Andersen Global
Andersen Consulting

Sector: Corporate M&A

Cambodia Strengthens Legal Framework to Combat Online Scams

On April 6, 2026, the Royal Government of Cambodia promulgated a Royal Decree announcing the Law on Combating Online Scams. As digital technology becomes increasingly integrated into daily life, criminal activities have also evolved. Online scams conducted through social media, the banking system, and digital platforms pose serious risks to individuals, businesses, and national security. This law establishes a structured legal framework to address these risks.

Purpose and scope

The law aims to strengthen criminal measures against technology-enabled scams, safeguard the public, and promote both national and international cooperation. Its scope is broad. It applies not only to offenses committed in Cambodia but also to those involving Cambodian nationals abroad, as well as those committed against Cambodian victims, and crimes connected to Cambodia’s financial system. This ensures that offenders cannot evade liability by operating across borders.

The law describes various types of online scam offenses and their penalties, as described below.

Technology-enabled scams

The law defines technology-enabled scams as fraudulent acts carried out through technological systems to obtain funds, property, services, or legal obligations.

Offenders are subject to 2 to 5 years of imprisonment and fines ranging from KHR200 million to KHR500 million. Where the offense involves an organized group or multiple victims, penalties increase to 5 to 10 years of imprisonment and fines ranging from KHR500 million to KHR1 billion.

Organizing or leading scam centers

Anyone who organizes or leads a premises established as a technology-enabled scam center, whereby multiple persons operate individually or in groups or networks for the purpose of committing technology-enabled scams, is subject to 5 to 10 years of imprisonment and a fine ranging from KHR500 million to KHR1 billion.

The same penalties apply to anyone who organizes or leads multiple premises interconnected as a network for such purposes, even without a centralized structure.

Where the offense is committed with aggravating circumstances, including violence, unlawful detention, or any form of exploitation, the offender will be subject to 10 to 20 years of imprisonment and a fine of from KHR1 billion to KHR2 billion.

Where the offense results in the death of one or more persons, the offender will be subject to a sentence of 15 years to life imprisonment

Recruiting or training for scam activities

Anyone who recruits or trains others to participate in technology-enabled scams will be subject to 2 to 5 years of imprisonment and a fine ranging from KHR200 million to KHR500 million.

Where the offense involves aggravating circumstances such as violence, torture, cruelty, involving abduction, unlawful detention or restraint, causing death, or where the offender knowingly recruits victims of trafficking, the penalty increases to 5 to 10 years of imprisonment and a fine of from KHR500 million to KHR1 billion.

Misuse of personal identification documents

The unlawful collection or use of identity cards, passports, or other personal information documents for the purpose of facilitating online scams is punishable by 1 to 3 years of imprisonment and a fine ranging from KHR100 million to KHR300 million.

Where committed by an organized group, the penalty increases to 3 to 5 years of imprisonment and a fine of from KHR300 million to KHR500 million.

Money laundering related to online scams

Where a person cannot prove the lawful origin of assets linked to online scams, such conduct is treated as money laundering. Penalties apply in accordance with anti-money laundering laws, in addition to sanctions under this framework.

Additional penalties and liability

In addition to imprisonment and fines, the court may impose additional measures, including confiscation of assets, seizure of property used in the commission of offenses, and closure of bank accounts or online platforms involved in scams.

Legal entities may also be held criminally liable. Such entities will be subject to fines ranging from KHR1 billion to KHR30 billion or an amount equivalent to the value of the proceeds of the offense, along with additional sanctions.

The strong punitive measures, including significant financial penalties, ensures serious consequences for offenders, removing the financial incentives behind online scams to make enforcement more effective.

Final Reminder: Foreign Work Permit Compliance Deadline

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.

Clarification of Identity Documents for Public Works and Transport Services

On March 9, 2026, Cambodia’s Ministry of Interior and Ministry of Public Works and Transport issued Inter-Ministerial Circular No. 010 to clarify the documents that Cambodian citizens can use to verify their identity when requesting public services in the public works and transport sector. The circular aims to address the practical challenges citizens encounter when trying to access services at the local administrative level and to facilitate faster and more efficient access to public services through the Single Window Service Units.

Cambodian citizens requesting services in the public works and transport sector must attach one of the following identification documents when submitting an application:

  • A copy of their Cambodian national ID card certified by a competent authority
  • A copy of their Cambodian national ID card signed and thumbprinted by the applicant in the presence of the service officer, together with their original national ID card for verification
  • An original letter attesting to their personal identity or a letter confirming the accuracy of their personal identity data, both issued by the General Department of Identification

In addition to the identification documents listed above, applicants must continue to comply with other conditions and documentation requirements applicable to each specific public service, in accordance with the relevant laws and regulations in force.

Instruction Strengthens Regulations on Commercial and Industrial Gaming Centers

On February 9, 2026, the Commercial Gaming Management Commission of Cambodia (“CGMC”) issued Instruction No. 003/26 to strengthen compliance with the Law on Commercial Gaming Management, relevant regulations of the Royal Government, and licensing requirements governing commercial and industrial gaming centers. It applies to all owners and operators of licensed commercial and industrial gaming centers in the Kingdom of Cambodia.

The instruction emphasizes that all casino companies must strictly comply with the regulatory and operational requirements set forth in the Law on Commercial Gaming Management. In particular, commercial and industrial gaming centers are required to submit to the General Secretariat of the CGMC:

  • A comprehensive master plan of the casino premises; and
  • A detailed layout plan showing the precise location of all gaming equipment.

If needed, they must revise their casino premises layout to clearly identify:

  • Commercial gaming areas
  • Non-gaming business areas
  • The functional purpose of each building, floor, and room

The revised layout plan must be resubmitted to the General Secretariat of the CGMC for review and official approval before continued operation.

In addition, commercial and industrial gaming centers must ensure that their premises are not used for any unlawful activities, including but not limited to:

  • Technological fraud, cybercrime, or online scams
  • Kidnapping, torture, unlawful detention, or coercion
  • Human trafficking and all forms of sexual exploitation
  • Illegal arms trading, possession, storage, or use of weapons
  • Unlawful establishment of armed groups or misuse of private security personnel
  • Illegal trafficking, storage, or use of narcotics and psychotropic substances
  • Any other criminal activity in violation of applicable laws

Any equipment or facilities used for purposes unrelated to the licensed casino operations must immediately be dismantled and removed.

Any owner or operator found to be in violation of the instruction will be subject to having their license suspended or revoked and to legal action in accordance with the applicable laws and regulations.

New Sub-Decree Guides Implementation of the Law on Nationality

On December 1, 2025, the Royal Government of Cambodia issued Sub-Decree No. 225 to implement the Law on Nationality. The Sub-Decree provides procedures, conditions, and institutional mechanisms for the acquisition, voluntary renunciation, and revocation of Khmer nationality, addressing cases involving marriage, naturalization, investment, donation, and legal violations. An overview is provided below.

Acquisition of Khmer nationality through marriage

  • Foreigners legally married to Cambodian citizens may apply for Khmer nationality. Applications must be submitted in person to the General Department of Identification.
  • The marriage must be lawful and genuine, not entered into solely for the purpose of acquiring nationality.
  • Applicants must satisfy general legal and procedural requirements, including residency in Cambodia, good conduct, health standards, and compliance with Cambodian law.
  • Foreign-issued documents must be legalized prior to submission.

Applications involving minor children

  • Parents may apply together with minor children as a family unit.
  • If children were not included in the original application, parents may apply subsequently with proof of parentage and confirmation of the parents’ Khmer nationality.

Naturalization

Foreigners may acquire Khmer nationality through naturalization under three main categories:

  • General eligibility: Based on lawful residence, employment, or investment in Cambodia. Applicants must demonstrate stable residence, economic activity, good conduct, and compliance with the Law on Nationality.
  • Cash donation: For individuals who make a personal cash contribution of at least KHR12 billion to the national budget or humanitarian sector. The donation must have a legal source and be paid through the Ministry of Economy and Finance.
  • Special qualities or abilities: This category applies to individuals whose skills or contributions are officially recognized by the Royal Government of Cambodia. This recognition typically involves approval granted through a sub-decree or another formal legal instrument, in addition to general legal and conduct requirements.

Investment requirements

  • Foreign investors with a valid investment permit may apply if they have made a personal investment of at least KHR4 billion in priority sectors and approved projects.
  • Investments must have a lawful source and comply with obligations, including tax obligations.

Review, decision, and appeal

  • Applications are reviewed within 45 working days.
  • Applicants are notified to correct deficiencies within 30 working days.
  • Corrected applications are re-evaluated within 15 working days.
  • Approved applicants must take an oath before the Supreme Court.
  • Applications may be rejected for sham marriages, fraud, false documents, violations of Cambodian law, or failure to meet eligibility requirements.
  • Rejected applicants have the right to appeal through the courts within 30 working days of notification

Renunciation of Khmer nationality

  • Khmer citizens 18 years or older holding or acquiring another nationality may voluntarily renounce Khmer nationality.
  • Applications must be submitted to the General Department of Identification.
  • Parents may renounce on behalf of minor children to prevent statelessness.
  • Applications for renunciation of Khmer nationality will be examined within 30 working days.
  • If the application is incomplete or does not comply, the applicant will be notified in writing to correct the deficiencies within 30 working days.
  • Corrected applications will be re-examined and processed within 10 working days from the date of receipt of the corrected documents.

Revocation of Khmer nationality

Citizens by birth:

Khmer nationality by birth may be revoked if a citizen:

  • Commits treason or colludes with a foreign country against Cambodia’s interests.
  • Acts against national sovereignty, territorial integrity, or security.
  • Serves in a foreign military or public office and refuses to resign despite government orders.
  • Is convicted of crimes such as insulting the King, threatening state security, or terrorism.

Citizens by naturalization or claiming nationality

Khmer nationality acquired by naturalization or other nationality claim may be revoked if a citizen:

  • Commits treason, undermines sovereignty, or refuses to leave foreign military/public service.
  • Obtains nationality through fraud or false information.
  • Is convicted of crimes against the King, state security, or terrorism.

Reminder on the MLVT’s Requirements on Computerized Payroll Systems

On May 6, 2025, the Ministry of Labor and Vocational Training (“MLVT”) issued Prakas No. 111/25 requiring entities to declare their monthly payroll information through the online platform the Labor Sector Data Management System(“LACMS”).

This marks a significant step toward the digitalization of payroll management and strengthens compliance and transparency requirements for employers operating in Cambodia.

All payroll ledgers and computerized payroll books will now include a QR code generated from the LACMS. The QR code constitutes official legal confirmation of the accuracy and authenticity of the payroll information.

Where there are any changes, updates, or additions to payroll information, particularly where an employer uses a format different from the standard template prescribed by the MLVT, entities are required to update the payroll records through the LACMS.

Procedures for using computerized payroll records

To lawfully and properly use payroll records, entities must follow the steps below:

  • Select the payroll format: Choose either a computerized payroll book or a payroll ledger (computerized payroll list).
  • Customize payroll information: Where applicable, entities should select and/or complete additional payroll information to reflect their specific business activities, whether using a computerized payroll book or payroll ledger.
  • Download official payroll templates: Download the computerized payroll book and payroll ledger directly from the LACMS.
  • Sign, seal, and re-upload: After printing, the payroll must be signed and stamped with the official seal of the entity, then re-uploaded into the system to generate the QR code.
  • Submit on a timely basis: Payroll data must be entered into the LACMS no later than the 20th day of the following month.

Recordkeeping and inspection

Entities are required to retain payroll-related documents at their office premises to ensure they are readily available for inspection.

Specifically, they must:

  • Retain the payroll book for three years after it is fully used; or
  • Retain the monthly payroll ledger for at least threeyears.

Any person or entity that fails to comply with the Prakas’s requirements may be subject to fines or other penalties in accordance with the Labor Law.

Prakas No. 269 dated October 11, 2001 on the establishment of pay books, as well as any other regulations inconsistent with this Prakas, are hereby repealed and declared null and void.

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

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.

December 2025 Labor Inspection Self-Declaration Deadline Approaching

On November 25, 2025, the Ministry of Labor and Vocational Training (“MLVT”) issued a notification on the requirement for entities to submit their labor inspection self-declaration through its automated system, the Self-Inspection Compliance Management System (“SICMS”).

All entities that fall under the scope of the Labor Law must submit a labor inspection self-declaration twice per year by June 30 for the first half of the year and by December 31 for the second half of the year.

The self-declaration must be submitted via the official SICMS website at: https://sicms.mlvt.gov.kh.

Failure to conduct the labor inspection and submit the declarations by the prescribed deadlines will result in the imposition of fines and other enforcement measures by the MLVT’s labor inspectors, as per the applicable laws and regulations. Entities should ensure full compliance with this requirement to avoid any penalties.