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.

Visa Exemption Pilot Program for Chinese Tourists Coming in 2026

On December 3, 2025, the Ministry of Tourism issued Notification No. 334 to announce the implementation of a visa exemption pilot scheme for Chinese nationals traveling from the People’s Republic of China aimed at increasing Chinese tourist arrivals to Cambodia.

Under the pilot scheme, Chinese tourists will be exempt from visa requirements for distinct stays of up to 14 days each during the four-month period from June 15 to October 15, 2026, with multiple entries allowed. During the pilot period, eligible travelers will not be required to submit a visa application or pay any visa-related fees; they will only need to complete an E-arrival card.

Notice on the Issuance of Border Crossing Vessel Permits

On October 7, 2025, the Ministry of Public Works and Transport (“MPWT”) issued Notification No. 065 to inform all shipping companies, shipowners, and operators of cross-border transport vessels that the Vietnamese authorities have strengthened the enforcement of laws governing cross-border transport operations.

Accordingly, all vessels engaged in commercial transport activities, including the carriage of goods or passengers from Cambodia to Vietnam are now required to obtain a border crossing vessel permit.

Thus, shipping companies operating cross-border transport should ensure that all vessels possess valid permits to avoid potential delays, penalties, or denial of entry.

Permit application requirements

Applications for border crossing vessel permits must submitted to the MWPT’s Waterway Transport Department of the General Department of Waterway, Sea and Port Transport.

The following documents must be attached with the application form:

  • Valid shipowner identification card
  • Ship-related document, such as a ship identification card or a domestic waterway vessel registration certificate
  • Vessel technical inspection certificate
  • Waterway transport business certificate
  • Insurance policy or relevant insurance certificate
  • Letter of criminal record
  • Business registration certificate
  • Company’s articles of incorporation:

Validity period

Border crossing vessel permits are valid for one year from the date of issuance.

Cambodia Minimum Wage for Workers for 2026

On September 17, 2025, Ministry of Labor and Vocational Training issued Prakas No. 214/25 on the minimum wage for workers in 2026. Starting January 1, 2026, the minimum monthly wage for workers in the textile, garment, footwear, travel goods, and bag industries will increase by US$2, raising the minimum wage from US$208 to US$210 per month.

Probationary workers will receive a minimum wage of US$208 per month during their probation period. After probation, their wage will increase to US$210 per month.

For workers receiving piece-rate pay (i.e. based on their production output), wages will be calculated according to the actual quantity produced. If their earnings fall below the set minimum wage during the probation period or subsequently, employers must top up their pay to meet the minimum wage thresholds.

All other benefits workers currently receive will remain unchanged.

Any previous regulations that conflict with this new minimum wage will be considered null and void.

Cambodia Sets Official 2026 Public Holiday Schedule

On September 18, 2025, the Royal Government of Cambodia issued Sub-Decree No. 167, officially establishing the public holiday calendar for 2026. In total, civil servants, employees, and workers across Cambodia will be entitled to 22 days of paid public holidays in 2026, covering a mix of national days, traditional days, and religious observances, as shown in the table below.

Date  OccasionNo. of Days
January 1New Year’s Day1 day
January 7Victory Over the Genocide Day1 day
March 8International Women’s Day1 day
April 14, 15, 16Khmer New Year3 days
May 1International Labor Day & Visakha Bucha Day1 day
May 5Royal Ploughing Ceremony1 day
May 14Royal Birthday of His Majesty Preah Bat Samdech Preah Baromneath Norodom Sihamoni1 day
June 18Her Majesty Queen Mother Norodom Monineath Sihanouk’s Birthday1 day
September 24Constitution Day1 day
October 10, 11, 12Royal Pchum Ben Festival 3 days
October 15Commemoration Day of King Father Norodom Sihanouk1 day
October 29Coronation Day of His Majesty King Norodom Sihamoni 1 day
November 9Cambodia’s Independence Day1 day
November 23, 24, 25Cambodian Water Festival (Bon Om Touk)3 days
December 29Peace Day1 day

This Sub-Decree applies to all workers covered under the Cambodian Labor Law. Employers are advised to review the 2026 holiday calendar carefully to ensure full compliance with the labor regulations.

Entities whose operations are continuous and global in nature, and where shutting down entirely during public holidays would either be detrimental to the public interest or significantly disrupt business operations, may implement rotational leave schedules, allowing workers to take public holidays in turns. If even rotational leave is impractical, employers and worker representatives may mutually agree to have employees work on a public holiday in exchange for alternative leave at another time.

Such agreements may be guided by company rules, collective agreements, or direct agreements between employers and workers.

Employers must keep records of these arrangements for labor inspection. Temporary staff can be hired to cover workers on leave during this time.