Cambodia’s revised audit criteria under Prakas No. 063 dated 18 August 2026 apply from the 2026 accounting period. Management should assess the entity’s status, financial criteria and previous audit obligations before concluding whether an audit is required.
Currency note: USD equivalents below are illustrative, using KHR 4,000 per USD 1. The statutory thresholds are denominated in KHR and should be assessed in KHR.
1. Check the entity’s status
The Prakas covers enterprises and not-for-profit organisations in Cambodia, excluding enterprises classified as small taxpayers. Being a small business does not, by itself, establish that classification.
Article 8 requires an independent audit for:
- Public enterprises and public interest entities.
- Qualified Investment Projects (QIPs).
- Branches of foreign companies.
- Casino operators.
- Enterprises constructing houses or buildings for sale that hold the required licence or permit and have turnover of KHR 8 billion or more (approximately USD 2 million).
These categories do not depend on meeting the general two-out-of-three test. Public interest entities include publicly traded entities, entities issuing instruments for public trading, and entities holding assets in a fiduciary capacity for a broad group of outsiders as a primary business.
2. Apply the general enterprise test
For enterprises not already covered by Article 8, an audit is required when at least two of the following three criteria are met:
| Criterion | Threshold |
|---|---|
| Turnover for the accounting period | Commercial: KHR 20 billion ≈ USD 5 million; manufacturing: KHR 30 billion ≈ USD 7.5 million; services: KHR 8 billion ≈ USD 2 million. Each threshold is inclusive. |
| Total assets at period-end | KHR 10 billion or more ≈ USD 2.5 million |
| Average employees during the year | 100 or more |
Turnover is gross income from business operations, not profit. Assets are assessed at period-end; employees are assessed using the annual average. Where mixed activities make sector classification uncertain, obtain clarification rather than select the most favourable threshold.
Example: A commercial enterprise with turnover of KHR 25 billion (approximately USD 6.25 million), assets of KHR 12 billion (approximately USD 3 million) and 60 average employees meets two criteria and requires an audit. If assets were KHR 7 billion (approximately USD 1.75 million), it would meet only one criterion. Its entity status, previous audit obligations and other applicable requirements would still need to be checked.
3. Apply the separate not-for-profit tests
Assess both project and organisation-level obligations:
- Project financial statements: audit is required where total project cost exceeds KHR 2 billion (approximately USD 500,000).
- Organisation’s annual financial statements: audit is required where annual expenditure exceeds KHR 3 billion (approximately USD 750,000), excluding costs of projects subject to independent audit, and average annual employees are 20 or more.
The monetary tests use “exceeds”, not “equals or exceeds”. Qualifying projects lasting no more than 18 months may undergo one audit; longer projects require an audit for each 12-month period.
4. Check continuing obligations and exemption procedures
An enterprise that ceases to meet Article 9’s conditions must continue audits for at least three further consecutive years, provided annual turnover remains KHR 5 billion or more (approximately USD 1.25 million). Falling below two criteria does not automatically end an existing obligation.
An enterprise may apply to ACAR for exemption where:
- An Article 8 enterprise has had no business operations for 12 consecutive months following its most recently audited financial year; or
- It no longer meets Article 9’s conditions and turnover is below KHR 5 billion (approximately USD 1.25 million).
The application and applicable public-service fee are due within 30 days after period-end. Eligibility should not be treated as an automatic exemption.
A not-for-profit organisation that ceases to meet Article 10 follows a different procedure: it must notify ACAR in writing within 30 days after period-end.
5. Take the appropriate next steps
If an audit is required:
- Document the assessment and appoint an ACAR-licensed auditor early enough to plan necessary procedures.
- Prepare the financial statements, reconciliations and supporting records.
- Complete the audit and issuance of the auditor’s opinion within six months after period-end.
- File the audited financial statements and auditor’s report with ACAR within six months and 20 days after period-end.
For a 31 December 2026 year-end, the ordinary deadlines are 30 June 2027 for audit completion and 20 July 2027 for filing, subject to any valid extension or subsequent applicable direction.
If an audit is not required:
- Retain the assessment and supporting calculations, including the review of previous audit status.
- Complete any applicable exemption application or notification procedure.
- Continue maintaining accounting records and preparing financial statements under the applicable framework.
- If within the Prakas’s scope, file unaudited financial statements with ACAR within three months and 20 days after period-end, ordinarily 20 April 2027 for a 31 December 2026 year-end.
- Check separately for sector-regulator, lender, donor, shareholder or contractual audit requirements.
An audit exemption does not remove the financial-statement filing obligation. ACAR expressly confirms this distinction.
This article provides general guidance. Each entity’s conclusion should reflect its circumstances, applicable legal instruments and current ACAR guidance.
