Regional Round-Up: Cambodia Q2 2025

Instruction on the Building of Telecoms Infrastructure in Designated Areas or Constructions

On 16 June 2025, the Ministry of Land Management, Urban Planning and Construction issued Instruction No. 001 on the Building of Telecommunications Infrastructure in Towns, Residential Areas, Borey, Co-Owned Buildings, Commercial Buildings, Shopping Malls, Industrial Areas, Special Economic Zones, and Other Designated Areas or Constructions (“Instruction No. 001“). In line with the 2015 Telecommunications Law and 2019 Construction Law, Instruction No. 001 aims to advise (i) construction owners;​ (ii) developers of boreys; and (iii) investors of industrial areas, special economic zones, tourism resorts, or other designated areas, to ensure that telecommunications infrastructure therein is efficient, modern, safe, environmentally friendly, and capable of supporting socio-economic development and high-quality public services. 

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Sub-Decree on the Amendment to the Negative List of Investment Activities

The Royal Government of Cambodia adopted Sub-Decree No. 139 on the Implementation of Law on Investment (“Sub-Decree No. 139“) on 26 June 2023, aiming to implement the Law on Investment, which was promulgated on 15 October 2021. Sub-Decree No. 139 covers investment projects registration, obligations, incentives, after-care services, and acquisition/sale or merger/nullification of the projects, with ten annexes including a negative list of ineligible activities (“Negative List“).

On 6 June 2025, Sub-Decree No. 86 was issued, amending the Negative List to include the manufacturing and/or assembly or installation of electronic cigarettes and other similar devices. The inclusion means that the manufacturing, assembly, or installation of electronic cigarettes and similar products in Cambodia cannot be registered as a qualified investment project with the Council for the Development of Cambodia. Hence, these activities will not be eligible for the investment incentives provided under the Law on Investment.

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Prakas on the Issuance of Infrastructure Bonds

On 30 May 2025, the Non-Bank Financial Services Authority issued Prakas No. 046 on the Issuance of Infrastructure Bonds (“Prakas No. 046“). Prakas No. 046 sets out the conditions and procedure for the issuance of infrastructure bonds, as well as further obligations following the issuance, with the aim of ensuring effectiveness, accountability, and transparency. Prakas No. 046 applies to the (i) public issuance of infrastructure bonds; (ii) private issuance of infrastructure bonds; and (iii) issuance of infrastructure bonds for qualified investors and relevant stakeholders in the Kingdom of Cambodia.

The key requirements and features specified in Prakas No. 046 include (i) the types of infrastructure bonds that may be issued by public limited companies or other permitted entities; (ii) issuance requirements; (iii) post issuance requirements; (iv) the conditions and documents required for the Securities and Exchange Regulator of Cambodia’s review and approval; and (v) penalties and sanctions in cases of non-compliance.

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Circular on the Implementation of Procedures for the Registration of Private Units within Co-Owned Buildings

On 22 May 2025, the Ministry of Land Management, Urban Planning and Construction (“MLMUPC“) issued Circular No. 001 on the Implementation of Procedures for the Registration of Private Units within Co-Owned Buildings Constructed Prior to 1979 and to 19 December 1997 (“Circular No. 001“). Circular No. 001 serves as a supplement to Prakas No. 050, dated 19 July 2024, and is intended to safeguard the legal ownership rights of private unit owners in such buildings, while also streamlining the associated formalities and administrative processes for MLMUPC officials.

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Prakas on the Classification of Development Projects for Environmental Impact Assessment

On 6 May 2025, the Ministry of Environment issued Prakas No. 3591.0525 on the Classification of Development Projects for Environmental Impact Assessment (“Prakas No. 3591“). Prakas No. 3591 nullifies Prakas No. 021 on the classification of environmental impact assessments (“EIAs“) for development projects dated 3 February 2020, and redefines the classification of EIAs for development projects. Prakas No. 3591 aims to facilitate and guide project owners in effectively implementing EIA procedures in Cambodia.

Prakas No. 3591 applies to all requested development projects, existing and ongoing activities of private individuals, private companies, state joint ventures or state-owned enterprises (SOE), and ministries or governmental institutions, as listed in its annex. The types of projects enumerated in the annex pertain to the mining, energy, industry, healthcare, water resources, agriculture, tourism, and infrastructure sectors.

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Please note that whilst the information in this Update 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 a substitute for specific professional advice

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