Cambodia’s revised statutory audit framework expressly brings enterprises operating casino businesses within the category of enterprises subject to mandatory independent audit.
Under Prakas No. 063 dated 18 August 2026 on the Obligations to File Annual Financial Statements and Submit Financial Statements for Independent Audit, casino businesses are specifically identified as enterprises required to submit their annual financial statements for independent audit.
The revised audit requirements apply from the 2026 accounting period onwards.
Casino Businesses Are Specifically Subject to Mandatory Independent Audit
Article 8 of Prakas No. 063 lists several categories of enterprises that must submit their annual financial statements for independent audit.
These expressly include:
“Enterprises operating casino businesses.”
This is an important distinction because the audit obligation arises from the nature of the enterprise’s business under Article 8, rather than solely from the general financial thresholds under Article 9.
Accordingly, an enterprise operating a casino business does not need to satisfy the general two-out-of-three criteria relating to turnover, total assets and employees in order for the Article 8 audit requirement to apply.
The General Financial Thresholds Are a Separate Test
Article 9 contains a separate mandatory audit test for enterprises that do not otherwise fall within the categories specifically identified in Article 8.
Under Article 9, an enterprise is generally required to undergo independent audit if it satisfies at least two of the following three criteria:
- the applicable turnover threshold for its business sector;
- total assets of at least KHR 10 billion (USD 2.5 million); and
- an average of 100 employees or more during the year.
For a casino business, however, the specific Article 8 requirement should be considered first because casino businesses are expressly named in the mandatory audit categories.
Who Can Perform the Independent Audit?
Prakas No. 063 defines an “independent audit” as an audit of financial statements performed by an auditor licensed by the Accounting and Auditing Regulator (“ACAR”).
An enterprise operating a casino business should therefore ensure that its statutory audit is performed by an appropriately licensed auditor.
Audit Completion Deadline
The independent audit work and issuance of the independent auditor’s opinion on the annual financial statements must be completed:
No later than six months after the closing date of the accounting period.
Where the audit cannot be completed within the prescribed period, the enterprise may apply to ACAR for an extension by stating appropriate reasons.
For a casino enterprise with an accounting year ending on 31 December 2026, the audit would ordinarily need to be completed by 30 June 2027, unless an extension is obtained in accordance with the applicable requirements.
Filing Audited Financial Statements with ACAR
An enterprise subject to independent audit must file:
- its audited annual financial statements; and
- the independent auditor’s report
with ACAR no later than:
Six months and twenty days after the closing date of the accounting period.
Accordingly, for a casino enterprise with a 31 December 2026 year-end, the filing deadline would ordinarily be 20 July 2027.
The filing must be made in accordance with the forms and procedures prescribed by ACAR.
Is an Audit Exemption Available?
Prakas No. 063 provides a limited exemption mechanism for enterprises falling within Article 8.
An Article 8 enterprise may apply to ACAR for exemption from the independent audit requirement where it has not conducted business operations for twelve consecutive months following the most recently audited financial year.
The exemption is not automatic.
An eligible enterprise must submit its exemption application to ACAR:
No later than 30 days after the closing date of the accounting period
and pay the applicable public service fee in accordance with the regulations in force.
Accordingly, a casino enterprise that has ceased or suspended operations should not assume that its audit obligation automatically ceases. The exemption procedure prescribed by Article 15 should be considered where applicable.
Effective from the 2026 Accounting Period
Article 26 provides that enterprises required to submit financial statements for independent audit under Articles 8 to 11 must comply with the new requirements:
From the 2026 accounting period onwards.
Prakas No. 563 MEF.PrK dated 10 July 2020 has been repealed, while existing implementing guidelines issued under that Prakas remain in force until replaced by new implementing guidelines.
Key Takeaway for Casino Operators
For the 2026 accounting period onwards, enterprises operating casino businesses in Cambodia are expressly identified under Article 8 of Prakas No. 063 as being subject to mandatory independent audit.
The obligation is based on the enterprise’s status as an operator of a casino business and is therefore separate from the general financial-size criteria under Article 9.
Casino operators should ensure that:
- annual financial statements are prepared on a timely basis;
- the statutory audit is performed by an auditor licensed by ACAR;
- the audit and auditor’s opinion are completed within six months after the accounting-period closing date; and
- the audited financial statements and independent auditor’s report are filed with ACAR within six months and twenty days after the closing date.
Early audit planning is particularly important to ensure timely compliance with the new statutory requirements.
Legal Reference: Prakas No. 063 dated 18 August 2026 on the Obligations to File Annual Financial Statements and Submit Financial Statements for Independent Audit.
Download the Prakas here:
Disclaimer: This article provides general information based on Prakas No. 063 and does not constitute legal, accounting or other professional advice. The application of the requirements should be considered based on the particular facts and circumstances of the enterprise together with applicable Cambodian laws, regulations and ACAR implementing guidance.
