Introduction
Following the issuance of Prakas No. 117 MOC.BRD.PrK on the Simplification of Commercial Registration on 9 December 2025 (“Prakas“), the Ministry of Commerce of the Kingdom of Cambodia (“MOC“) issued a Press Release No. 0657 MOC.BRD dated 25 February 2026 to provide updates regarding the enforcement of the Prakas and to clarify the uncertainty of key provisions.
Key Points
This Update highlights the key points outlined in the Press Release.
- Annual Declaration of Commercial Enterprise (“ADCE”)
More than 200 companies have submitted the application requesting a waiver of penalty for their failure to file the ADCE for the past years, by participating in a shareholder background check. Upon conducting the background check, it has been found that nine shareholders are on MOC’s alert list. As a result, MOC has requested for the identified shareholders to be removed from the Commercial Registry.
- Company Secretary
The implementation of the requirement to appoint a company secretary has been postponed to January 2027. MOC emphasises that the requirement of the appointment of a company secretary is only applicable to limited companies and does not extend to (i) sole proprietorships; (ii) startups; (iii) informal economy groups; and (iv) small and medium enterprises.
MOC further clarifies that the company secretary qualifications set out in the Prakas only apply to those persons who intend to provide professional services as the company secretary, while each limited company still has the right to appoint its own company secretary, who does not need to fulfil those qualifications.
- Standard Operating Procedures (“SOP”)
MOC is preparing a SOP as a complementary document to supplement the above Prakas.
If you have any queries on the above, please feel free to contact our team members, who will be happy to assist.
Disclaimer
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