The Royal Government of Cambodia issued Sub-Decree No. 102 SD.Es on Penalties for Violation of the Law on Accounting and Auditing, dated 25 May 2026 (the “Sub-Decree”).
The Sub-Decree sets out the specific offenses and corresponding fines for violations of the Law on Accounting and Auditing, together with the authorities, measures, and mechanisms for imposing and managing penalties. It replaces the interim penalty regime under Sub-Decree No. 79 dated 1 June 2020. Enforcement of the penalties is within the jurisdiction of the Accounting and Auditing Regulator (“ACAR”).

Scope of Application
The Sub-Decree applies to:
– Audited and non-audited enterprises registered with the Ministry of Commerce and/or the General Department of Taxation that are large taxpayers or medium taxpayers, and all not-for-profit organizations registered with the competent authorities; and
– All accountants and auditors who are members of the Kampuchea Institute of Certified Public Accountants and Auditors and hold an accounting or auditing license from ACAR.

Offenses and Fines for Enterprises
The Sub-Decree prescribes specific fines for each category of obligated person. For audited enterprises (Article 6), the principal fines include:
– Failure to submit annual financial statements to ACAR: 60,000,000 riels
– Failure to submit annual financial statements in accordance with the prescribed conditions: 20,000,000 riels
– Failure to keep accounting records: 10,000,000 riels
– Keeping incorrect accounting records: 5,000,000 riels
– Preparing annual financial statements that do not comply with applicable accounting standards: 10,000,000 riels
– Intentionally reporting incorrect annual financial information: 10,000,000 riels
– Failure to use riel, or failure to use Khmer, in the annual financial report filed with ACAR: 2,000,000 riels each

For non-audited enterprises (Article 7), failure to submit annual financial statements to ACAR carries a fine of 50,000,000 riels, with other offenses subject to comparable but generally lower fines. Audited not-for-profit entities (Article 8) and non-audited not-for-profit entities (Article 9) are subject to their own separate scales of fines.

Offenses and Fines for Accountants and Auditors
The Sub-Decree also sets out fines applicable to accountants and auditors, both as individuals and as legal entities (Articles 10 to 13). These include per-day fines for late payment or late renewal of professional licenses, fines for auditors who fail to sign and seal an independent audit report (10,000,000 riels per report), fines for failure to retain audit evidence for at least 5 years (20,000,000 riels), and fines for failure to report suspicious transactions related to money laundering, terrorist financing, or the financing of proliferation of weapons of mass destruction (20,000,000 riels per case).

Enforcement Through Inspections – Graduated Penalties
For enterprises and not-for-profit entities, penalties are imposed through inspections on a graduated basis (Article 14). For entities that have filed their annual financial statements with ACAR, where violations are detected during the first inspection, ACAR may suspend the penalty and issue a first letter of recommendation to correct, or impose 20% of the applicable fine. The percentage then increases to 50% at the second inspection, 80% at the third, and 100% at the fourth.
For entities that have failed to submit annual financial statements to ACAR, a fine of 30% of the applicable fine is imposed at the first inspection (together with corrective instructions), rising to 50% at the second inspection and 100% at the third. Compliance inspections are conducted no more than once a year.

Non-Payment of Fines
Where an offender fails to pay a fine within 30 days, the fine is doubled; failure to pay within 60 days results in the fine being tripled; and failure to pay within 90 days allows ACAR to take further action in accordance with the law, including inviting the enterprise owner to appear, requesting other ministries to take measures, or filing a complaint with the provincial court prosecutor. These periods are counted from the date the offender receives the notice of fine.

Right of Appeal
A person subject to a penalty who is dissatisfied with the decision may appeal to the Director General of ACAR within 30 days of receiving notification of the decision. If still dissatisfied with the Director General’s decision, the person may appeal to the Minister of Economy and Finance as Chairman of the Non-Banking Financial Services Authority Council within 30 days of receiving that decision. If still dissatisfied with the Minister’s decision, the person may appeal to the competent court within 30 days of receiving that decision.

Effective Date and Transition
The penalties under the Sub-Decree come into effect 6 months after the date of the Sub-Decree, except for certain specified offenses (points 4, 5, and 7 of Article 6; points 3, 4, and 6 of Article 7; points 4, 5, and 7 of Article 8; and points 3, 4, and 6 of Article 9), which come into effect 1 year after the date of the Sub-Decree.

Implementation Considerations
Enterprises classified as large or medium taxpayers should review their accounting and financial-statement compliance, in particular the timely submission of annual financial statements to ACAR, the maintenance of proper accounting records, and the use of riel and Khmer in filings, ahead of the staggered effective dates. Given the graduated penalty structure, addressing any compliance gaps before a first inspection – when ACAR may issue a recommendation rather than a fine – is advantageous. The substantial fines for failure to submit annual financial statements (up to 60,000,000 riels for audited enterprises) make proactive compliance particularly important.

For Assistance
Enterprises and not-for-profit organizations subject to ACAR filing obligations, as well as accounting and auditing firms, should consult with their legal, tax, or accounting advisors to review their compliance position against the new penalty framework and to prepare for the staggered effective dates.