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.
On August 10, 2026, the National Bank of Cambodia (“NBC”) issued Circular No. B37.026.006 on the obligations of Banks and Financial Institutions (“BFI”) to provide customer account information and to implement account freezing or unfreezing customer account.
The Circular aims to strengthen cooperation between BFIs and competent authorities while ensuring the proper handling of customer account information and account restrictions in accordance with applicable laws and regulations. Under the Circular, banking and financial institutions are required to:
- Direct compliance with competent authorities: The BFIs are required to directly review and comply with court orders or requests from competent authorities regarding customer account information and account freezing or unfreezing. The competent authorities are not required to obtain further confirmation from the NBC before taking action in accordance with such orders or requests. The NBC also clarified that it has no authority to interpret or provide further explanations regarding actions taken by competent authorities.
- Confidentiality obligations: The BFIs are bound by professional confidentiality obligations. Disclosure of customer information is permitted only to competent judicial authorities acting within the framework of criminal proceedings. It’s must also retain all documents and information relating to relevant orders or requests, their responses, and the information provided to competent authorities. Such records must be made available to the NBC upon request.
In this regard, the BFIs shall ensure to act swiftly and transparently in response to competent authority requests. By balancing confidentiality obligations with compliance requirements, the measure reinforces trust in the financial system.
The Ministry of Commerce of Cambodia (“MOC”) has officially migrated its business registration system to a new online platform. However, as of the date of this alert, no official public announcement has been made by the MOC.
Notwithstanding the above, all future corporate updates, changes, and Annual Declaration of Commercial Enterprise (“ADCE”) filings must now be conducted exclusively through this new platform. To access the system, you will be required to use your existing username and registered email address to reset your password.
New MOC Business Registration Platform
Website: https://newuser-businessregistration.moc.gov.kh/login
Steps to Reset Your Password on the New Platform
- Access the website using the link above.
- Enter your username and registered email address (the same details used for your existing MOC online account), then submit the request.
- Follow the link sent to your registered email to create a new password.
Your login credentials should be kept secure, as they will be required for all future filings with the MOC.
Change in Timeline for Filing the ADCE
With the new platform and in accordance with Prakas No. 117 on the Simplification of Business Registration dated December 9, 2025, the ADCE filing window opens three months prior to the anniversary of an entity’s incorporation date as stated in its Certificate of Incorporation and remains open for an additional 15 days after the incorporation date anniversary.
Accordingly, we strongly recommend activating your entity’s account on the new platform as soon as possible to ensure your entity remains compliant by avoiding any delays in filing the ADCE by the deadline.
If you have any questions regarding the new platform, please feel free to email Ms. Pauline Pen, Andersen in Cambodia Senior Associate, via pauline.pen@kh.andersen.com, or contact the MOC Hotline directly, at 1266.
We would like to once again draw your attention to Notification No. 038/25 dated December 22, 2025 issued by the Ministry of Labor and Vocational Training, which outlines the requirements for obtaining and renewing foreign work permits for the 2026 calendar year.
The deadline for renewal—March 31, 2026—is fast approaching. Those who have yet to process their work permit renewal should do so now to ensure timely compliance and avoid potential fines or other penalties as specified under the Cambodian labor law.
Key information is provided below.
Work permit application processing
In alignment with the government’s digital transformation initiatives, all applications must be processed through the Foreign Workers Central Management System at www.fwcms.mlvt.gov.kh.
Renewal of existing work permits
Foreign nationals currently holding a valid 2025 work permit are required to apply for a renewal (extension). The renewal process is currently open and will close on March 31, 2026.
New work permit applications
Foreign nationals who have recently entered Cambodia for employment or to engage in a self-employed occupation must apply for their initial work permit within 90 days of their arrival date.
Additional compliance requirements
We would also like to highlight that, pursuant to Instruction No. 110/23 dated December 28, 2023, the following individuals are also required to obtain a work permit, regardless of their physical presence in Cambodia:
- Foreign national employers if their name appears on a patent tax certificate
- Foreign national employees if their name appears on a patent tax certificate or who is a self-employed person
If you have questions or would like assistance with the above, please do not hesitate to contact us.
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.
On May 30, 2025, the Ministry of Labor and Vocational Training (“MLVT”) issued Notification No. 018/25 on the requirement for entities to submit their labor inspection self-declaration by June 30, 2025.
Effective immediately, all entities that fall within the purview of the Labor Law are required to submit their labor inspection self-declaration through the MLVT’s online system at https://sicms.mlvt.gov.kh. The self-declarations must be completed twice annually June 30 and December 31.
Failure to submit these declarations by the stipulated deadlines will result in the imposition of fines and direct enforcement action by the MLVT’s labor inspectors. Entities should be sure to fully comply with this requirement to avoid any penalties.
On April 25, 2025, the Ministry of Interior issued Notification No. 1373 on the full implementation of personal identity administrative services starting on May 1, 2025. These services are as follows:
- Verification of personal identity data through the Cambodian Data Exchange (“CamDX”) system.
- Personal identity attestation.
- Confirmation of the accuracy of personal identity data.
Administrative fees
Fees for these services will be implemented in accordance with the Ministry of Interior and the Ministry of Economy and Finance’s Inter-Ministerial Declaration No. 601 dated September 27, 2024 and Council of Ministers’ Letter No. 357 dated March 5, 2025.
Application to use services
To access these services, an application must be submitted through the CamDX system with the necessary technical information to connect to the system in accordance with the Ministry of Interior’s Prakas No. 3922 dated June 19, 2024.
Of particular note is that anyone that has been using these services before full implementation must resubmit their application to ensure compliance with the updated technical standards specified in Prakas No. 3922 to avoid a suspension of services.
Uses for the services
The identity-related services can be used for various purposes, including:
- School enrollment
- Employment applications
- Real estate registration
- Vehicle registration
- Bank account opening
- Business registration
- Contract signing
- Other administrative services, unless otherwise specified
On May 6, 2025, the Ministry of Labor and Vocational Training (“MLVT”) issued a notification further extending the deadline for renewing work permits and employment cards for foreign employees. Details are below.
- Extension of deadline: Due to delays in the submission of applications for the extension of work permits and employment cards for the year 2025, the MLVT has decided to extend the application period. The new deadline for submission is May 31, 2025.
- Online application: All applications for work permits and employment cards must be submitted through the official MLVT website at www.fwcms.mlvt.gov.kh before the stated deadline.
- Legal consequences for non-compliance: Failure to renew work permits and employment cards by the deadline will be considered in violation of Chapter 16 of the Labor Law and Joint Prakas No. 498 dated July 31, 2023, and subject to fines, imprisonment, or both.
