Statutory Audit Requirements and Obligations in Cambodia: Everything You Need to Know 

Auditing

Audit Obligations

Under the Law on Accounting and Auditing (amended 2021) and Prakas No. 563 MEF.Prk (2020), certain categories of entities are required by law to have their financial statements independently audited by a registered audit firm.

The Prakas clearly stated the classification of Enterprise/Non-for-profit Organisation on the obligation to submit the audited report to Accounting and Auditing Regulator (“ACAR”) as below:

1. Public Enterprise

The public enterprise is an enterprise that all or most of its capital belongs to the State. The public enterprises have its mission to enable the country’s economic and social development, namely to increase the value of natural resources and to create professions.

The public enterprise sector consists of:

    • Public establishments with economic characteristics

    • State own companies

    • Joint ventures in which the State directly or indirectly hold more than 51% of the capital or the right to vote

(According to Law on the General Status of Public Enterprise issued on 26 May 1996)

2. Public Limited Enterprise

            Public limited enterprise refers to:

    • Enterprise having debt instruments or other capital instruments of that enterprise are traded publicly on market or the enterprise is under process of release those instruments for public trading on market (local or foreign stock market or local or regional OTC “Over the Counter” market; or

    • Asset management enterprise which has a guarantee for others as a part of main business of the enterprise such as: bank, saving deposit, microfinance institutions, broker, dealer and mutual fund.

3. Investment Project

Investment project refers to the Qualified Investment Projects which was granted the Final Registration Certificate from the Council for the Development of Cambodia.

4. Any enterprise that meet 2 out of 3 criteria as follows:

    • 1st criteria: having annual turnover for the accounting period from Riels 4,000,000,000 (four billion) (Around USD 1,000,000) up.

    • 2nd criteria: having total assets from Riels 3,000,000,000 (three billion) (Around USD 750,000) up on the date of ending accounting period.

    • 3rd criteria: having the total employee from 100 (one hundred) based on the total proportion of employee during the year.

Enterprise which does not meet at least 2 (two) among the above 3 (three) criteria can voluntarily submit financial statement for independent audit.

5. Non-profit Organisation shall submit its financial statements for each accounting period for independent audit if it meets 2 criteria as follows:

    • Total annual expense exceeds Riels 2,000,000,000 (two billion); and

    • Having total of employee from 20 (twenty) people up based on the total proportion of employee during the year.

Enterprise which does not meet the above two criteria can voluntarily submit its annual financial statement for independent audit.

If obligated person does not have the commercial activities or operating activities within executive 12 (twelve) months starting from the ending accounting period, that obligated person can submit request to the ACAR to exempt from submission of financial statements for independent audit.

The independent audit and issuance of independent audit opinion on annual financial statements shall be finalised no later than 6 (six) months after accounting closing date.

The obligated person can send audited financial statements and audit report to ACAR no later than 6 months and 20 days from the financial year ended.

Prakas No. 563 MEF.Prk (2020)

Failure to submit an independent audit report will be subject to penalty amount Khmer Riels 20,000,000. In the case that the offender did not pay penalty within 30 days, the amount of penalty will increase twice. In the case that the offender did not pay penalty within 60 days, the amount of penalty will increase 3 times. In the case the offender does not pay penalty within 90 days, NAC will take legal action.

For 30 days, 60 days and 90 days starting from the date of the offender received the notification letter to pay penalty from NAC.

Please refer to Sub-Degree No. 79 ANKR BK

The independent audit of financial statements for the accounting period of 2020 shall be determined as 1st year independent audit. Auditors must not provide service more than 5 consecutive years. There was no mention about the holiday period or cooling off period.

If the entities are not able to meet the deadline, what should they do?

If the entities not able to submit the audited financial statements to ACAR on time, the entities must submit letter of request delay to ACAR (office) before the deadline.

The required document as below:

    • The letter request delay

    • Authorise letter (attached with the copy of National ID/Passport of authoriser and National ID of the person received authorized)

    • Certificate of FIN

    • Certificate of Incorporation

    • Company Extract,

    • Memorandum of Association

    • VAT certificate

    • Patent

    • Receipt of payment request delay (based on the number of days to request and the fee as mention in the Prakas 002 about public service fee for ACAR) – please see the attached Prakas 002 2025

How to submit the audited financial statements to ACAR?

All the entities must request for Financial Reporting Identification Number (FIN) via ACAR E-filing system.

The Entities need to go to https://efiling.acar.gov.kh to fill in the information include create user and password in order to request FIN. It is suggested that the entities should use the company’s email to register.

It is important to note that ACAR E-filing system is different from GDT E-filing system. However, the entities can use same email that use in GDT E-filing system to create user in ACAR E-filing system. But, please aware that these two platforms are not the same or the systems are not syncronise.

The FIN serves as a unique registration ID for submission of audited financial statements. Which usually start from A. The processing time is approximately 10 working days. Once the FIN is issued, audited financial statements and audit reports must be uploaded through: https://efiling.acar.gov.kh.

How to upload audited financial statement into ACAR E-filing system?

To upload your company’s audited financial statements to ACAR e-filling system, you can consider follow the following steps:

Step 1: Log in to ACAR E-filing system via the link https://efiling.acar.gov.kh.

            Key in your user ID and Password that create before.

Step 2: Select “submission of financial statement” – it will show list of year that the entity submitted audited financial statements.

Step 3: Select “submit financial statements” then choose the year

Step 4: Fill in the additional information

Step 5: Fill in the Financial Statements

            This includes the Income statement and Balance Sheet.

            In the income statement – it aske to choose whether your financial statements present by Nature or by Function.

            By Nature:

            Expenses are grouped according to their type or “nature”, regardless of where they are used in the organization.

            For example:

Income statement by Nature

  USD
Income  
Revenue 500,000
Other income 10,000
  510,000
   
Raw materials and consumables used (200,000)
Employee benefits expense (120,000)
Depreciation and amortisation (30,000)
Utilities (25,000)
Rental (10,000)
Transportation costs (15,000)
Profit before Tax 110,000
   

            By Function:

            Expenses are grouped according to the function or activity they relate to, such as:

    • Cost of sales (COGS)

    • Selling and marketing

    • Administrative

    • Research and development

For example:

Income statement by Function

  USD
Income  
Revenue 500,000
Cost of sale (220,000)
Gross profit 280,000
   
Selling and marketing expenses (70,000)
Administrative expenses (90,000)
Other operating expense (10,000)
Profit before Tax 110,000
   

Step 6: Attache file

Attache the signed audited financial statements. Khmer report is compulsory to attached. The file attached must be no bigger than 10MB and must be in PDF.

Step 7: Payment and submit the payment slip.

After the audited report is uploaded, it will auto generate the invoice for the entities to make the payment for “the service fee for keeping the audited financial statements” which is Riels 300,000. The entity must make the payment before the filing deadline via the banks accounts of ACAR as below detail:

Bank name: Accounting and Auditing Regulator
Bank account: 0001-04-094580-1-8
Bank: ACLEDA Bank

Please note that when the entity makes payment, please do the remark in the payment which is put the invoice number that generate from the system.

Please refer to sample below for invoice from ACAR generate from E-filing system.

Once the entity made payment already. The entity needs to generate the payment (paid via internet banking) or take the bank slip (paid at the bank counter) and upload the Receipt to ACAR E-filing system. When uploading, the entity must key in the transaction number too.

What to do if the entity wrongly requests the FIN code?

If the enterprise confuses in the type of their entities (the entity was Audited obligation but confuse to request non-audited), the entities need to submit the document to ACAR office. The required document as below:

    • The letter request change from N (FIN) to A (FIN)

    • Authorise letter (attached with the copy of National ID/Passport of authoriser and National ID of the person received authorized)

    • Certificate of FIN

    • Certificate of incorporation

    • Company Extract,

    • Memorandum of Association

    • VAT certificate

    • Patent

    • TOI (the latest year) which has company stamp

Pls refer to the “Letter request cange FIN” Here.

What to do if the entity wrongly submit the payment slip?

If the enterprise wrongly made the payment (pay less/pay over), the entities need to submit the document to ACAR office. The required document as below:

    • The letter request pays additional (if pay less)/ or letter request refund from ACAR (if pay over) – this letter has no sample. The entity must prepare themselves the admin letter. In this letter must explain why the entity pay less or pay over.

    • Authorise letter (attached with the copy of National ID/Passport of authoriser and National ID of the person received authorized)

    • Certificate of FIN

    • Certificate of incorporation

    • Company Extract,

    • VAT certificate

    • Patent

ACAR officer will review the letter and feedback to the entity to make extra payment (if pay less) and information of refund (if pay over). Follow the instructions from the officer to end the process.

What to do if the entity forgets the user or password?

If the enterprise forgot the password or user log in, the entities need to submit the document to ACAR office. The required document as below:

    • The letter request user and password – this letter has no sample. The entity must prepare themselves the admin letter. In this letter must explain the reason.

    • Authorise letter (attached with the copy of National ID/Passport of authoriser and National ID of the person received authorized)

    • Certificate of incorporation

    • Company Extract,

    • VAT certificate

    • Patent

ACAR officer will contact back after review the documents submitted. Follow the instructions from the officer to end the process.

What to do if the entity would like to change company information?

If the enterprise would like to change company information, the entities need to submit the document to ACAR office. The required document as below:

    • The letter would like to change company information – this letter has no sample. The entity must prepare themselves the admin letter. In this letter must explain the reason.

    • Authorise letter (attached with the copy of National ID/Passport of authoriser and National ID of the person received authorized)

    • Certificate of incorporation

    • Certificate of FIN

    • Company Extract,

    • VAT certificate

    • Patent

ACAR officer will contact back after review the documents submitted. Follow the instructions from the officer to end the process.

Scroll to Top