Obligations of Banks and Financial Institutions in Providing Customer Account Information and Account Freezing/Unfreezing

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.

Business Registration Simplification Phase Two: Key Reforms Introduced by Prakas No. 044 and Notification No. 1755

On 26 May 2026, the Ministry of Commerce (“MOC“) issued Prakas No. 044 and Notification No. 1755 on the Business Registration Simplification Phase Two initiative. These regulations introduce several significant reforms and clarifications while further simplifying key business registration procedures.

The aim is to reduce administrative burden, improve the business registration environment, and support the implementation of initiatives introduced under Prakas No. 117 dated December 9, 2025.

Below are the main highlights of the Phase Two initiative:

1. Shift to digitalized business registration:

  • The submission of hard copies of articles of incorporation (“AOI”) and other relevant company documents in connection with business registration or corporate updates is no longer required. In place of the traditional physical official stamp on the AOI, document verification is now conducted through the government online platform, verify.gov.kh, which is used to authenticate and validate the legal validity of the documents.
  • The registration of a local branch is now fully integrated into the online business registration portal. In addition, any changes to the branch manager no longer require notification to the MOC.

2. Business objectives requiring prior approval:

  • Companies may freely select their business objectives, except where the proposed business activities fall within regulated sectors that require a prior approval-in-principle from the relevant competent authority before registration can be completed with the MOC. Pursuant to Annex 1 of Prakas No. 044, the main regulated sectors are:
    • Banking
    • Telecommunications
    • Tourism
    • Casinos and gambling
    • Non-bank financial services and activities
    • Mining

3. Reduced requirements for the company secretary:

  • The requirement for a professional company secretary licensed with the MOC to maintain a security deposit has been removed.
  • Any individual may be appointed as a company secretary, except where otherwise restricted by specific statutory provisions.
  • The filing and updating of company secretary information must now be done through the MOC online system and is free of charge.

4. Migration of the MOC’s new online system and enhanced business services support

  • To improve user support and further enhance the efficiency, security, and stability of the business registration online system, the MOC has officially migrated to a new platform at www.businessregistration.moc.gov.kh.
  • All future corporate updates, amendments, and filings of the Annual Declaration of Commercial Enterprise (“ADCE”) must now be conducted exclusively through this new platform. To access the system, users are required to use their existing username and registered email address to reset their password.
  • Due to the migration of the MOC business registration online system and the change in the ADCE filing timeline in accordance with Prakas No. 117, a dedicated working group has been established to provide free-of-charge assistance to private-sector users in relation to:
    • ADCE filings
    • Account recovery requests
    • Updates to company information
    • Other issues with the online business registration portal

Users can access this assistance by contacting the MOC hotline at 1266 and pressing 2 or by visiting the MOC during working hours.

5. Abrogation of the dispute resolution mechanism

Chapter 10 of Prakas No. 117, which established a formal complaint mechanism for any shareholder to challenge unauthorized corporate changes that could result in significant losses or prejudice to their rights and interests, has been formally repealed.

These reforms reflect Cambodia’s ongoing commitment to modernizing its regulatory framework and fostering a more attractive investment environment. By simplifying administrative procedures, enhancing regulatory efficiency, and expanding digital public services, the government seeks to facilitate business operations and encourage both domestic and foreign investment.

Phnom Penh Capital Hall Launches Online Administrative Services

On May 25, 2026, Phnom Penh Capital Hall issued Notification No. 019/26 officially announcing the implementation of an online administrative service system through the Single Window Service Office, marking another important step in Cambodia’s digital transformation and public service modernization.

The initiative aims to improve the efficiency of public service delivery by eliminating the need for travel, and reducing the administrative burden and related costs for citizens seeking administrative services at Phnom Penh Capital Hall.

Types of services available

Under the new system, citizens can now submit applications to access nine categories of online administrative services, as follows:

  • Legalization Services (certification of document copies)
  • Administrative Services
  • Tourism Sector
  • Public Works and Transport Sector
  • Culture and Fine Arts Sector
  • Industry, Science, Technology, and Innovation Sector
  • Mines and Energy Sector
  • Land Management, Urban Planning, Construction, and Cadaster Sector
  • Agriculture, Forestry, and Fisheries Sector

Application and service fees

The official service fees for applications through the online administrative service system will be the same as those for in-person applications at Phnom Penh Capital Hall. No additional charges or online processing fees will be imposed. In addition to the online system, administrative services can still be accessed in person at the Single Window Service Office.

The online administrative service system can be accessed through the official website at: https://online.owso.gov.kh/

Applicants are required to create an account and upload relevant supporting documents in accordance with the instructions provided for each service application.

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.

The Ministry of Interior Launches its Online Complaint Submission System

On February 19, 2026, the Ministry of Interior of Cambodia issued Notification No. 686 announcing the official launch of an online complaint submission system. It will facilitate the efficient submission and resolution of complaints and denunciations from citizens concerning the competence and conduct of civil servants under the ministry. It also aims to support investigation processes and promote fairness and accountability. An overview is provided below.

  • The system officially commenced operation on February 19, 2026, allowing the public to begin submitting complaints through the online platform.
  • It is accessible via website: https://css-gdin.interior.gov.kh/home.
  • Users may submit complaints by completing the electronic form available in the system. Alternatively, they can download a complaint form, complete it manually, and contact the telephone number provided in the system to submit their complaint.

This initiative reflects the ministry’s effort to improve accessibility, transparency, and efficiency in handling public complaints and strengthen accountability.

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.

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.

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.