Cambodia’s new statutory audit framework introduces a specific independent audit requirement for certain enterprises engaged in property development.
Under Prakas No. 063 dated 18 August 2026 on the Obligations to File Annual Financial Statements and Submit Financial Statements for Independent Audit, an enterprise engaged in the construction of houses or buildings for sale may be expressly subject to mandatory independent audit where the conditions prescribed in Article 8 are met.
The new independent audit requirements apply from the 2026 accounting period onwards.
Which Property Development Enterprises Are Specifically Subject to Audit?
Article 8 of Prakas No. 063 provides that an enterprise is required to submit its annual financial statements for independent audit where it:
- is engaged in the construction of houses or buildings for sale;
- has obtained a licence or business permit from the Real Estate Business and Pawnshop Regulator or another competent authority; and
- has turnover of at least KHR 8 billion, stated in the Prakas as equivalent to USD 2 million.
Accordingly, the requirement should not be interpreted as automatically applying to every company operating somewhere within the real-estate sector.
The specific Article 8 requirement applies to enterprises meeting the characteristics prescribed by the Prakas—namely, enterprises constructing houses or buildings for sale, holding the relevant licence or business permit, and meeting the prescribed turnover threshold.
The KHR 8 Billion Threshold Is a Specific Audit Trigger
For an enterprise falling within this category, the KHR 8 billion turnover threshold forms part of the specific Article 8 audit requirement.
This is different from the general audit assessment under Article 9, which applies a “two out of three” test based on:
- turnover;
- total assets; and
- average number of employees.
Therefore, where a qualifying property development enterprise meets the specific requirements of Article 8, it is not necessary for the enterprise also to satisfy two of the three Article 9 criteria in order for the Article 8 audit obligation to arise.
Example
A company that:
- constructs residential houses for sale;
- holds the required business licence or permit from the relevant regulator or competent authority; and
- generates annual turnover of KHR 10 billion
would fall within the specific mandatory audit category prescribed by Article 8.
Its audit obligation would arise under Article 8 even if its total assets and average number of employees were below the general Article 9 thresholds.
What If Turnover Is Below KHR 8 Billion?
An enterprise engaged in property development that does not meet the specific KHR 8 billion Article 8 turnover condition should not automatically conclude that no independent audit is required.
The enterprise should separately assess the general criteria under Article 9.
Under Article 9, an enterprise is subject to independent audit where it meets at least two of the following three criteria:
| Criterion | Threshold |
|---|---|
| Applicable sector turnover | Threshold depends on the relevant business sector |
| Total assets | KHR 10 billion (USD 2.5 million) or more |
| Average employees | 100 or more |
Prakas No. 063 prescribes different turnover thresholds for commercial, manufacturing and service enterprises. However, the attached Prakas does not itself provide detailed rules for determining the appropriate sector classification for every type of property development activity. Accordingly, sector classification should be considered carefully with reference to applicable ACAR guidance.
Who Can Perform the Independent Audit?
For purposes of Prakas No. 063, an “independent audit” means an audit of financial statements performed by an auditor licensed by the Accounting and Auditing Regulator (“ACAR”).
A property development enterprise falling within the mandatory audit requirements should therefore ensure that its statutory audit is performed by an appropriately licensed auditor.
Audit Completion and Filing Deadlines
The independent audit work and issuance of the independent auditor’s opinion 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.
The audited entity must subsequently 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.
For example, for an enterprise with a 31 December 2026 year-end:
- the independent audit should ordinarily be completed by 30 June 2027; and
- the audited financial statements and auditor’s report should ordinarily be filed with ACAR by 20 July 2027.
Is an Audit Exemption Available?
Article 15 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 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.
Effective from the 2026 Accounting Period
Article 26 of Prakas No. 063 provides that enterprises required to submit their 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 effective until replaced by new implementing guidance.
Key Takeaway for Property Developers
For the 2026 accounting period onwards, an enterprise engaged in the construction of houses or buildings for sale should carefully assess whether it falls within Article 8 of Prakas No. 063.
Where the enterprise:
- constructs houses or buildings for sale;
- holds a licence or business permit from the Real Estate Business and Pawnshop Regulator or another competent authority; and
- has turnover of at least KHR 8 billion,
its annual financial statements are specifically subject to mandatory independent audit under Article 8.
Management should therefore plan the statutory audit early enough to ensure that the audit is completed within six months after year-end and that the audited financial statements and auditor’s report are filed with ACAR within the prescribed filing period.
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 and together with applicable Cambodian laws, regulations and ACAR implementing guidance.
