Executive summary

Cambodian enterprises should coordinate four distinct annual obligations: tax compliance, financial reporting, independent audit where required, and Ministry of Commerce (MoC) corporate filings. Management should confirm the reporting framework, reassess audit requirements under Prakas No. 063 for the 2026 accounting period, reconcile the accounts with the tax computation, and calendar the Annual Declaration of Commercial Enterprise (ADCE) by reference to the registration anniversary. Completing one submission does not discharge the others.

Key annual obligations and deadlines

Obligation	Ordinary deadline
Prepare the 2026 financial statements	31 March 2027
File the 2026 annual Tax on Income return and pay the balance due	31 March 2027
Pay annual patent tax for 2027, where applicable	31 March 2027
File unaudited 2026 financial statements with ACAR, where applicable	20 April 2027
Complete the 2026 independent audit and issue the audit opinion, where required	2027年6月30日
File audited 2026 financial statements and the auditor’s report with ACAR, where required	2027年7月20日
File the MoC annual declaration (ADCE) [8]	Three months before the registration anniversary; additional 15-day grace period

These are the ordinary dates calculated under the rules in force as at 24 October 2026, subject to subsequent official notices, applicable holiday adjustments or approved extensions. ACAR means the Accounting and Auditing Regulator. Filing requirements depend on the enterprise’s classification and circumstances; an exemption from audit does not automatically remove the financial statement filing obligation. Eligible Article 15 audit-exemption applications are due within 30 days after year-end.

Management action: Confirm audit applicability, the MoC registration anniversary and outstanding corporate changes; assign an owner to every obligation and retain evidence of approval, payment and successful filing. The June audit deadline does not defer March tax and accounting obligations, and the MoC declaration follows its own anniversary-based timetable.

Annual compliance requires reliable financial information and an accurate corporate record. Directors and finance teams should organise the financial close, tax filings, audit and MoC declaration as one controlled process, while recognising the separate legal purpose and deadline of each obligation.

A tax return establishes the enterprise’s tax position; financial statements report its financial performance and position; an independent audit provides assurance on those statements. The MoC annual declaration confirms corporate information held in the commercial register. None of these documents substitutes for another.

This article provides a planning framework for Cambodian business enterprises for the 2026 financial year and the related filings in 2027. The MoC cycle is linked to each entity’s registration anniversary. Sector licences, labour, social security and other operational obligations require separate review. Internal-control recommendations below are distinguished from the statutory requirements cited.

1 Establish the enterprise’s compliance profile

Management should maintain a documented compliance profile covering legal form, taxpayer classification, business activities, financial year-end, investment status, sector licences and previous audit obligations. Include the MoC registration number and anniversary, registered office, directors, shareholders and company secretary details, together with access to the relevant filing accounts.

This profile should be reassessed when the business expands, establishes a branch, obtains investment incentives, changes activities or undergoes a restructuring. A checklist carried forward from the previous year may overlook the consequences of those changes.

The board or business owner should appoint a senior person to oversee annual compliance. Finance, the company secretary or authorised corporate representative, tax advisers and the external auditor should agree deliverables, responsibilities and escalation arrangements. Management remains accountable for accounting judgements, corporate information and approval of submissions.

2 Prepare financial statements on an appropriate basis

The Law on Accounting and Auditing requires enterprises to maintain accounting records supported by valid vouchers and generally to prepare financial statements within three months after year-end. It also establishes Khmer-language and Khmer-riel requirements, permits accompanying English and foreign-currency information subject to prescribed conditions, and requires accounting records to be retained for at least ten years from their creation.

Management should document the reporting framework applicable to the enterprise. Cambodia has adopted Cambodian International Financial Reporting Standards (CIFRS) and CIFRS for small and medium-sized entities (CIFRS for SMEs). Publicly accountable entities generally apply CIFRS; eligible non-publicly accountable entities may apply CIFRS for SMEs or CIFRS, subject to applicable requirements. The Accounting and Auditing Regulator (ACAR) oversees the reporting framework. Taxpayer classification alone does not determine the applicable standard.

The annual reporting process should produce the complete financial statements and disclosures required by the selected framework. A trial balance, a management profit-and-loss report or the financial schedules attached to a tax return should not be assumed to constitute a complete set of compliant financial statements.

Before closing the accounts, management should review the areas most likely to affect the reliability of the results:

• Revenue and expense cut-off, including transactions recorded around year-end.
• Recoverability of receivables and the condition and valuation of inventories.
• Ownership, classification, depreciation and impairment of fixed assets.
• Completeness of payables, accrued expenses, employee obligations and provisions.
• Loan terms, related-party balances, foreign-currency exposures and financing arrangements.
• Going-concern assessments, subsequent events and material disclosures.

These reviews should produce a clear record of the evidence considered, the judgements made and the person approving each significant adjustment. Entries should have an identifiable business basis and an audit trail linking them to supporting records.

For entities applying CIFRS for SMEs, the forthcoming reporting cycle also warrants transition planning. The third edition of the IFRS for SMEs Accounting Standard is effective for annual periods beginning on or after 1 January 2027, with early application permitted. Management should confirm the edition applicable to its reporting period and any relevant ACAR directions, then assess the impact on accounting policies, systems and comparative information. The publication of a new edition should not lead to an undocumented change of accounting basis.

3 Determine and support the annual tax position

Under the Law on Taxation, medium and large taxpayers must file their annual Tax on Income return within three months after the tax year-end, including where the enterprise reports a loss. The standard rate for legal persons is 20% of taxable income, subject to sector-specific treatment and applicable incentives.

Management should prepare a reconciliation from accounting profit or loss to taxable income. This reconciliation explains why the financial statements and the tax computation may contain different amounts without either being incorrect. It should identify each adjustment, the supporting calculation and the relevant tax treatment.

The review should address, as applicable, the deductibility and substantiation of expenditure, differences between accounting and tax depreciation, provisions and write-offs, interest charges, losses carried forward, available tax credits and income associated with investment incentives. These are review priorities; their treatment depends on the applicable rules and the enterprise’s circumstances.

Particular care is appropriate where an expenditure item is recorded through a year-end journal with limited supporting documentation. Management should be able to explain what was received, why the enterprise incurred the cost, when the obligation arose and how the amount was determined. An invoice should be considered alongside the contract, evidence of delivery or performance, and payment records where relevant.

Minimum tax requires a separate assessment. Article 24 provides for minimum tax at 1% of annual turnover inclusive of taxes other than VAT for enterprises failing to maintain proper accounting records. It also links minimum-tax exemption for a Qualified Investment Project (QIP) to an independent audit report. Management should verify eligibility under the applicable implementing requirements and reconcile the liability with Tax on Income and credits.

For related-party transactions, the annual review should identify charges, financing and balances involving shareholders, group companies and other relevant parties. Management should examine the commercial substance, contractual terms, pricing support and applicable transfer-pricing documentation requirements. A group policy or an invoice from an overseas affiliate should not be treated as sufficient evidence without considering how it applies to the Cambodian enterprise.

For example, a management-service charge warrants examination of the services actually provided, the benefit received, the allocation method and any associated withholding or other tax obligations. The review should also distinguish tax-law related-party definitions from financial reporting definitions where they differ.

Before filing, the finance team should reconcile the annual tax computation to the approved accounting records and relevant monthly declarations. Differences in revenue, purchases, payroll, withholding taxes or credits should be investigated and documented. Where an error is identified, management should assess the appropriate correction process rather than leaving an unexplained discrepancy in the annual file.

4 Reassess the independent audit obligation

Prakas No. 063, dated 18 August 2026, replaces Prakas No. 563; its revised audit criteria apply from the 2026 accounting period. Small taxpayers are excluded from its scope.

Mandatory categories include public enterprises, public interest entities, QIPs, foreign-company branches and casino operators. Licensed or permitted enterprises constructing houses or buildings for sale are also covered where turnover reaches KHR 8 billion.

Other enterprises meet the general test when they satisfy at least two criteria:

标准	阈值
Annual turnover	Commercial: KHR 20 billion; manufacturing: KHR 30 billion; services: KHR 8 billion
Year-end total assets	100 亿韩元
全年平均员工人数	100

Each threshold is inclusive. Prior audit status matters: continuation applies for at least three consecutive years after falling below the general criteria where turnover remains at least KHR 5 billion. Eligible Article 15 exemption applications are due within 30 days after year-end.

Management should document the applicable category, sector classification, calculations and conclusion. Mixed activities, a change in investment status or a proposed exemption merit early consideration. A low level of revenue or an accounting loss should not be used as a substitute for this assessment.

The appointment process should also address the auditor’s licence, relevant sector approvals and independence. Article 15 of the Law on Accounting and Auditing restricts auditing an entity for which the auditor previously provided accounting services unless those services ended at least three years earlier. Management should confirm that the proposed service arrangements satisfy applicable legal and ethical requirements.

Audit planning should begin before year-end where possible. Agree the timetable, identify significant transactions and ensure that records will be available. For an inventory-intensive business, early coordination helps the auditor plan any necessary attendance at stock counts. Receivable confirmations, property documents, loan agreements and support for opening balances may also require advance preparation.

An independent financial statement audit provides reasonable assurance regarding material misstatement; it does not provide absolute assurance. Management remains responsible for preparing the financial statements. A financial statement audit opinion should therefore not be represented as a tax-clearance certificate or a guarantee of compliance with every legal obligation.

5 Complete annual compliance with the Ministry of Commerce

Article 7 of the Law on Commercial Enterprises requires each partnership or company to file an annual declaration with the MoC. The 2026 business-registration reforms also address ADCE filings by registered limited companies, foreign-company branches and representative offices. Assess the requirements for the entity’s legal form rather than relying solely on its tax classification.

Annual declaration timetable

Under the current framework described in guidance on Prakas No. 044 dated 26 May 2026, the ADCE filing window covers the three months before the commercial-registration anniversary, followed by a 15-day grace period. File through the MoC electronic registration service. This differs from older guidance referring to three months after the anniversary. Confirm the anniversary against the registration certificate and the live company record, and set an internal deadline before the anniversary.

The ADCE is separate from the annual Tax on Income return, patent tax payment and ACAR filing. A company with a 31 December financial year-end may have a different MoC filing month. Lack of trading activity should prompt a status review rather than an assumption that annual filings have ceased.

Corporate information and submission controls

Before filing, reconcile the commercial-register information with the company’s constitutional documents, statutory records and approved changes. Review the registered name and office, business activities, directors, shareholders, capital and contact details. Prepare the tax registration and patent certificate information and any other supporting information required by the current electronic form. Complete applicable amendment procedures when changes arise; the annual declaration should not be used to postpone them.

Review the company secretary appointment and electronic registration of the secretary’s information. Phase II guidance confirms electronic registration without a fee and clarifies that a security deposit is not a prerequisite for the secretary’s qualification. Check eligibility under the applicable rules. Separately, review annual shareholder approvals and corporate records required by the company’s legal form and constitution. [8]

Assign a preparer and reviewer, verify account access in advance, and retain the approved declaration, payment receipt and filing acknowledgement. Reconcile any differences between MoC particulars, tax records and financial-statement disclosures. Record the next filing window immediately after completion.

Overdue declarations and temporary penalty relief

Outstanding declarations require prompt review of every affected year, filing fees and the entity’s registry status. Prolonged non-filing may lead to inactive status and restrictions affecting the enterprise. Temporary relief does not remove the underlying filing obligation.

Notification No. 2463 dated 10 July 2026 provides a six-month opportunity for qualifying companies to regularise overdue ADCEs. Published guidance describes payment of the penalty for the latest missed declaration, payment of service fees for all outstanding years, and participation in shareholder background checks. Confirm eligibility and the precise cut-off with MoC before relying on relief; retain evidence that each condition has been met.

6 Maintain a calendar for each separate obligation

The calendar below separates year-end obligations from the MoC anniversary-based filing. For a 31 December 2026 year-end, the financial and tax dates assume no later official notice, applicable holiday adjustment or approved extension. Entities within Prakas No. 063 must file financial statements even where an audit is not required. [1, 4, 5, 8]

Obligation	Ordinary deadline
Prepare the 2026 financial statements	31 March 2027
File the 2026 annual Tax on Income return and pay the balance due	31 March 2027
Pay annual patent tax for 2027, where applicable	31 March 2027
File unaudited 2026 financial statements with ACAR, where applicable	20 April 2027
Complete the 2026 independent audit and issue the opinion, where required	2027年6月30日
File audited 2026 financial statements and the auditor’s report with ACAR	2027年7月20日
File the MoC annual declaration (ADCE) [8]	Three months before the registration anniversary; additional 15-day grace period

Preparation, audit completion and filing are distinct milestones. The later audit timetable should not be used as the working deadline for preparing the accounts or submitting the annual tax return. If the audit subsequently identifies adjustments, management should assess the implications for previously filed tax information and any correction required.

Patent tax is payable annually between 1 January and 31 March. Activities and operating locations can affect the number of payments required. [4] Management should therefore review the current business profile when renewing its patent tax certificate rather than automatically repeating the previous year’s payment.

The calendar should identify the preparer, reviewer, approver and evidence of completion for every submission. Where an extension is needed, management should establish the applicable procedure early and retain the authority’s response. A request should not be treated as approval, and an extension for one obligation should not be assumed to cover another.

7 Preserve a complete and consistent compliance file

The annual compliance file should contain the final trial balance, reconciliations, financial statements, tax computation, filed returns, payment receipts and audit report where applicable. Keep the submitted ADCE and acknowledgement alongside the current commercial-register extract, corporate approvals, amendment confirmations and relevant regulatory correspondence.

For medium and large taxpayers, the Law on Taxation requires relevant accounting and supporting records to be retained for ten years from the end of the tax year. [4] This commencement point differs from the accounting-law rule. A retention policy should accommodate all applicable requirements and preserve records needed for unresolved enquiries or disputes.

Management should retain the final version actually submitted to each authority, together with the filing acknowledgement. A saved draft or an adviser’s confirmation that a return has been prepared is insufficient evidence of successful submission.

Access controls and backup arrangements should protect records without preventing retrieval. Businesses using external accounting providers should agree how source documents, ledgers and system exports will remain accessible if the service arrangement changes.

8 Escalate compliance weaknesses before filing

The annual review should distinguish missed filings, inaccurate corporate particulars, incomplete accounting records, disputed tax treatments and audit-evidence limitations. Assign a corrective action and owner to each issue. Payment of a penalty does not itself correct an inaccurate declaration or replace an outstanding submission.

Tax understatements can attract additional tax and interest under the Law on Taxation. [4] Accounting and audit failures must be assessed separately under the applicable regulatory provisions. Management should obtain an assessment based on the actual breach, affected period and entity status rather than applying a generic penalty estimate.

Beyond statutory consequences, unresolved discrepancies can complicate financing, shareholder reporting, investment transactions and regulatory enquiries. The practical response is to identify the issue promptly, quantify its effect, assign responsibility and document the corrective action.

9 Set management priorities for the 2026 close

Before year-end, confirm the reporting framework and audit assessment, address gaps in records and agree the closing timetable. Independently check the MoC filing window, company secretary information and any unfiled corporate changes. Give priority to matters requiring third-party evidence, shareholder approval or regulatory processing.

During the closing process, a senior reviewer should examine significant adjustments, the tax reconciliation and outstanding audit matters. The review should challenge explanations that rely solely on prior-year treatment, unsupported estimates or differences that have repeatedly remained unresolved.

Before approving each submission, management should be satisfied that the information agrees to the underlying records, material judgements are supported and differences between submissions are explained. After filing, the annual process should conclude with an assessment of recurring weaknesses and assigned actions for the following year.

This discipline gives directors and business owners a defensible basis for approving financial information and meeting their regulatory responsibilities. It also reduces the dependence on last-minute corrections when deadlines are close.

Professional support

VSD Audit and Assurance Co., Ltd. can assist with annual compliance assessments, financial reporting, tax compliance and independent audit, subject to applicable licensing, independence and engagement-acceptance requirements. A coordinated engagement should also identify MoC filing responsibilities and any corporate-secretarial or legal support required. The agreed scope should specify the responsible service provider, deliverables and deadlines.

References

[1] Law on Accounting and Auditing 2016, particularly Articles 15–23 and 29. English translation published by ACAR.  ACAR legal text

[2] IFRS Foundation, Cambodia jurisdiction profile, updated 8 May 2025.  IFRS Foundation jurisdiction profile

[3] IFRS Foundation, third edition of the IFRS for SMEs Accounting Standard and supporting materials, issued February 2025.  IFRS Foundation supporting materials

[4] Law on Taxation 2023, particularly Articles 20, 24, 29, 38–39, 112–113, 201 and 233. Official Khmer text published by GDT; English translation hosted by the Embassy of India in Phnom Penh used for reference.  Official Khmer law | English reference translation

[5] Prakas No. 063 dated 18 August 2026 on the Obligations to File Annual Financial Statements and Submit Financial Statements for Independent Audit, particularly Articles 2, 6, 8–9, 13, 15 and 26–27. English reference translation hosted by VSD.  Prakas No. 063 reference translation

[6] IAASB, A Framework for Audit Quality, included in the 2025 Handbook, Volume 5.  IAASB 2025 Handbook Volume 5

[7] Law on Commercial Enterprises, Article 7. English text published in the Cambodia National Trade Repository.  Government legal text

General information. This article reflects the regulatory position reviewed as at 24 October 2026 and is intended as general guidance. Its application depends on the facts, applicable implementing instruments and any subsequent changes. The official Khmer legal texts prevail over reference translations. Obtain advice on the enterprise’s circumstances before making a filing, exemption or other compliance decision.