On 6 August 2026, the National Bank of Cambodia (“NBC”) issued Notification No. 14.026.1075 on the Notification Obligations of Business Owners Who Have Issued Electronic Money (E-Wallet Accounts) for Payments for Products or Services Within a Closed-Loop Network (the “Notification”). Businesses falling within its scope must file a written notification with the NBC within 90 days of receiving the Notification. Calculated from the date of the Notification itself, that period expires on 4 November 2026. Where no notification is filed within that period, the NBC has stated that it will take measures in accordance with the procedures under the laws in force.

Businesses Affected
The NBC observes that a number of businesses – it names coffee shops, service stations, transport companies, entertainment centres and fuel stations – have been issuing electronic money in the form of e-wallet accounts through mobile applications or membership cards. Customers create an account, load a monetary balance, and use that balance to pay for products or services supplied only by the issuing shop or company. The NBC refers to this as “Single-Purpose E-Money”.

The Notification is directed at businesses that are neither banking and financial institutions nor licensed payment service institutions. Institutions already holding an NBC licence are outside its scope.

Legal Basis
Under the 1999 Law on Banking and Financial Institutions, providing means of payment to customers forms part of the operations of banking and financial institutions and requires authorisation from the NBC.

Article 20, paragraph 1 of the 2017 Prakas on the Management of Payment Service Institutions prohibits any legal person other than a banking and financial institution or a licensed payment service institution from issuing electronic money. Article 20, paragraph 2 of the same Prakas then provides that, in certain limited cases, the issuance of electronic money does not require prior authorisation, but does require prior written notification to the NBC.

Conditions for the Notification-Only Treatment
Under Article 20, paragraph 2 of the Prakas on the Management of Payment Service Institutions, all of the following conditions must be satisfied:
– the maximum balance per account does not exceed KHR 200,000 (approximately USD 50) or its equivalent;
– the aggregate balance across all accounts does not exceed KHR 800,000,000 (approximately USD 200,000) or its equivalent;
– the electronic money is used to pay only for products or services supplied by a single person; and
– any other conditions determined by the NBC.

The third condition is directed at the closed-loop character of the arrangement: the balance must be usable only for the goods or services of a single supplier. It does not restrict the notification-only treatment to businesses operated by individuals, and the Notification expressly contemplates that the issuer may be a shop or a company.

How to Notify
An affected business must submit an official letter, together with copies of the relevant supporting documents, to the Communications Unit of the NBC within 90 days of receiving the Notification.

Restrictions Highlighted by the NBC
The NBC has also drawn the public’s attention to the following points, which operate as constraints on how these arrangements may be structured and presented to customers:
– an e-wallet account of this kind is not a savings account, and balances held in it are not deposits;
– the issuing business is prohibited from paying interest on such balances; and
– customers should not hold balances exceeding the prescribed limit, and bear the risks arising from opening and using such accounts.

Implementation Considerations
The Notification reaches further than its examples might suggest. Arrangements such as prepaid cards used at a factory canteen or company shop, fuel cards issued for company vehicles, stored-value membership cards, and balances loaded into a retailer’s or restaurant chain’s own mobile application may all constitute Single-Purpose E-Money, whether or not the business regards itself as operating a payment service.

Businesses operating such schemes should first establish whether the per-account and aggregate balance thresholds are respected and whether balances can be spent only with the issuer. Where the thresholds are exceeded, or where balances can be used across third-party merchants, the arrangement falls outside Article 20, paragraph 2 of the Prakas altogether, and a payment service institution licence or other NBC authorisation may be required. Businesses should also confirm that no interest – and no equivalent benefit accruing by reference to the balance held – is credited to accounts, and that customer-facing materials do not describe the account in terms suggesting a deposit or savings product.

For Assistance
Businesses operating closed-loop e-wallets, stored-value membership cards or prepaid account systems in Cambodia should consult their legal advisors to assess whether the Notification applies to their arrangements and to prepare the required filing within the applicable 90-day period.