Corporate M&A - Andersen in Cambodia

0% Customs Duty on Certain Goods Imported from the USA

On August 8, 2025, the Ministry of Economy and Financeissued Prakas No. 632 establishing a 0% customs duty on eligible goods imported into Cambodia from the United States of America. On the same date, the General Department of Customs and Excise (“GDCE”) issued Prakas No. 3724/25 on the Customs Formality Procedures for Goods Originating from the United States of America and Imported from the United States of America. Taken together, these two related Prakas establish the legal basis and customs procedures for applying a 0% customs duty rate on qualifying US-origin goods. Any existing regulations or provisions that contradict these Prakas are considered null and void.

Key Provisions

0% customs duty rate: A customs duty rate of 0% will apply to eligible goods originating from the US and directly consigned to Cambodia.
Eligibility requirements: To be eligible for the 0% customs duty, the goods must originate from the US and be shipped directly to Cambodia without transshipment. This exemption does not apply to used goods, which are explicitly excluded from the scope of the Prakas. The specific criteria for identifying used goods will be determined and clarified by the GDCE.
Proof of origin: Importers must submit appropriate proof of origin using the forms and procedures prescribed by the GDCE to benefit from the 0% customs duty rate.
Effective date: The 0% customs duty rate applies to goods that are loaded onto the means of transport in the US on or after August 8, 2025.

GDCE Procedural Requirements and Eligibility Conditions

The GDCE has outlined specific procedural requirements and eligibility conditions, especially for motor vehicles.

Eligible vehicle criteria

Cars must meet the following conditions to be eligible for the 0% customs duty rate:

Be manufactured in the US;
Be vehicles with a model year of: one year before the current year; the current year; or one year after the current year;
Have less than 5,000 kilometers on the odometer; and
Be in good condition, with no signs of collision, damage, or alteration.

Motorcycles, tricycles, and ATVs must meet the following conditions to be eligible for the 0% customs duty rate:

Be manufactured in the US;
Be vehicles with a model year of: one year before the current year; the current year; or one year after the current year;
Have less than 2,000 kilometers on the odometer; and
Be in original, undamaged condition.

Customs formalities to access the 0% customs duty rate

Importers or representatives must submit a declaration of origin using Form US, via the CVDS electronic system at https://value.customs.gov.kh/CV/Login2.aspx?ReturnUrl=%2fCV%2f.
Supporting documents or evidence of US origin must be available for verification upon request.
Customs verification and approval will follow existing free trade agreement procedures.
Declarants must complete the following in the customs declaration (single administrative document or “SAD”) in ASYCUDA:
- Enter code “KHUSPT” (KH and US preferential tariff) in Box 36 (Preference) of the SAD.
- Enter the number and date of the approved declaration of origin by using “862” as the document name code when lodging the SAD.
Customs officers and declarants can review and verify documents directly through the ASYCUDA system.

Cambodia Reiterates Requirements for Legal Casino Gambling Operations

On July 5, 2025, the Commercial Gambling Management Commission (“CGMC”) issued a notification to emphasize that legal commercial gambling operations in Cambodia are strictly regulated under national law and summarize the key provisions.

Legal Framework

Under Article 35 of the Law on Commercial Gambling Management, only legal entities holding a valid license may conduct commercial gambling. Additionally, no individual may represent a licensee or operator unless duly authorized under such law.
Article 74 of the Law on the Control of Commercial Gaming further mandates that a commercial gaming operator may only conduct games if:
The type of game has received prior approval from the CGMC, and the approval remains valid;
The game is conducted according to the approved gaming rules; and
The game is operated by personnel holding a special license issued by the CGMC.

Mandatory Compliance for Legal Operation

To operate casino games in full compliance with Cambodian law, entities must:

Hold a valid casino license issued by the CGMC and operate only at the location specified in that license.
Possess a registration certificate covering the type of game, gaming rules.
Use gaming equipment and/or software that is registered and approved by the CGMC, identified by a CGMC sticker affixed to the equipment.

Noncompliance with any of these legal requirements may result in enforcement action, penalties, or revocation of operating rights.

Say Goodbye to That Stamp in Your Passport: Cambodia Introduces a Digital Pass for Foreign Visitors

On July 1, 2025, Cambodia officially introduced the visitor pass (known as “v-Pass”) system, a digital immigration authorization system that replaces physical passport stamps and QR code stickers for foreign travelers entering and exiting the country. This initiative is part of the Cambodian government’s broader commitment to advancing its digital economy, and aims to modernize border control and enhance the efficiency of immigration procedures.

The v-Pass system is now mandatory at all international points of entry, including airports and seaports across Cambodia. Upon arrival, foreign nationals will no longer receive an inked stamp in their passports. Instead, immigration officers will process entries electronically and issue a digital visitor pass directly to travelers via email. This digital pass can also be accessed through the official Cambodia e-Arrival website (https://arrival.gov.kh/) or the Cambodia e-Arrival mobile application, available on Google Play, the Apple App Store, and the Huawei App Gallery.

The procedure is as follows:

Upon entry: Travelers present their passports to the immigration officials, who electronically record the entry and issue a digital v-Pass via email. Travelers should keep this digital pass accessible during their stay.
During their stay: The v-Pass may be requested for verification and can be shown on a mobile device or printed out. Travelers must comply with the authorized duration of stay indicated on their v-Pass.
Upon departure: Travelers present their passport at the departure immigration, where their exit is electronically recorded. No physical exit stamp is required.

Online Labor Inspection Self Declaration Deadline Set for June 30, 2025

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.

New Regulations on Exports to the United States

In response to recent tariff threats from the United States and to provide further clarification on provisions in Cambodia’s Law on the Rules of Origin (2023), the Cambodian government has issued two Prakas aimed at tightening enforcement of the rules governing the export of goods to the US. The first Prakas addresses obtaining an Origin Certification Letter (“OCL”) to export certain goods to the US, while the second Prakas addresses anti-fraud measures. Both Prakas entered into effect on May 12, 2025 and existing regulations that do not conflict with their provisions remain in force.

Procedures for Obtaining an Origin Certification Letter

On April 30, 2025, the Ministry of Commerce (“MOC”) issued Prakas No. 047 on the Procedures for Applying for and Issuing Origin Certification Letters for the Export of Certain Goods to the United States (“Prakas 047”). It complements existing legal documents related to the prevention of origin fraud, ensuring compliance with Cambodia’s and the US’s rules of origin by strengthening verification procedures.

Mandatory registration

Exporters and producers must register with the MOC’s online CO Automation System at https://co.moc.gov.kh before applying for an OCL. Required uploads (in PDF) include:

Certificate of Incorporation
GSP/MFN Certificate
Letter of authorization for the representative from the company owner or registered manager
ID/passport and a 4×6 cm photo of the authorized representative or designated recipient

On-site inspection for the first OCL

Initial certification requires an inspection by MOC officials to verify compliance. The detailed steps for this process are outlined in Prakas 047’s Standard Operating Procedures (Annex II), which include:

Procedures for initial and subsequent OCL issuance, which involves giving authority to the MOC officials to do the following:
Inspect business premises, warehouses, and manufacturing sites
Examine export documents such as purchase orders, invoices, and cost breakdowns
Inspect aspects of the manufacturing process including raw materials, workforce, machinery, production capacity, and labeling
Verify production records
Documentation responsibilities of producers/exporters
Mechanisms for inter-ministerial data sharing and verification
Risk or complaint-based inspection and enforcement measures
Cooperation mechanisms with competent US authorities

After inspection, the MOC officials will issue an initial inspection report, which is required for the initial and all future OCL applications.

Required documents for the OCL application

After registration and inspection, applicants must submit the following through the CO Automation System:

Invoice and packing list
Cost breakdown or reference documents required by the rules of origin
Initial MOC inspection report

Issuing authority and fees

The General Directorate of Trade Support Services issues the OCL. There is no public service fee for the application. A sample OCL is provided in Annex III of the Prakas.

Anti-Fraud Measures

The MOC and the Ministry of Economy and Finance’s Joint Prakas No. 379 on Measures to Prevent Fraud on the Origin of Certain Goods Exported to the United States was also issued on April 30, 2025. It applies to all Cambodian producers and exporters shipping certain goods to the United States (the list of applicable goods is included in Annex I of Prakas 047).

Certification requirements

Exporters must obtain an OCL from the MOC in accordance with Prakas 047.
The OCL must be attached when submitting the customs declaration for exports claiming Cambodian origin.

Verification and investigation

If there are questions as to origin or at the request of the US authorities, the General Directorate of Trade Support Services and the General Department of Customs, with support from relevant institutions, will jointly investigate the origin of the goods.

Penalties for non-compliance

Any producer or exporter found committing fraud with regard to the origin of goods, including concealing transshipment operations, will face penalties under the Law on Rules of Origin and the Law on Customs, such as a fine ranging from KHR10 million to KHR40 million, and imprisonment of one to five years.

The Ministry of Interior Announces Full Implementation of its Personal Identity Data Services

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

Further Extension of the Application Period for Work Permit and Employment Card Renewal

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.

Ministry of Commerce Announces New Template for Articles of Incorporation

On April 10, 2025, the Ministry of Commerce announced the adoption of a new template for entities’ articles of incorporation (“AOI”), which now includes an Appendix 1.

Under this update, Appendix 1 consolidates all essential corporate information, such as:

Entity name
Organizational structure
Business objectives
Registered address
Registered capital
Par value of shares
Shareholder information
Director information

One of the benefits of this new template is that when an entity has changes to its corporate information that it needs to register with the Ministry of Commerce, it will only need to update Appendix 1 of its AOI.

Our understanding is that new entities will need to begin using the new template for their AOI; entities currently operating under the old AOI format can continue to do so, and change to the new template the next time they have to update their AOI. We will provide updates on this if there are any further requirements for currently operating entities.