Prakas on the Issuance of Licence and Management of Digital Asset Business

Introduction

In view of the growing circulation and use of cryptocurrencies in Cambodia, on 30 December 2025, the Non-Bank Financial Services Authority of Cambodia (“NBFSA“) issued Prakas No. 093 on the Issuance of Licence and the Management of Digital Asset Business (“Prakas“). The Prakas sets out the conditions and procedures for the issuance and renewal of licences for Digital Asset Service Providers, Digital Asset Agents, and other relevant persons operating in Cambodia.

This Prakas was adopted as part of the Royal Government of Cambodia’s broader efforts to establish a comprehensive legal and regulatory framework to support financial sector development and digital transformation, as articulated in the Cambodian Financial Technology Development Policy 2023–2028 (“Policy“).

In this Update, we will highlight some of the key features of the Prakas.

A) Scope and Key Terms

The Prakas applies to all activities related to digital asset businesses conducted for investment purposes, excluding the use of digital assets or virtual assets as a means of payment in Cambodia.

The Prakas provides for specific definitions of certain key terms including, amongst others, the following:           

1. Digital Asset has the same meaning as under the Policy, which refers to “valuable digit units created on distributed ledger technology or similar technology or associated with a smart contract or contract in various forms between digital asset holders and counterparts and can be traded or transferred, including Bitcoin. These assets are financial instruments and are type of securities”.
2. Digital Asset Service Provider (“DASP“) refers to a company licensed by the Securities Exchange Regulator of Cambodia (“SERC“) to conduct permitted digital asset business activities under the Prakas.
3. Digital Asset Agent (“DAA“) refers to an individual working for a DASP who is licensed by SERC to carry out permitted activities under the Prakas.

B) Digital Asset Business 

1. Permitted Businesses for DASPs: Under the Prakas, DASPs are permitted to conduct one or more of the following business activities:

• • Digital asset trading business: for the provision of services related to (i) digital asset intermediation; (ii) digital asset commissioning; (iii) digital asset trading platforms and digital asset derivate instruments; (iv) digital asset person-to-person trading; (v) digital asset investment advisory; and (vi) creation, direct sale, and marketing and dissemination of digital assets;
  • Digital asset wallet business: for the provision of services related to the protection, deposit, withdrawal, and transfer of digital assets from one wallet, address, or storage location to another, for the customers;
  • Digital asset borrowing and lending business: for the provision of services related to digital asset loans from a lender to a borrower, wherein the borrower is required to return the same digital asset to the lender based on the request of the lender at any time during or at the expiry of an agreed-upon period in accordance with the relevant agreement on digital asset borrowing and lending;
  • Digital asset management business: for the management and disposal of digital asset investment on behalf of the customers; and/or
  • Other related digital asset businesses or activities determined by SERC.

2. Permitted Activities for DAAs: Further, DAAs licensed by SERC are permitted to conduct the following activities:

• • Opening and managing accounts for digital asset transactions;
  • Executing permitted forms and documents on behalf of a DASP;
  • Providing advice on the creation and distribution of digital assets;
  • Providing investment advice to customers in relation to digital assets; and
  • Performing such other functions on behalf of and as authorised by a DASP.

C) Conditions and Obligations of DASPs and DAAs 

1. Conditions of DASPs and DAAs

No person may act as, or hold themselves out as a DASP unless such person has obtained a valid and active DASP Licence from SERC.

The DASP Licence is valid for a period of two years and is subject to renewal. Upon renewal, the licence shall be valid for a period of three years, provided that the renewal application is submitted at least 60 days prior to the expiry date of the existing licence.

Similar to the DASP Licence, the DAA Licence is valid for a period of two years, and upon renewal, for a period of three years. However, renewal applications must be submitted at least 30 days prior to the expiry of the existing licence.             

To obtain a DASP Licence, DASP applicants are required to, including among others:

• Have duly completed commercial and tax registration in Cambodia;
• Have successfully tested its IT system, business model, products, or services related to digital assets in the securities’ regulatory sandbox environment;
• Meet the minimum capital as provided under the Prakas;
• Have proper corporate governance structures approved by SERC;
• Establish internal principles and policies; and
• Abide by other conditions specified under the Prakas.

DAA applicants are required, among others, to:

• Either (i) hold a higher education degree in securities, finance, economics, business, or accounting; or (ii) have at least one year working experience in the securities, finance, or digital asset sector; and
• Have completed the required training and examination and have been duly authorised by SERC to perform the permitted activities.

Detailed conditions required of DASPs and DAAs are outlined in Chapter 3 and Chapter 4 of the Prakas respectively.

2. Obligations of DASPs

Chapter 5 of the Prakas outlines key obligations of DASPs including, among others:

• Obligation to obtain prior approval from SERC;
• Obligation to submit to SERC;
• Obligation to notify to SERC; and
• Other obligations.           

D) Penalties

In the event of non-compliance, SERC has the authority to impose administrative penalties including but not limited to:

• Issuance of guidance and written warning;
• Public notice and corrective order;
• Restriction on, suspension, or revocation of licences and qualifications;
• Other administrative penalties determined by SERC and in accordance with applicable laws.

If you have any queries on the above, please feel free to contact our team members set out on this page who will be happy to assist.