Cambodia’s revised statutory audit framework expressly brings enterprises operating casino businesses within the category of enterprises subject to mandatory independent audit.
下面 关于提交年度财务报表及提交独立审计财务报表义务的2026年8月18日第063号部门规章, 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年会计期间及以后.
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 以下三个标准中的两个:
- the applicable turnover threshold for its business sector;
- total assets of at least KHR 10 billion (USD 2.5 million); 和
- an average of 100 名或更多员工 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.
谁可以执行独立审计？
Prakas No. 063 defines an “独立审计” as an audit of financial statements performed by an 经会计和审计监管局（ACAR）许可的审计师.
An enterprise operating a casino business should therefore ensure that its statutory audit is performed by an appropriately licensed auditor.
审计完成截止日期
The independent audit work and issuance of the independent auditor’s opinion on the annual financial statements must be completed:
不迟于会计期间截止日后六个月。.
如果审计无法在规定的期限内完成，企业可以陈述适当理由，向ACAR申请延期。.
For a casino enterprise with an accounting year ending on 2026年12月31日, the audit would ordinarily need to be completed by 2027年6月30日, unless an extension is obtained in accordance with the applicable requirements.
向 ACAR 提交经审计的财务报表
An enterprise subject to independent audit must file:
- 它的 经审计的年度财务报表; 和
- the 独立审计师报告
ACAR 不迟于：
会计年度截止日后六个月零二十天。.
Accordingly, for a casino enterprise with a 2026年12月31日 在年底，申报截止日期通常是 2027年7月20日.
该备案必须按照ACAR规定的表格和程序进行。.
是否有审计豁免？
063号部门规章为属于第8条的企业提供了一项有限的豁免机制。.
符合第8条规定的企业如果具备以下条件，可向ACAR申请豁免独立审计要求 自最近一次经审计的财务年度结束后的连续十二个月内未开展业务运营.
该豁免不是自动生效的。.
An eligible enterprise must submit its exemption application to ACAR:
不迟于会计期间截止日后30天
并按照现行规定缴纳适用的公共服务费。.
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.
自2026会计年度起生效
Article 26 provides that enterprises required to submit financial statements for independent audit under Articles 8 to 11 must comply with the new requirements:
自2026会计年度起。.
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
对于 2026年会计期间及以后, enterprises operating casino businesses in Cambodia are expressly identified under Article 8 of Prakas No. 063 as being subject to 强制性独立审计.
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.
法律参考： 关于提交年度财务报表及提交独立审计财务报表义务的2026年8月18日第063号部门规章.
在此处下载 Prakas：
免责声明 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.
