Obligation to Submit 2025 Annual Financial Statements to the Accounting and Auditing Regulator

January 14, 2026

On December 23, 2025, the Accounting and Auditing Regulator (“ACAR”), announced that all business owners and non-profit organizations are obligated to submit the 2025 annual financial statements in accordance with the applicable accounting standards. The deadlines for submission are as follows:

For entities NOT subject to independent audit:

• Financial statements must be submitted to the ACAR no later than April 20, 2026.
• For entities with an approved accounting period ending on a date other than December 31, financial statements must be submitted to the ACAR no later than three months and 20 days from the closing date of their accounts.

For entities subject to independent audit:

• Audited financial statements must be submitted to the ACAR no later than July 20, 2026.
• For entities with an approved accounting period ending on a date other than December 31, audited financial statements must be submitted to the ACAR no later than six months and 20 days from the closing date of their accounts.

To ensure compliance with the Accounting and Auditing Law and to avoid administrative penalties, all entities should be aware of the following:

• Requirement to maintain proper accounting records: Entities must maintain accurate and complete accounting records in accordance with the applicable regulations.
• Timing for preparation of financial statements: Financial statements must be prepared in compliance with the applicable accounting standards within three months from the closing date of the accounting records.
• Special frameworks for small and medium-sized enterprises (“SMEs”): To facilitate compliance, SMEs that are not independently audited or publicly accountable must use the Cambodian Reduced Financial Reporting Framework, the Digital Financial Reporting Preparation Tool, and the Accounting Layout for Enterprises.
• Completion of independent audits: Independent auditing must be completed, and the audit opinion issued, no later than six months from the end of the accounting period for entities required to undergo independent audits.
• Obtaining a financial reporting identification number (“FIN”): FINs are necessary for submission of the financial statements to the ACAR. Entities that do not have a FIN must apply through the ACAR.
• Timing for requesting a change in FIN classification: Entities that change their classification (i.e. subject to independent auditing or not subject to it) must submit a request to the ACAR for a change in their FIN status no later than 60 days before the financial statement submission deadline.
• Eligibility for acting as the entity’s representative before the ACAR: Entities may appoint representatives to fulfill their accounting and auditing responsibilities with the ACAR. The representative may be an employee of the entity or an external accounting/auditing firm licensed by the ACAR. The entity owner or head is still fully responsible for the actions of the appointed representative.