Notification Obligation on Business Owners Issuing E-money for Payment

Introduction

On 6 August 2026, the National Bank of Cambodia (“NBC“) issued Notification No. B14-026-1075 SCN on the Notification Obligation on Business Owners Issuing E-money for Payment of Goods or Services within a Single Network (“Notification“).

NBC has observed that business owners – including owners of coffee shops, restaurants, transportation companies, entertainment centres, gas stations and other businesses – have been issuing e-money through mobile application-based e-wallets or membership cards. In such instances, customers are required to create an e-wallet account and top up funds to pay for the goods or services offered by such businesses (“Single-Purpose E-Money“).

Under Cambodian law, the provision of payment services to customers, including the issuance of e-money, is considered a banking or financial service and may only be carried out by licensed banking and financial institutions or payment service institutions (Article 2 of the Law on Banking and Financial Institutions dated 19 November 1999, and Article 20(1) of the Prakas on the Management on Payment Service Institutions (“Prakas“)).

However, to support micro, small and medium enterprises and promote innovation, Article 20(2) of the Prakas permits business owners to issue e-money without obtaining a licence, provided that they submit prior written notification to NBC and comply with the following requirements: 

  1. The maximum of each balance shall not exceed KHR200,000 or equivalent;
  2. The aggregate balance shall not exceed KHR800,000 or equivalent;
  3. The e-money may only be used to pay for goods or services provided by a single natural person; and
  4. Other conditions as determined by NBC.

The Notification reminds all concerned business owners to comply with the above requirements by submitting written notification to NBC within 90 days from the date of the Notification. Non-compliance may result in regulatory measures. Members of the public are also advised to exercise caution and use such e-wallet accounts responsibly and at their own risk, as they are not intended to hold substantial balances or to serve savings or interest-bearing purposes.

If you have any queries on the above, please reach out to our team set out on this page.

For regional Banking & Finance matters, please see Rajah & Tann Asia’s Regional Banking & Finance Practice for more information.


 

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Please note also that whilst the information in this publication is correct to the best of our knowledge and belief at the time of writing, it is only intended to provide a general guide to the subject matter and should not be treated as legal advice or a substitute for specific professional advice for any particular course of action as such information may not suit your specific business and operational requirements. You should seek legal advice for your specific situation. In addition, the information in this publication does not create any relationship, whether legally binding or otherwise. Rajah & Tann Asia and its member firms do not accept, and fully disclaim, responsibility for any loss or damage which may result from accessing or relying on the information in this publication.

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