLMUPC will deliver the certificate directly to their residence.
• If the property owner is hospitalized in Cambodia and wishes to transfer or donate property, the MLMUPC will dispatch a working group to the hospital to facilitate the necessary procedures.
• If the property owner is hospitalized abroad, the MLMUPC will prepare the necessary documents through an authorized representative, with the additional requirement of a video recording (with audio) to confirm the owner’s intent.
• If the property owner suffers from memory loss, confirmation from a medical specialist is required. The MLMUPC will then assist with one of the following procedures:
  • Division of the property based on family agreement.
  • Division of the property in accordance with the law.
  • Division of the property if there is no family agreement, which will fall under the jurisdiction of the court.

Customs

The notification announces the introduction of the first phase of the GDCE’s online complaint system. This initiative is intended to improve public service delivery by providing a more accessible, efficient, and transparent mechanism for receiving complaints from businesses and the public.

In addition to the existing complaint mechanism through physical customs complaint boxes, the GDCE is now encouraging the public to submit complaints electronically through the online complaint system.

Under this new system, complaints can be submitted as either an anonymous complaint or an identified complaint, whereby complainants provide their contact information for follow-up purposes.

The online complaint system is available through the GDCE’s dedicated portal at https://complaint.customs.gov.kh.

Manufacturing

Product labels play an important role in providing accurate information, demonstrating regulatory compliance, and maintaining consumer trust. The unauthorized use of government logos or certification marks on product labels may mislead consumers and expose businesses to regulatory and reputational risks.

The MISTI has identified a number of domestic and imported products that display the MISTI logo without proper authorization; therefore, it has issued this notification to remind businesses to comply with the following requirements:

• All products marketed in Cambodia must comply with the Cambodian standard on product labeling (CS 001-2000)
• The MISTI logo or logos of former ministries cannot be printed or displayed on product labels or packaging without prior authorization; any unauthorized use must cease immediately.
• The Cambodian Standard Mark cannot be used unless the business has obtained a valid license for its use from the MISTI; any unauthorized use must cease immediately.

Accounting and Auditing

The ACAR has found that a number of individuals and entities are providing accounting and auditing services without the required professional license, in violation of the Law on Accounting and Auditing No. NS/ RKM/0416/008 dated April 11, 2016.

This notification was issued as a reminder that those providing accounting or auditing services must obtain the appropriate professional license.

Key Highlights

Eligibility and licensing requirements

Any individual or entity providing accounting or auditing services must:

• Be registered as a member of the Kampuchea Institute of Certified Public Accountants and Auditors; and
• Hold a valid professional license issued by the ACAR.

Scope of regulated services

The licensing requirement applies to the following services:

Accounting services

• Bookkeeping
• Accounting transaction recording and classification
• Financial statement preparation and presentation
• Accounting review and certification services
• Sample financial statement preparation
• Company liquidation services

Auditing services

• The independent and systematic review and evaluation of data, reports, transaction records, and the financial or non-financial results of an entity for a specific purpose.

Responsibilities of service users

All entities (including non-profits and associations) engaging external accounting or auditing service providers should verify that they hold a valid ACAR professional license. Engaging an unlicensed service provider may expose both the provider and the service user to regulatory enforcement and legal consequences.

Penalties for non-compliance

Providing accounting or auditing services without the required professional license may result in the following penalties under the Law on Accounting and Auditing:

• Individuals: Imprisonment for a period of from six months to two years and fines ranging from KHR2 million to KHR 8 million.
• Entities: Criminal liability under Article 42 of the Cambodian Criminal Code, fines ranging from KHR5 million to KHR20 million, and other penalties as prescribed under the applicable laws.

Individuals and entities currently providing accounting or auditing services should review their licensing status and, where necessary, promptly apply for the required professional license. Businesses engaging external accounting or auditing service providers are also encouraged to verify the licensing status of their providers to ensure compliance and mitigate regulatory risks.

Commerce

This notification serves as a reminder to all entities (including handicraft businesses) that manufacture or import products for circulation in the Cambodian market of their continuing obligations under the product registration mark licensing regime, specifically complying with the product sampling and testing requirements stipulated in product registration mark license agreements.

Key requirements

Owners or representatives of entities holding product registration mark licenses are required to:

• Submit product samples for quality and safety testing every six months.
• Cooperate with sampling procedures conducted by officers of the product registration office of the ISC or officers responsible for standards work at the provincial or municipal departments of the MISTI.
• Pay the applicable service fees for product quality and safety testing.

Regulatory consequences of non-compliance

Failure to comply with the mandatory product testing requirements may result in suspension or revocation of the product registration mark license in accordance with the Law on Standards and the Law on Amendments to the Law on Standards.

Commerce

These regulations introduce several significant reforms and clarifications while further simplifying key business registration procedures. The aim is to reduce administrative burden, improve the business registration environment, and support the implementation of initiatives introduced under Prakas No. 117 dated December 9, 2025.

Below are the main highlights of the Phase Two initiative:

1. Shift to digitalized business registration:

• The submission of hard copies of articles of incorporation (“AOI”) and other relevant company documents in connection with business registration or corporate updates is no longer required. In place of the traditional physical official stamp on the AOI, document verification is now conducted through the government online platform, gov.kh, which is used to authenticate and validate the legal validity of the documents.
• The registration of a local branch is now fully integrated into the online business registration portal. In addition, any changes to the branch manager no longer require notification to the MOC.

2. Business objectives requiring prior approval:

• Companies may freely select their business objectives, except where the proposed business activities fall within regulated sectors that require a prior approval-in-principle from the relevant competent authority before registration can be completed with the MOC. Pursuant to Annex 1 of Prakas No. 044, the main regulated sectors are:
  • Banking
  • Telecommunications
  • Tourism
  • Casinos and gambling
  • Non-bank financial services and activities
  • Mining

3. Reduced requirements for the company secretary:

• The requirement for a professional company secretary licensed with the MOC to maintain a security deposit has been removed.
• Any individual may be appointed as a company secretary, except where otherwise restricted by specific statutory provisions.
• The filing and updating of company secretary information must now be done through the MOC online system and is free of charge.

4. Migration of the MOC’s new online system and enhanced business services support

• To improve user support and further enhance the efficiency, security, and stability of the business registration online system, the MOC has officially migrated to a new platform at businessregistration.moc.gov.kh.
• All future corporate updates, amendments, and filings of the Annual Declaration of Commercial Enterprise (“ADCE”) must now be conducted exclusively through this new platform. To access the system, users are required to use their existing username and registered email address to reset their password.
• Due to the migration of the MOC business registration online system and the change in the ADCE filing timeline in accordance with Prakas No. 117, a dedicated working group has been established to provide free-of-charge assistance to private-sector users in relation to:
  • ADCE filings
  • Account recovery requests
  • Updates to company information
  • Other issues with the online business registration portal

Users can access this assistance by contacting the MOC hotline at 1266 and pressing 2 or by visiting the MOC during working hours.

5. Abrogation of the dispute resolution mechanism

Chapter 10 of Prakas No. 117, which established a formal complaint mechanism for any shareholder to challenge unauthorized corporate changes that could result in significant losses or prejudice to their rights and interests, has been formally repealed.

These reforms reflect Cambodia’s ongoing commitment to modernizing its regulatory framework and fostering a more attractive investment environment. By simplifying administrative procedures, enhancing regulatory efficiency, and expanding digital public services, the government seeks to facilitate business operations and encourage both domestic and foreign investment.

To implement the directives of the Royal Government of Cambodia, the Consumer Protection, Competition, and Fraud Repression Directorate-General (“CCF”) of the MOC issued this notification to protect public health and safety by preventing the circulation of unsafe, prohibited, and untraceable products in the Cambodian market.

Key highlights are provided below.

Obligations for importers, traders, and distributors

It is strictly prohibited to import, sell, distribute, or supply any goods that:

• Contain prohibited or harmful chemical substances.
• Are illegally processed or adulterated in a manner that may endanger consumer health or safety.
• Are banned from importation under applicable law.
• Have unclear or unverified origins.
• Are not compliant with applicable standards and regulations.

All stakeholders must strictly adhere to product safety principles, particularly for food products, including but not limited to:

• Proper storage conditions.
• Hygiene requirements.
• Packaging standards.
• Transportation safety.
• Distribution and supply chain integrity.

Obligations for retailers and secondary distributors

Retailers and downstream distributors are expected to strictly comply with product safety requirements when supplying goods to consumers, and must:

• Refrain from selling or distributing any products that may pose a risk to consumer health, have unclear origins, or are not compliant with regulatory standards.
• Ensure that suppliers provide valid invoices or supporting documentation for traceability purposes.
• Fully cooperate with the CCF in:
  • Product traceability investigations.
  • The identification of production, import, and distribution sources.
  • The sampling and laboratory testing of products to assess potential risks.

Obligations for consumers and the general public

Consumers and the general public are advised to:

• Exercise caution and increase vigilance when purchasing goods.
• Avoid purchasing products suspected of containing prohibited chemical substances, adulterants, or harmful components.
• Refrain from buying goods with uncertain or unverifiable origins.
• Report any suspicious products being sold or distributed in the market to the CCF for investigation and legal action in accordance with applicable laws.

The CCF will take the necessary legal measures in accordance with applicable laws against any individuals or entities found in violation of this regulatory guidance.

Advertisement

Following high-level direction from the Royal Government of Cambodia, the MEF has introduced new regulatory measures governing promotional practices in the beverage sector aimed at addressing concerns relating to aggressive marketing practices for both alcoholic and sugary beverages.

The measures will be implemented in phases, with full enforcement from October 1, 2026.

The notification introduces a uniform restriction on all reward-based promotional schemes for both sugary beverages (including energy drinks) and alcoholic products (both beer and other alcoholic beverages).

• All forms of promotional rewards, including but not limited to can tabs, bottle caps, and any similar mechanisms, must be fully discontinued by the end of the third quarter of 2026.
• From October 1, 2026 onward, entities are:
  • Prohibited from offering any form of promotional rewards for both sugary and alcoholic beverages.
  • Not permitted to order, import, produce, or distribute any packaging materials linked to reward-based promotional schemes.

The instruction imposes restrictions on advertising, sponsorship, and collaboration with the tobacco industry and businesses engaged in the import, manufacturing, and distribution of nicotine products.

It aims to protect public health, by reducing exposure to tobacco and nicotine product promotion and influence.

Under the instruction, all public institutions, educational institutions, and private businesses operating in Phnom Penh are prohibited from the following:

• Advertising tobacco goods, electronic smoking devices, and other smoking-related chemicals or substances in any way and anywhere.
• Cooperating, entering into sponsorships, or signing memorandums of understanding with tobacco or nicotine product businesses.
• Allowing the use of their venues for tobacco or nicotine product promotional activities.

These entities should review their existing sponsorship arrangements, partnership agreements, promotional activities, and venue-use policies to ensure compliance with the instruction.

Customs

In line with Cambodia’s ongoing digital transformation agenda and the continued enhancement of cybersecurity measures across public administration systems, the GDCE has introduced a new security requirement applicable to its electronic customs platform, the Automated System for Customs Data (“ASYCUDA”).

ASYCUDA has replaced traditional paper-based processes and is now used by importers, exporters, customs declarants, and relevant stakeholders to submit customs declarations, process imports and exports, and calculate duties and taxes.

The GDCE has implemented an additional security layer designed to enhance user authentication, data privacy, and system integrity, and to reduce the risk of unauthorized access to sensitive customs data.

From May 15, 2026, ASYCUDA will require two-factor authentication (“2FA”) using a one-time password. The 2FA system will require users to verify their identity through two separate authentication steps:

• Their own password; and
• A one-time password generated via the National Single Window Authenticator application.

Transportation

As electric vehicle (“EV”) adoption continues to grow in Cambodia, the MISTI has issued an instruction aimed at enhancing consumer awareness of EV safety and reducing potential risks associated with the operation, charging, and maintenance of EVs.

Many EV users have a limited understanding of basic safety measures, which may pose risks to drivers, passengers, and other road users, property, the environment, and public safety.

Thus, the MISTI is instructing EV manufacturers, importers, and distributors to strengthen consumer education and ensure compliance with applicable safety standards by:

• Requiring basic EV safety instructions in the Khmer language, accompanied by illustrations, before vehicles are sold in Cambodia. These should address, among other matters:
  • Vehicle system failures that prevent doors or windows from opening
  • Battery fires or explosions resulting from collisions
  • Battery overheating during charging
  • Charging-related issues caused by unsuitable electrical supply conditions
  • The safe use of charging equipment during rainfall or when batteries are overheated
  • Electrical short circuits or system failures arising from flooding, rainy conditions, or vehicle washing
• Encouraging EV suppliers to develop short educational videos based on the safety guidance materials.
• Requiring EV suppliers to provide customers with basic safety training and guidance on the proper use and potential risks of operating an EV.
• Requiring that all EVs marketed are registered with the MISTI in compliance with the applicable laws and regulations.
• Requiring that EV suppliers cooperate with Cambodian Standards Inspectors and facilitate regulatory inspections and compliance verification activities conducted by the MISTI.

Manufacturers, importers, and distributors of EVs should review their existing customer information materials to ensure alignment with this instruction, which enters into effect on May 12, 2026.

Taxation

In response to rising global fuel prices and continued economic pressure, the MEF has introduced a state-borne VAT mechanism applicable to the domestic supply of diesel and LPG. This targeted fiscal relief initiative is aimed at reducing the financial burden on citizens and businesses while stabilizing the prices of essential fuel products. 

Under this instruction, the government will bear the full 10% VAT applicable to the supply of diesel and LPG, thereby relieving final consumers from paying VAT on these products. 

The measure entered into effect from April 1, 2026 and will remain in force until further notice. 

Obligations of suppliers engaged in the importation and distribution of diesel and LPG products in Cambodia 

Invoicing requirements: 

• For taxpayers under the self-assessment regime, a VAT invoice must be issued without charging VAT and should indicate “State-Borne VAT” in place of the standard “10% VAT.” 

• For final consumers who are not under the self-assessment regime, a standard invoice must be issued, with the sales price not subject to VAT. 

Monthly tax declaration (e-filing system) 

In the e-filing system, under the “Purchase and Sales Journal” function, suppliers must select the transaction type as “State-borne VAT.” 

Input VAT credit entitlement 

The notification provides clarity on how to handle input VAT credits. VAT incurred at the rate of 4% and/or 10% on the importation or domestic purchase of diesel and LPG remains fully creditable as input VAT, provided that entities maintain proper supporting documentation, including customs declarations, VAT invoices, and valid payment records. 

Accounting

This new instruction, which is effective from the date of issuance, requires enterprises and non-profit organizations to formally notify the ACAR when ceasing operations.

Key highlights

• Mandatory notification: Entities must submit a cessation notice to the ACAR at least 60 days before the annual financial statement filing deadline, along with the applicable service fees.
• Required supporting documents: These include the entity’s certificate of financial reporting identification number (FIN certificate), payment confirmation receipts for payments submitted when filing prior years’ financial reports, outstanding financial statements (if any), and the relevant cessation requests submitted to other authorities (if applicable).
• Outstanding compliance obligations: Entities must fulfill all pending financial statement obligations before the ACAR approves the cessation.
• Deemed ongoing operations: Failure to notify the ACAR within the prescribed timeline will result in the entity being considered still active and subject to ongoing legal obligations and potential penalties.

This marks a tightening of enforcement by the ACAR – entities must now proactively notify and settle all reporting obligations to avoid continued liabilities.

Labor

Following the outcome of the National Minimum Wage Council meeting held on March 20, 2026, the MLVT issued this notification to address the rising costs of transportation and accommodation faced by workers due to the global fuel crisis.

Under the notification, all entities operating in the garment and textile, footwear, and travel goods and bag manufacturing sectors must provide an additional US$2.50 per month to their workers. This amount is to be added to the existing transportation and accommodation allowances that entities already provide.

This temporary increase entered into effect on April 1, 2026, and will remain in force until further notice from the MLVT.

Customs

Amid growing global attention to clean energy and sustainable development, Cambodia has revised its customs tariff framework with targeted reductions in import duties and export tariffs to promote the adoption of environmentally-friendly technologies, support development, encourage the use of clean energy, and enhance trade efficiency.

Following the issuance by the Royal Government of Cambodia of Sub-Decree No. 52 dated March 26, 2026, on the adjustment of customs import duty and export tax rates on certain goods, the GDCE issued this notification to support its implementation. The adjusted customs duty and export tariff rates entered into force on April 1, 2026, and apply to all relevant import and export activities from that date onward.

A summary of the key revised rates are shown in the table below.

Import Duty Rates

Category	Previous Rate	New Rate
Electric vehicle (“EV“) battery chargers, electric rice cookers, and solar lamps	7%	0%
Electric motors (for EVs), solar energy systems, lithium batteries (including laptop batteries, aircraft batteries, car batteries, solar batteries, and energy storage devices, such as power banks, power stations, mobile phone batteries, etc.), microwaves, electric kettles, and passenger and cargo vehicles (hybrid EVs, plug-in hybrid EV (“PHEVs“), and EVs)	15%	0%
Family PHEVs	35%	7%
Electric stoves, toasters, and family EVs	35%	0%

Adjusted Export Tariffs

Category	Previous Rate	New Rate
Bauxite (aluminum ore)	25%	10%

Real Estate

In light of Cambodia’s rapid urbanization, the regulation of elevator installation and maintenance has become a critical legal and public safety priority.

MLMUPC issued this Prakas to establish a legal framework to regulate elevator installation activities. It sets out the conditions and procedures for the granting, suspension, and revocation of installation licenses, with the objective of ensuring safety, quality, and professional accountability within the construction sector.

Scope of application

The Prakas applies to all types of elevators, including lifts, escalators, and travelators, except those used at construction sites.

Elevator installation license categories and conditions

A. Level 1 elevator installation license

This license is granted to companies authorized to carry out elevator installation, repair, and modification works for all types of construction projects.

Requirements:

• A valid business registration with a construction-related business objective
• One technical manager (an engineer holding a mechanical engineering degree with at least five years of experience)
• Three technical personnel (engineers holding a mechanical, electrical, and civil engineering degree, each with at least three years of experience)
• A valid insurance certificate issued by an insurance company operating in Cambodia covering liability arising from business operations

B. Level 2 elevator installation license

This license is granted to companies authorized to carry out elevator installation, repair, and modification works only for construction projects approved by the authorities at the capital, provincial, municipal, district, and khan administration levels.

Requirements:

• A valid business registration with a construction-related business objective
• One technical manager (an engineer holding a mechanical engineering degree with at least three years of experience)
• Two technical personnel (engineers holding a mechanical and electrical engineering degree, each with at least two years of experience)
• A valid insurance certificate issued by an insurance company operating in Cambodia covering liability arising from business operations.

Licensing procedure

The application, which is submitted through the MLMUPC’s One Window Service Office, must include the following documents:

• Company-related documents:
  • A completed application form
  • A copy of the business registration certificate
  • A copy of the insurance certificate
  • A list specifying the technical manager and technical personnel
• Company director’s information:
  • A copy of their national ID card or passport
• Technical manager and personnel information:
  • A copy of their national ID card or passport
  • A copy of academic qualification (degree)
  • A copy of a professional registration certificate issued by the relevant professional association
  • A copy of a valid work permit and residency certificate (if foreign personnel)
  • A copy of proof of relevant work experience (to be legalized by the relevant embassy if the individual is a foreign national)

The competent authority will review the application within a maximum of 15 working days from the date of submission.

License validity and renewal

Elevator installation licenses are valid for a period of three years from the date of issuance, and are renewable. Renewal applications must be submitted at least 30 days before the license’s expiry date.

If a license expires, the holder may continue to perform obligations arising from existing elevator installation service contracts, provided that such contracts were concluded when the license was still valid.

However, license holders are strictly prohibited from entering into any new elevator installation service contracts after their license expires.

License holders’ obligations

License holders are subject to strict operational obligations, including requirements to:

• Comply with technical standards and construction regulations.
• Adhere to professional ethics.
• Ensure the safety of workers and construction sites.
• Cooperate with technical inspectors.
• Provide a 24-hour emergency hotline.
• Prepare technical reports for each installation.

Penalties

Failure to comply with this Prakas or respond within the specified timeframe will result in penalties such as warnings, or suspension, or revocation of the license, depending on the severity of the violation.

Commerce

The MOC recently released a progress report on the outcomes of the issuance of Prakas No. 117 dated December 9, 2025 on business registration reforms and Notification No. 0051 dated January 8, 2026 on penalty waivers for lack of compliance with annual declaration requirements. Essentially, the MOC is moving to modernize how companies are registered while offering a waiver of some penalties for companies that have failed to file their annual declarations.

Outcome of the penalty waiver for failure to file annual declarations under Notification No. 0051

The MOC confirmed a positive outcome so far and reported encouraging participation from the business community.

To date, 224 companies have submitted applications for the penalty waiver. In addition, 498 shareholders have voluntarily participated in background checks on natural persons, a measure introduced to enhance transparency and strengthen anti-money laundering compliance within the business registration framework.

Through this verification process conducted via the Dow Jones watchlist screening system, nine shareholders were identified as being on a monitoring list. These individuals were subsequently requested to remove their names from the business registration system.

In the press release, the MOC included a reminder that compliant companies can continue to file their annual declarations within the same timeframe as the patent tax payment process at the General Department of Taxation, which occurs between January and March each year.

Outcome of business registration reforms under Prakas No. 117

The MOC also reported positive developments regarding business registration.

Business registrations conducted through the CamDx system increased by 9.3% in January 2026 compared to January 2025, indicating a growing demand for new business registrations in Cambodia.

Clarifications on the company secretary requirement

In light of the increase in new business registrations and to facilitate a smoother transition for companies, the MOC announced that the implementation timeline for the company secretary requirement has been extended until January 2027.

It also provided clarification on the company secretary requirement. Pursuant to the Law on the Amendment of the Law on Commercial Enterprises, together with Prakas No. 117, it applies only to limited liability companies. It does not apply to:

• Sole proprietorships
• Startups
• Informal economy groups
• Small and medium-sized enterprises

In addition, limited liability companies can appoint any individual as its company secretary without them having to meet the specified qualifications. However, individuals who intend to provide company secretary services professionally to multiple companies must comply with the qualification conditions set out in Article 25 of Prakas No. 117.

Upcoming Prakas on business registration guidance

To further facilitate and provide additional guidance to the private sector, the MOC is currently preparing a draft Prakas that will formally recognize its Business Registration Handbook, which supplements the existing regulatory framework by providing practical guidance on business registration procedures and compliance with standard operating procedures.

Banking and Finance

To address the growing need for effective management of distressed assets, the NBC has established legal and operational requirements for institutions that specialize in the acquisition and management of non-performing loans (“NPLs”) and related collateral from banks and financial institutions. The Prakas aims to enhance financial stability by facilitating the effective resolution of distressed loans while ensuring proper oversight and governance of institutions involved in this activity.

Permitted and prohibited activities

Licensed Asset Management Institutions (“AMIs”) can engage in several activities related to the management and recovery of distressed loans, including:

• Acquiring and managing NPLs and related collateral from Banks and Financial Institutions (“BFIs”).
• Acquiring and managing debtor assets through court-ordered auctions, provisional administration, or liquidation processes.
• Providing debt collection services to BFIs.
• Facilitating the sale of collateral with the debtor’s consent.
• Selling loans to BFIs or other AMIs.
• Conducting other activities permitted by the NBC.

However, AMIs are prohibited from engaging in certain financial activities, including:

• Providing loans or refinancing services.
• Providing loan guarantees.
• Acquiring NPLs from BFIs that have extended lending facilities to the AMI.
• Conducting other activities prohibited by the NBC.

Formation and capital requirements

To obtain a license, an AMI must be established as a public limited company and maintain a minimum registered capital of KHR200 billion. Before commencing operations, an AMI is required to deposit an amount equal to 100% of its registered capital into an account with the NBC. In addition, the AMI must deposit with the NBC an amount equal to 5% of its registered capital as a capital guarantee.

To obtain a license, applicants must submit comprehensive documentation to the NBC, including corporate information, governance structure, shareholder details, business plans, strategies for NPL acquisition and management, internal audit procedures, and details on its consumer complaint resolution mechanism.

Licensing and regulatory approval

The NBC will review license applications and notify applicants of its decision within six months of the date of application submission. Licenses granted to AMIs are valid for five years and may be renewed, provided the renewal application is submitted at least six months prior to the license’s expiration date.

AMIs are required to obtain prior approval from the NBC for significant corporate changes, such as:

• Changes to the institution’s name or address
• Changes in registered capital
• Amendments to the articles of incorporation
• Changes in directors or senior management

BFIs that intend to acquire or hold equity interests in an AMI must obtain prior written approval from the NBC to do so.

Official fee

Licensed AMIs must pay an annual license fee of KHR50 million, which must be paid before January 15 each year. For institutions that receive their license during the year, the payment structure is adjusted depending on the timing of approval:

• Institutions licensed during the first half of the year must pay the full annual fee,
• Institutions licensed during the second half of the year pay only half of the annual fee.

In addition to the annual license fee, AMIs are required to pay several administrative fees, including:

• Information request fee: KHR500,000
• License processing or renewal fee: KHR2.5 million
• Fee for changes to the articles of incorporation: KHR1 million per page
• License amendment fee: KHR2 million
• Share transfer or capital increase fee: 0.5% of the value of the shares transferred or the increase
• Decrease in capital fee: 1% of the value of the decrease in capital

Acquisition and transfer of NPLs

AMIs must acquire NPLs from BFIs through transparent and arm’s-length transactions at prices mutually agreed upon by the parties.

Once an NPL is transferred, the AMI assumes the rights and obligations of the creditor, including the right to enforce claims against debtors and guarantors and to manage or dispose of associated collateral. When transferring NPLs, BFIs must obtain prior approval from the NBC and provide relevant documentation such as board resolutions, a letter requesting approval for the NPL sale, and valuation reports.

BFIs must also transfer all related loan documentation and notify customers and credit reporting service providers of the transfer of the NPLs.

Supervision requirements

AMIs shall submit quarterly reports to the NBC, including financial statements and reports on NPL portfolio performance and recovery activities, no later than the 15th day of the first month of the next quarter.

AMIs also submit annual audited financial statements no later than April 30 of the following year. If an AMI fails to comply with these requirements, it shall be subject to a transactional fine of KHR1 million per day.

AMIs shall maintain all transactions and records for at least 10 years following the final resolution of the relevant NPLs and associated collateral.

Governance requirements

All AMIs shall have a board of directors consisting of at least five members, including at least two independent members.

Board members and senior management shall have the appropriate qualifications, experience in banking or financial systems, and knowledge of the relevant regulations. Individuals convicted of serious financial or criminal offenses, including fraud, theft, money laundering, or bankruptcy-related misconduct, are prohibited from holding these positions.

Fines and license enforcement

The NBC may impose fines as follows;

• Failure to comply with this Prakas (other than supervisory requirements, which are covered separately): A transactional fine of KHR 3 million per day.
• Failure to comply with an injunction or breaching of other relevant regulations: A fine of KHR1 million per day.

Failure to start operations within six months of licensing, violating laws, becoming insolvent, or voluntarily ceasing operations: Suspension or revocation of the AMI’s license.

Real Estate

Under this Prakas, the MLMUPC introduces a comprehensive framework that mandates the strict regulation of elevator systems across Cambodia to safeguard lives and property. It applies to all types of elevators used in buildings and other structures, including passenger or freight lifts, escalators, and moving walkways.

Elevator use certificate requirement

Under this Prakas, elevators can only be used after obtaining an elevator use certificate issued by the MLMUPC. The application must be submitted through the ministry’s Single Window Service and may be filed either separately or together with the certificate of use of the building in which the elevator is installed. While multiple elevators within the same project can be included in a single application, a separate certificate will be issued for each elevator.

Application documents and procedure

Applicants must submit an application package that includes:

• An application form for the elevator use certificate
• The applicant’s identification documents
• Construction permit and site opening permit (if available)
• Technical documents, including an inspection and report of the elevator installation works

The MLMUPC shall examine the application and decide within 21 working days from the application submission date. If approved, an elevator use certificate shall be issued and delivered to the applicant within two working days from the date of the ministry’s decision.

Validity and periodic safety inspection

The elevator use certificate has indefinite validity. However, building owners must ensure that elevators undergo quality and safety inspections by licensed elevator inspectors every two years. The inspection must confirm that the elevator system remains compliant with technical and safety standards.

Following inspection, the MLMUPC shall issue an elevator quality and safety certificate, which will be recorded in the digital elevator data management system maintained by the ministry. Where technical defects are identified during inspection, the building owners are responsible for arranging for repair or modification before the safety inspection report can be issued.

Compliance measures and enforcement

The MLMUPC shall issue a written warning to building owners in cases where elevators are operated without periodic safety inspections or where technical defects are identified.

Failure to comply with the warning or respond within the specified timeframe shall result in the suspension of the elevator use certificate, during which the elevator must not be used.

In more serious cases, including where the elevator is dismantled, replaced entirely with a new system, or where the safety system is permanently defective and cannot be repaired, the elevator use certificate shall be revoked.

Transitional requirement

For elevators already in operation before the entry into force of this Prakas, building owners are required to apply for an elevator use certificate within one year in accordance with the procedures. Failure to comply after this transitional period shall result in enforcement actions under the construction laws in force.

Real Estate

This Sub-Decree establishes a comprehensive legal framework to strengthen security, public order, and social safety in collective living environments throughout the Kingdom of Cambodia.

Scope and Application

It applies to all collective living areas, whether public or private, including boreys, condominiums, apartments, co-ownership buildings, factories, enterprises, farms, special economic zones, hotels, guesthouses, dormitories, religious institutions, orphanages, and similar residential settings across Cambodia.

It imposes legal obligations on heads of units, owners, managers of collective living areas, residents, and private security service providers. Residential areas under the Royal Cambodian Armed Forces and the National Police are excluded from this scope.

Competent Authorities

The Ministry of Interior (“MOI”) is the primary authority responsible for leading implementation. It delegates operational responsibilities to the administrations of the capital, provinces, cities, districts, and khans, which are accountable for accommodation management and the enforcement of security and safety measures within their respective jurisdictions.

Security and Safety Measures

The competent authorities are responsible for:

• Conducting regular administrative inspections of collective residential areas;
• Arranging, supervising, and inspecting security protection systems, including CCTV systems, fire prevention, and access control mechanisms.

The owners, managers, and heads of units of collective living areas are required to:

• Maintain accurate and up-to-date resident records, in paper and/or electronic form;
• Report any changes in residency to the local authorities in a timely manner;
• Submit resident lists, identification documents, and accommodation-related records upon request;
• Report the temporary presence of foreigners within 24 hours to the competent authorities;
• Cooperate fully with administrative inspections conducted by competent authorities;
• Verify foreigners’ legal entry and residence documents before permitting residence;
• Prohibit the residence of foreigners who have entered the Kingdom of Cambodia illegally;
• Report suspicious individuals or activities that may pose security or safety risks.

Foreigners holding a valid permanent residence permit from the MOI must report and register their residency within 48 hours of receiving the permit, while other foreign residents in a Concentrated Residential Area must register their residency in compliance with applicable laws and regulations.

All security camera data shall be retained for a minimum of 90 days, and records of movements into and out of the Concentrated Residential Area shall be maintained for a minimum period of 1 year. Furthermore, these data and records shall be provided to competent authorities upon request to enhance investigatory capacity and accountability.

Penalties and Enforcement

Failure to comply with the Sub-Decree may result in administrative and sanctions, including:

• A fine of KHR 400,000 (approx. USD100) for negligence in fulfilling obligations related to security and safety systems;
• A fine of KHR 4,000,000 (approx. USD1,000) per foreigner for intentionally allowing illegal foreign residents, without prejudice to criminal liability;
• Officials who fail to perform their duties in good faith shall face disciplinary action, including dismissal.

This Sub-Decree significantly enhances regulatory oversight of concentrated residential areas and places clear legal responsibilities on owners, managers, private security providers, and authorities. All relevant stakeholders are advised to review their current practices, ensure compliance with resident management and security requirements, and prepare for increased inspections and enforcement.

Labor

The MLVT specifies in this notification that strict legal measures will be taken against any employer who requires Cambodian migrant workers returning from Thailand to present a Cambodian national ID card as a condition of applying for employment.

This requirement contradicts the Notification No. 026/25 dated August 11, 2025, concerning the exemption from the obligation to attach Cambodian national ID cards when applying for employment for Cambodian migrant workers returning from Thailand.

Clarification on acceptable identification documents

The MLVT further clarifies that, for the purpose of applying for legal employment, issuance of a Cambodian employment book, and registration with the National Social Security Fund, employers may accept any one of the following identification documents from Cambodian migrant workers returning from Thailand:

• Birth certificate
• Family book
• Passport
• Cambodian overseas worker travel document (TD)
• Cambodian -Thailand border pass
• Any other identity document issued by a competent authority

Requiring a Cambodian national ID card will be considered a violation of labor inspection measures and subject to administrative fines in accordance with the Labor Law.

Taxation

In a continued effort to strengthen the resilience and competitiveness of Cambodia’s export-driven industries, the MEF has announced the temporary suspension of the obligation to make monthly income tax prepayments for certain industrial enterprises in the textile and garment sector.

Purpose and policy objective

This goal is to promote the sustainability of the textile and garment industry, enhance export capacity, and protect employment opportunities for Cambodian workers who depend on this key sector of the economy.

Enterprises eligible for the suspension

The suspension applies to enterprises operating in the textile and garment sector that are registered as qualified investment projects, including manufacturers engaged in the following for export:

• Textile and garment production
• Footwear manufacturing
• Handbag and briefcase production
• Hat manufacturing
• Clothing label production
• Manufacturing of gloves, socks, and towels
• Production of pillowcases, quilt covers, bedspreads, and tablecloths

Duration of the suspension

The temporary suspension of monthly income tax prepayments begins from December 26 2025, through December 31, 2028.

Conditions for obtaining this incentive

To continue benefiting from this suspension, enterprises must strictly comply with the following requirements:

• Proper accounting records must be maintained in accordance with the applicable regulations.
• All tax declarations must be submitted and other tax obligations settled on time.
• An annual independent audit report must be provided to the tax authorities.

Failure to meet these compliance obligations may result in the revocation of the suspension and the imposition of a tax reassessment and penalties.

Trust

This Prakas establishes comprehensive conditions and procedures for obtaining approval to establish branches in Cambodia’s trust sector. It strengthens regulatory oversight and clarifies governance, licensing, and operational and compliance obligations applicable to licensed trust companies and trust service operators. Key highlights are provided below.

Scope

This Prakas applies to trust companies and trust service operators that have been licensed or authorized by the Cambodian Trust Regulator (“TR”) to conduct trust operations in the country.

No parent company may establish a branch, nor may any person represent itself as a trust branch, without obtaining prior approval from the TR.

Conditions for approval

To obtain approval to establish a branch, the Parent Company must comply with comprehensive regulatory conditions, including:

• Register the branch in the commercial register in Cambodia
• Register the branch with the tax department
• Must be a clear branch management structure that ensures transparency, accountability, efficiency, and sound corporate governance.
• Must have a suitable premise and operational facilities that are appropriate to the scale of the branch’s activities.
• Must have sufficient IT systems and infrastructure.
• Must implement effective internal control and risk management frameworks.
• Must have proper complaint-handling and dispute resolution mechanisms.
• Must have adequate, qualified, and regulator-approved personnel.
• Other requirements as determined by the TR.

The above operational requirements do not apply to parent companies that are commercial banks licensed or authorised to operate as trust service operators providing safekeeping or custodial services.

Management and human resource requirements

Each branch must appoint the following management personnel, as applicable:

• A branch director (required for all branches); and
• A head of operations (required for branches of trust service operators providing safekeeping or custodial services).

These individuals must be officially recognized as qualified by the TR prior to their appointment.

To be eligible, they must:

• Be of good character and satisfy fit-and-proper criteria.
• Be legally competent and reside in Cambodia.
• Hold at least a bachelor’s degree in trust, finance, or a related discipline (or an equivalent qualification).
• Possess the relevant professional experience:
  • At least four years for branches of licensed trust companies.
  • At least three years for branches of trust service operators providing safekeeping or custodial services.
• Be formally appointed by the parent company.
• Complete mandatory training and pass examinations organized or recognized by the TRC.

Examination results are valid for two years. Approved personnel must complete continuing professional education before the expiration of the validity period.

Branches of licensed trust companies must also appoint licensed individual trustees in numbers proportionate to the size and type of their trust operations.

Application process and regulatory review

• An application to establish a branch is submitted in the prescribed form, together with all required supporting documentation to the TR.
• The TR issues a written decision approving or rejecting the application within 60 days from receipt of a complete application dossier.
• The TR may conduct on-site inspections to verify operational readiness, governance arrangements, systems, and supporting documentation.
• The approved branch must then commence operations within 3 months from the date of approval.

Ongoing compliance obligations  

The parent company remains fully responsible for all obligations and activities of its branches. Vacancies in key positions must be filled within two months.

Branch operations must be conducted separately from the parent company’s other business activities, including:

• Separate operational systems and IT infrastructure;
• Dedicated personnel; and
• Appropriate information barriers to prevent conflicts of interest and misuse of information.

Prior approval from the TR is required for:

• The appointment or replacement of the branch director or head of operations.
• A change of the branch’s registered address.
• The transfer or reassignment of licensed individual trustees between the parent company and its branches.

Suspension, revocation, and closure

A parent company intending to close a branch must obtain prior approval and comply with the conditions prescribed by the TR.

The TRC may suspend or revoke a branch’s approval where:

• The parent company requests the suspension or termination of its operations.
• The parent company is in financial or technical distress, liquidation, or court-ordered dissolution.
• The parent company fails to maintain the required approval conditions.

Official Service Fees

• Fees to be paid by the parent company when applying to establish a branch:
  • Application fee: KHR20,000 per application (approx. USD5)
  • Dossier review fee: KHR600,000 (approx. USD150)

• Annual branch authorization fees

Upon approval from the TR, the parent company must pay an annual authorization fee for each branch, which varies depending on the type of trust operation conducted:

• • Public trust operations: KHR5 million per year (approx. USD1,250)
  • Commercial trust operations: KHR4 million per year (approx. USD1,000)
  • Social trust operations: KHR2 million per year (approx. USD500)
  • Individual trust operations: KHR2 million per year (approx. USD500)

• Fees for amendments or changes

Where the parent company seeks approval for certain changes, a dossier review fee of KHR200,000 (approx. USD50) per request applies in each of the following cases:

• • Change of a branch’s registered address
  • Appointment or replacement of a branch director or head of operations
  • Change in the workplace location of licensed individual trustees between the parent company and its branches, or between branches

All fees are non-refundable, regardless of whether the application is approved or rejected.

Administrative sanctions

Non-compliance may result in the imposition of administrative measures by trust inspectors, including:

• Warnings
• Corrective orders
• Restrictions on the license and/ or permit
• Restrictions on the management and/ or administration of trust
• Suspension of the license and/ or permit
• Removal or dismissal of branch management or responsible personnel
• Revocation of the license and/ or permit

The formalities and procedures governing the imposition of the above administrative sanctions and penalties shall be implemented in accordance with Prakas No. 002 dated January 03, 2024 on the Formalities and Procedures for Administrative Sanctions and Penalties in the Trust Sector.