Cambodia’s revised statutory audit framework expressly requires Qualified Investment Projects (“QIPs”) to submit their annual financial statements for 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, QIPs are specifically identified as a category of enterprise subject to mandatory independent audit.
The revised requirement applies from the 2026年会计期间及以后.
What Is a Qualified Investment Project?
For purposes of Prakas No. 063, a 合格投资项目 refers to an enterprise that has received a registration certificate from:
- the Council for the Development of Cambodia (“CDC”); or
- the Capital or Provincial Investment Subcommittee.
This definition is important because the audit obligation under the Prakas is tied to the enterprise’s QIP status.
QIPs Are Specifically Subject to Mandatory Independent Audit
Article 8 of Prakas No. 063 provides that enterprises falling within specified categories must submit their annual financial statements for independent audit.
One of those categories is:
Qualified investment projects.
Accordingly, a QIP does not need to satisfy the general two-out-of-three financial criteria under Article 9 in order for the Article 8 audit requirement to apply.
The audit obligation arises because the enterprise is a QIP within the meaning of the Prakas.
No Separate QIP Turnover Threshold Is Prescribed in Article 8
Unlike the general audit test under Article 9, Article 8 does not prescribe a specific turnover, asset or employee threshold for QIPs.
Therefore, once an enterprise falls within the definition of a QIP under Prakas No. 063, the mandatory independent audit requirement applies by virtue of that status.
The general Article 9 thresholds—covering turnover, total assets and employee numbers—constitute a separate audit test applicable to enterprises outside or in addition to the specific categories identified in Article 8.
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.
A QIP should therefore ensure that its statutory audit is performed by an appropriately licensed auditor.
审计完成截止日期
独立审计工作和独立审计师意见的出具必须完成：
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 example, where a QIP has a financial year ending 2026年12月31日, the independent 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
A QIP 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 QIP 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？
Prakas No. 063 provides a limited exemption mechanism for enterprises falling within Article 8, which includes QIPs.
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 an application to ACAR no later than 30 days after the closing date of the accounting period; 和
- pay the applicable public service fee in accordance with the regulations in force.
A QIP that has suspended or ceased operations should therefore not assume that its audit obligation automatically ends.
自2026会计年度起生效
Article 26 of Prakas No. 063 provides that enterprises required to submit financial statements for independent audit under Articles 8 to 11 must comply with the revised 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 effective until replaced by new implementing guidelines.
Key Takeaway for Qualified Investment Projects
对于 2026年会计期间及以后, an enterprise holding QIP status as defined under Prakas No. 063 is expressly subject to 强制性独立审计.
The obligation arises from the enterprise’s status as a QIP and does not depend on satisfying the general turnover, asset or employee thresholds under Article 9.
Management of a QIP should therefore 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 planning is particularly important for QIPs to ensure timely compliance with the statutory audit and filing requirements.
在此处下载 Prakas：
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.
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.
