TBC
TBC
CDC Guideline on Investment Capital Implementation for Manufacturing QIPs
On 27 August 2026, the Council for the Development of Cambodia (“CDC“) issued Guideline No. 1555/26 CIB on the Actual Implementation of Investment Capital in an Amount Equal to or Exceeding the Minimum Capital for Qualified Investment Projects in the Manufacturing Sector (“Guideline“). The Guideline is intended to strengthen compliance by manufacturing qualified investment projects (“QIPs“) with the Law on Investment and related regulations.
Key features of the Guideline
- Requirement to Implement Actual Investment Capital
All Manufacturing QIPs are required to implement their actual investment capital within a maximum period of three years, in an amount equal to or exceeding the minimum capital prescribed in the Negative List under the Law on Investment.
It is noted that “Investment Capital” refers to the investment value that is indicated in a local currency or foreign currency, and which does not include land value and working capital.
- Implementation Timelines
The applicable timelines to implement the actual investment capital depends on the date on which the QIP is registered with CDC, as follows:
- QIPs registered before the issuance of the Guideline: within three years from the date of issuance of the Guideline.
- QIPs registered after the issuance of the Guideline: within three years from the date of registration.
- Consequences of Non-compliance
Based on the Guideline, failure to satisfy the above investment capital implementation requirement may result in CDC taking enforcement measures, include the potential withdrawal of investment incentives previously granted.
For more information, click here to read our Legal Update.
NBC Circular Clarifies Banks' and Financial Institutions' Obligations to Provide Customer Account Information and Freeze, Unfreeze or Hold Customer Accounts
On 10 August 2026, the National Bank of Cambodia (“NBC“) issued Circular No. B37.026.006 on the Obligation of Banks and Financial Institutions to Provide Customer Account Information and to Freeze, Unfreeze, or Hold Customer Accounts (“Circular“). The Circular provides guidance to banks and financial institutions (“BFIs“) on cooperating in the implementation of court orders and lawful requests issued by competent authorities.
Under Article 47 of the Law on Banking and Financial Institutions, BFIs and their officials must preserve the confidentiality of information obtained in the course of their activities. This obligation does not apply where disclosure is required by a supervisory authority, auditor, provisional administrator, liquidator, or a court handling criminal proceeding.
In this regard, the Circular clarifies and guides BFIs on the operation of such disclosure as follows:
- Cooperation and implementation of lawful orders and requests: Upon receipt of a lawful order or request from a court or competent authority, the relevant BFI shall act upon and implement the order or request directly, without first seeking confirmation or clarification from NBC.
- No interpretative role for NBC: NBC does not have the authority to interpret or provide additional clarification regarding an order or request issued by another competent authority.
- Record-keeping and submission to NBC: A BFI is required to maintain records relating to the relevant order or request, as well as records of the information provided to the court or competent authority pursuant to such order or request. Such records must be made available to NBC upon request.
For more information, click here to read our Legal Update.
Notification Obligation on Business Owners Issuing E-money for Payment
On 6 August 2026, the National Bank of Cambodia (“NBC“) issued Notification No. B14-026-1075 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 (called “Single-Purpose E-Money”).
Under Article 2 of the Law on Banking and Financial Institutions and Article 20(1) of the Prakas on the Management on Payment Service Institutions (“Prakas“), 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.
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 requirements set out in the Notification.
The Notification reminds all concerned business owners to comply with the prescribed 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.
For more information, click here to read our Legal Update.
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
