New Requirements Applicable from the 2026 Accounting Period
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Cambodia has introduced a new regulatory framework governing the filing of annual financial statements and the submission of financial statements for independent audit.
On 18 August 2026, Prakas No. 063 on the Obligations to File Annual Financial Statements and Submit Financial Statements for Independent Audit (“Prakas No. 063”) was signed in Phnom Penh by the Deputy Prime Minister, Minister of Economy and Finance, and Chairman of the Non-Banking Financial Services Authority Council.
Prakas No. 063 replaces Prakas No. 563 MEF.PrK dated 10 July 2020 on the Obligations to Submit Financial Statements for Independent Audit. Most importantly, enterprises and not-for-profit organisations falling within Articles 8 to 11 of the new Prakas are required to comply with the revised independent audit requirements from the 2026 accounting period onwards.
The new Prakas establishes an integrated framework covering:
- annual financial statement filing with the Accounting and Auditing Regulator (“ACAR”);
- mandatory independent audit requirements;
- specific categories of enterprises automatically subject to independent audit;
- sector-specific audit thresholds;
- audit requirements for not-for-profit organisations and their projects;
- continuation and exemption rules;
- ACAR’s inspection and regulatory powers; and
- administrative sanctions relating to late filing by enterprises and not-for-profit organisations that are not subject to independent audit.
This article summarises the principal requirements of Prakas No. 063.
1. Scope of Prakas No. 063
Prakas No. 063 applies to enterprises and not-for-profit organisations in the Kingdom of Cambodia, except enterprises classified as small taxpayers.
Its stated objective is to regulate the obligations to file annual financial statements and the requirements to submit annual financial statements for independent audit, with a view to strengthening regulatory compliance, efficiency, accountability, transparency and effectiveness.
For purposes of the Prakas, an independent audit means an audit of financial statements performed by an auditor licensed by ACAR.
It is important to distinguish between:
(i) the obligation to file annual financial statements with ACAR; and
(ii) the obligation to have those financial statements independently audited.
An enterprise may therefore have an annual financial statement filing obligation even if it is not required to obtain an independent audit.
2. Annual Financial Statement Filing with ACAR
Enterprises and not-for-profit organisations falling within the scope of the Prakas are required to file their annual financial statements with ACAR of the Non-Banking Financial Services Authority.
The filing must be made in accordance with the forms and procedures prescribed by ACAR.
Historical filing periods specified by the Prakas
Article 4 provides that:
- enterprises subject to independent audit shall file their annual financial statements for the 2020 accounting period and subsequent accounting periods; and
- enterprises not subject to independent audit and not-for-profit organisations not subject to independent audit shall file their annual financial statements for the 2021 accounting period and subsequent accounting periods.
These provisions should be distinguished from the new mandatory audit criteria under Articles 8 to 11, which apply from the 2026 accounting period onwards.
3. Filing Deadlines
Prakas No. 063 establishes different filing deadlines depending on whether the entity is subject to independent audit.
Entities not subject to independent audit
An enterprise or not-for-profit organisation that is not subject to independent audit must file its annual financial statements with ACAR no later than three months and twenty days after the closing date of the accounting period.
For an accounting period ending on 31 December, this would ordinarily correspond to 20 April of the following year.
Entities subject to independent audit
An enterprise or not-for-profit organisation that is 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.
For an accounting period ending on 31 December, this would ordinarily correspond to 20 July of the following year.
The independent audit work itself, including issuance of the independent auditor’s opinion, must be completed no later than six months after the closing date of the accounting period.
Prakas No. 063 also permits enterprises and not-for-profit organisations to apply to ACAR for an extension in relation to the preparation of annual financial statements and completion of an independent audit in accordance with applicable laws, regulations and guidelines.
Where an audit cannot be completed within the prescribed six-month period, the obligated enterprise or not-for-profit organisation may apply to ACAR for an extension by stating appropriate reasons.
4. Enterprises Automatically Subject to Independent Audit
Article 8 identifies specific categories of enterprises that are required to submit their annual financial statements for independent audit.
These categories are:
1. Public enterprises
Public enterprises are subject to mandatory independent audit.
For purposes of the Prakas, public enterprises are entities subject to the Law on the General Statute of Public Enterprises or the Law on Public Enterprises.
2. Public interest entities
Public interest entities are subject to mandatory independent audit.
Prakas No. 063 defines public interest entities to include:
- an entity whose debt or equity instruments are traded in a public market;
- an entity that is in the process of issuing such instruments for trading in a public market, whether through a domestic or foreign stock exchange or an over-the-counter market; or
- an entity that holds assets in a fiduciary capacity for a broad group of outsiders as one of its primary businesses.
The Prakas gives examples of the latter category including banks, deposit-taking microfinance institutions, credit unions, insurance companies, securities companies and mutual funds.
3. Qualified Investment Projects
A Qualified Investment Project (“QIP”) is expressly subject to mandatory independent audit.
For purposes of the Prakas, a QIP refers to an enterprise that has received a registration certificate from:
- the Council for the Development of Cambodia; or
- the Capital or Provincial Investment Subcommittee.
4. Branches of foreign companies
Branches of foreign companies are expressly included in Article 8 and are therefore subject to mandatory independent audit.
5. Enterprises operating casino businesses
Enterprises operating casino businesses are expressly subject to mandatory independent audit.
6. Certain enterprises constructing houses or buildings for sale
An enterprise engaged in the construction of houses or buildings for sale is subject to independent audit where it:
- has obtained a licence or business permit from the Real Estate Business and Pawnshop Regulator or another competent authority; and
- has turnover of KHR 8 billion, stated in the Prakas as equivalent to USD 2 million, at the threshold prescribed in Article 8.
These Article 8 categories are specific statutory audit categories and are separate from the general “two out of three” test under Article 9.
5. General Mandatory Audit Criteria for Enterprises
In addition to the enterprises specifically listed in Article 8, Article 9 provides that an enterprise must submit its financial statements for independent audit if it meets at least two of the following three criteria.
Criterion 1 – Turnover
The applicable turnover threshold depends on the business sector:
| Business sector | Turnover threshold |
| Commercial sector | KHR 20 billion (USD 5 million) or more |
| Manufacturing sector | KHR 30 billion (USD 7.5 million) or more |
| Service sector | KHR 8 billion (USD 2 million) or more |
Criterion 2 – Total assets
Total assets amount to KHR 10 billion (USD 2.5 million) or more as at the closing date of the accounting period.
Criterion 3 – Employees
The average number of employees during the year is: 100 employees or more.
Accordingly, satisfying only one criterion is not sufficient under Article 9. An enterprise must satisfy at least two of the three criteria.
A commercial enterprise with:
- turnover of KHR 25 billion;
- total assets of KHR 12 billion; and
- 60 employees
meets both the turnover and total asset criteria and would therefore be subject to independent audit.
By contrast, a commercial enterprise with:
- turnover of KHR 25 billion;
- total assets of KHR 7 billion; and
- 60 employees
meets only one of the three criteria and would not become subject to mandatory independent audit solely by reason of Article 9.
This analysis assumes that the enterprise does not otherwise fall within one of the mandatory categories in Article 8.
6. Meaning of Turnover, Total Assets and Employees
Prakas No. 063 provides definitions relevant to the Article 9 assessment.
Turnover
“Turnover” means the gross income generated from business operations during a specific accounting fiscal year.
Total assets
“Total assets” refers to both short-term and long-term resources shown in the statement of financial position.
Employees
The Prakas adopts a broad definition of employees, referring to persons of all types and nationalities who have entered into a contract to work for remuneration under the direction and control of another individual or legal entity, whether public or private.
For the Article 9 employee threshold, the relevant measure is the average number of employees during the year.
Classification between commercial, manufacturing and service sectors
Prakas No. 063 specifies different turnover thresholds for the commercial, manufacturing and service sectors. However, the text of the Prakas provided does not itself prescribe detailed rules for determining the sector classification of an enterprise that conducts mixed or multiple activities.
Where sector classification is not clear, the enterprise should therefore consider applicable ACAR implementing guidance and, where necessary, seek clarification rather than applying an unsupported classification methodology.
7. Continuing Audit Requirement After Falling Below the Thresholds
A particularly important provision appears in Article 9.
An enterprise that no longer meets the Article 9 conditions is nevertheless required to continue submitting its financial statements for independent audit for:
At least three consecutive years
provided that its annual turnover remains:
KHR 5 billion (USD 1.25 million) or more.
Therefore, falling below the normal two-out-of-three criteria does not necessarily terminate the statutory audit obligation immediately.
Enterprises should review both their current-year position and their prior audit status when determining whether an audit remains mandatory.
8. Independent Audit Requirements for Not-for-Profit Organisations
Prakas No. 063 provides a separate framework for not-for-profit organisations.
There are two distinct tests:
8.1 Project-level audit
The financial statements of a project must be submitted for independent audit where the project’s: Total cost exceeds KHR 2 billion (USD 500,000).
The wording is “exceeding” KHR 2 billion.
8.2 Annual financial statements of the not-for-profit organisation (NGOs)
The annual financial statements of a not-for-profit organisation must be submitted for independent audit where both of the following conditions are met:
Condition 1 – Annual expenditure
Total annual expenditure exceeds KHR 3 billion (USD 750,000) excluding the cost of projects that are themselves subject to independent audit.
Condition 2 – Employees
The average number of employees during the year is:
20 or more.
Both conditions must be satisfied for the annual financial statements of the not-for-profit organisation to fall within this test.
9. Audit Frequency for Not-for-Profit Projects
Article 11 further addresses the audit frequency of projects according to their duration.
Projects not exceeding 18 months
Projects with a duration not exceeding 18 months may be subject to one independent audit only.
Projects exceeding 18 months
Projects with a duration exceeding 18 months are subject to independent audit, with one independent audit for each twelve-month period.
The wording “may be subject to one independent audit only” for projects not exceeding 18 months is retained deliberately because that is the terminology used in the Prakas.
10. Voluntary Independent Audit
An enterprise that does not meet the conditions under Article 9 may voluntarily submit its financial statements for independent audit.
Similarly, a not-for-profit organisation or a project of a not-for-profit organisation that does not meet the Article 10 criteria may voluntarily obtain an independent audit.
A voluntary audit may nevertheless be appropriate or required for other reasons, including shareholder, lender, donor, contractual or group-reporting requirements. Such requirements would arise outside the mandatory audit tests in Prakas No. 063.
11. Exemption from Mandatory Independent Audit
Article 15 provides specific circumstances in which an enterprise may apply to ACAR for an exemption from the requirement to submit its financial statements for independent audit.
An exemption may be applied for where either of the following conditions is satisfied.
Condition 1 – Article 8 enterprise with no business operations
An enterprise referred to in Article 8 has not conducted business operations for twelve consecutive months following the most recently audited financial year.
Condition 2 – Enterprise no longer meeting Article 9
An enterprise no longer meets the conditions prescribed in Article 9 and has annual turnover less than KHR 5 billion (USD 1.25 million).
An enterprise seeking an exemption under Article 15 must submit its application to ACAR No later than 30 days after the closing date of the accounting period and must pay the applicable public service fee in accordance with the regulations in force.
Accordingly, an exemption should not simply be assumed. Where Article 15 applies, an application to ACAR is required.
12. Not-for-Profit Organisations No Longer Meeting the Audit Conditions
A different procedure applies to not-for-profit organisations.
Where a not-for-profit organisation no longer meets the conditions prescribed in Article 10, it ceases to be subject to the requirement to submit its annual financial statements for independent audit.
However, it must:
Notify ACAR in writing no later than 30 days after the closing date of the accounting period.
This should be distinguished from the Article 15 procedure applicable to enterprises, which requires an application for exemption.
13. ACAR’s Inspection and Regulatory Powers
Prakas No. 063 expressly gives ACAR regulatory powers relating to compliance with accounting and auditing obligations.
The Director General of ACAR may assign officers to inspect compliance on the basis of documents or information collected from enterprises and not-for-profit organisations.
Such inspections are to be conducted on a risk-based basis in accordance with applicable laws and regulations.
ACAR may also retain annual financial statements and related information and use those financial statements and information to assess compliance with applicable laws, legal instruments and relevant technical standards.
The Prakas simultaneously imposes confidentiality requirements on ACAR’s management and officers in relation to financial and non-financial information of enterprises and not-for-profit organisations.
ACAR may provide financial statements to competent public institutions where permitted under applicable laws and regulations. Where requested financial statements are classified as highly confidential, prior approval from the Chairman of the NBFSA Council is required.
14. Administrative Penalties for Late Filing by Entities Not Subject to Independent Audit
Chapter 6 of Prakas No. 063 prescribes administrative sanctions for enterprises and not-for-profit organisations that are not subject to independent audit.
This scope is important.
Enterprise:
An enterprise that delays filing its annual financial statements with ACAR is subject to an administrative fine of:
KHR 2 million (USD 500) per month.
The total late-filing penalty for each accounting period may not exceed:
Not-for-profit organisation
A not-for-profit organisation that delays filing its annual financial statements is subject to an administrative fine of:
KHR 1.2 million (USD 300) per month.
The total late-filing penalty for each accounting period may not exceed:
Annual financial statements filed after the prescribed deadline are regarded as late.
The penalty is calculated based on the number of months of delay, commencing from the month in which the filing deadline falls until the month in which ACAR receives the complete filing together with the annual financial statements.
Important scope point:
The specific penalty amounts in Articles 21 to 23 are expressly stated in relation to enterprises and not-for-profit organisations that are not subject to independent audit.
Accordingly, these particular penalty amounts should not be presented as if Article 21 applies equally to audited entities.
Other penalties or enforcement consequences may arise under the Law on Accounting and Auditing, Sub-Decree No. 102 dated 25 May 2026, or other applicable legal instruments, but those consequences should be assessed separately and should not be inferred from Articles 21 to 23 of Prakas No. 063 alone.
15. Failure to Pay an Administrative Fine
An enterprise or not-for-profit organisation subject to a fine under Articles 21 and 22 must pay the fine within a maximum period of 30 days.
Where failure to pay continues for more than:
- 60 days, the amount of the fine is doubled; and
- 90 days, the amount of the fine is tripled, and ACAR may take legal action in accordance with applicable laws and regulations.
The 30-day, 60-day and 90-day periods are counted from the date on which the person subject to the fine receives ACAR’s official notice for payment of the fine.
Where the obligated person refuses to pay within 90 days, the Director General of ACAR may take one or more measures, including:
- issuing a reminder letter to the owner of the enterprise or head of the not-for-profit organisation;
- summoning the responsible person to appear, provide explanations and/or fulfil the obligation;
- requesting relevant ministries and institutions to take measures in accordance with applicable laws and regulations; and/or
- referring the matter to the competent court or the prosecution attached to the court of first instance.
16. Transitional Provisions and Effective Date
The transitional provisions are particularly important for the 2026 financial year.
Existing guidelines under Prakas No. 563
Guidelines previously issued pursuant to Prakas No. 563 continue to remain in force Until they are replaced by new implementing guidelines. ACAR may issue additional guidelines or implementing rules for the implementation of Prakas No. 063.
Annual financial statement filing provisions
Article 26 specifically provides that the provisions concerning annual financial statement filing contained in paragraphs 2 and 3 of Article 4, for audited and unaudited entities respectively, take effect from the date of signature of Prakas No. 063.
New independent audit requirements
Enterprises and not-for-profit organisations required to submit their financial statements for independent audit under Articles 8 to 11 must comply with those requirements: From the 2026 accounting period onwards.
Repeal of Prakas No. 563
Prakas No. 563 MEF.PrK dated 10 July 2020 on the Obligations to Submit Financial Statements for Independent Audit, together with provisions contrary to Prakas No. 063, is repealed.
17. Summary of Mandatory Independent Audit Requirements from 2026
| Category | Requirement |
| Public enterprise | Mandatory independent audit |
| Public interest entity | Mandatory independent audit |
| Qualified Investment Project | Mandatory independent audit |
| Branch of a foreign company | Mandatory independent audit |
| Enterprise operating a casino business | Mandatory independent audit |
| Qualifying licensed/permitted enterprise constructing houses or buildings for sale | Mandatory where Article 8 turnover condition is met |
| Commercial enterprise | Audit required if at least 2 of 3 criteria are met: turnover ≥ KHR 20bn; assets ≥ KHR 10bn; average employees ≥ 100 |
| Manufacturing enterprise | Audit required if at least 2 of 3 criteria are met: turnover ≥ KHR 30bn; assets ≥ KHR 10bn; average employees ≥ 100 |
| Service enterprise | Audit required if at least 2 of 3 criteria are met: turnover ≥ KHR 8bn; assets ≥ KHR 10bn; average employees ≥ 100 |
| NPO project | Audit required where total project cost exceeds KHR 2bn |
| NPO annual financial statements | Audit required where annual expenditure exceeds KHR 3bn and average employees are 20 or more |
18. Key Compliance Considerations for the 2026 Accounting Period
Enterprises and not-for-profit organisations should perform a fresh assessment of their obligations under Prakas No. 063 for the 2026 accounting period.
In particular, management should consider:
1. Whether the enterprise falls within Article 8
The assessment should first consider whether the enterprise is automatically subject to audit as a public enterprise, public interest entity, QIP, foreign-company branch, casino operator or qualifying construction-for-sale enterprise.
2. Whether the Article 9 test applies
Where Article 8 does not determine the outcome, management should assess the applicable turnover threshold, total assets and average number of employees.
3. The appropriate sector
The applicable turnover threshold differs significantly between commercial, manufacturing and service enterprises.
Where the appropriate classification is unclear, particularly for enterprises undertaking multiple activities, the classification should be considered carefully by reference to applicable ACAR guidance.
4. Previous statutory audit status
An enterprise that ceases to meet Article 9 may remain subject to independent audit for at least three consecutive years where annual turnover remains KHR 5 billion or more.
5. Project-level obligations of NPOs
Not-for-profit organisations should separately assess individual projects against the KHR 2 billion project-cost threshold and assess the organisation’s annual financial statements against the annual expenditure and employee criteria.
6. Audit completion and filing deadlines
For audited entities, the audit and auditor’s opinion must generally be completed within six months after the accounting-period closing date, followed by filing of the audited annual financial statements and auditor’s report with ACAR no later than six months and twenty days after the closing date.
7. Exemption deadlines
An enterprise seeking an Article 15 exemption must act within 30 days after the accounting-period closing date.
A not-for-profit organisation that ceases to meet Article 10 must notify ACAR in writing within the same 30-day 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.
Prakas No. 563 MEF.PrK dated 10 July 2020 is repealed, subject to the transitional provision under which existing implementing guidelines remain effective until replaced by new implementing guidelines.
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Disclaimer
This article provides general information based on Prakas No. 063 and is intended for informational purposes only. The application of the Prakas may depend on the particular facts and circumstances of an enterprise, not-for-profit organisation or project and should be considered together with applicable laws, regulations and ACAR implementing guidance.
