On 18 August 2026, the Non-Bank Financial Services Authority, acting through the Accounting and Auditing Regulator (“ACAR”), issued Prakas No. 063 on the Obligation to File Annual Financial Statements and Submit Financial Statements for Independent Audit (the “Prakas”), replacing Prakas No. 563 dated 10 July 2020. ACAR subsequently issued an implementation notification (Notice No. 033/26) on 26 August 2026. The Prakas gives effect to the decision reached at the 19th Royal Government–Private Sector Forum.

Background
Financial statement obligations in Cambodia derive from the Law on Accounting and Auditing 2016. Until now, the independent audit requirement was governed by Prakas 563, while the obligation of all enterprises, including those not subject to audit, to file annual financial statements with ACAR was established separately by Instruction No. 002 dated 27 January 2022. The Prakas consolidates these two strands into a single comprehensive regime covering both the audit obligation and the filing obligation, together with revised audit thresholds, a codified exemption procedure, and a framework of administrative sanctions.

Filing Deadlines
Annual financial statements are filed through ACAR’s e-filing system. Under Article 6 of the Prakas, entities not subject to audit must file within three months and 20 days after the close of the accounting year (by 20 April for calendar-year entities), and entities subject to audit must file within six months and 20 days (by 20 July for calendar-year entities). This represents an extension from the 15-day period under Prakas 563. For audited entities, the audit opinion from the audit firm must be obtained within six months of the accounting closing date.

Entities Subject to Mandatory Audit Regardless of Size
Under Prakas 563, mandatory audit applied only to public enterprises, public accountable entities and Qualified Investment Projects (“QIPs”). The Prakas widens this category as follows:

– Public enterprises and public accountable entities (listed companies, banks, microfinance deposit-taking institutions, insurance companies, securities firms, mutual funds and the like)
– QIPs
– Branches of foreign companies (new)
– Casino operators (new)
– Residential and commercial building developers licensed by the Real Estate Business and Mortgage Regulator or other competent authorities, with annual turnover of KHR 8 billion (approximately USD 2 million) or more (new)

Size-Based Audit Thresholds
The Prakas retains the “two out of three” test but raises the thresholds and, for the first time, differentiates the turnover threshold by business sector.

Criterion 1 – Annual turnover. Previously KHR 4 billion (approximately USD 1 million) or more. Now: commercial, KHR 20 billion (approximately USD 5 million) or more; manufacturing, KHR 30 billion (approximately USD 7.5 million) or more; services, KHR 8 billion (approximately USD 2 million) or more.

Criterion 2 – Total assets. Previously KHR 3 billion (approximately USD 750,000). Now KHR 10 billion (approximately USD 2.5 million) or more as at the closing date.

Criterion 3 – Employees. Average annual headcount of 100 or more (unchanged).

Continuation Rule for Entities Falling Below the Thresholds
Under Prakas 563, an enterprise that had once been audited was required to continue submitting audited financial statements for at least three further consecutive years even if it no longer met the criteria. Under the Prakas, that three-year continuation obligation applies only where the enterprise still has annual turnover of KHR 5 billion (approximately USD 1.25 million) or more.

Non-Profit Organizations
Under Prakas 563, an NPO required an audit only where both of the following were met: total annual expenses above KHR 2 billion and an average of 20 or more employees. The Prakas splits the analysis into two independent triggers, either of which gives rise to an audit obligation:

– Individual projects with total costs exceeding KHR 2 billion (approximately USD 500,000)
– General operations with annual total expenditures exceeding KHR 3 billion (approximately USD 750,000), excluding audited project costs, together with an average of 20 or more workers employed during the year

A new audit frequency rule applies to NPO projects: projects of 18 months or less require only one independent audit, while projects longer than 18 months must be audited every 12 months.

Exemptions and Notifications
The Prakas codifies an express exemption regime for the first time.

Exemption requests by enterprises. Enterprises subject to audit by reason of business type or size may apply to ACAR for an exemption where they have been inactive for 12 consecutive months following their last audited financial year, or where they no longer meet the general criteria and have turnover under KHR 5 billion (approximately USD 1.25 million). Requests must be filed within 30 days of the accounting period end date, together with the applicable public service fees.

Notification by NPOs. NPOs that no longer meet the audit thresholds must notify ACAR in writing within 30 days after the accounting period end date.

Administrative Sanctions for Late Submission
Prakas 563 addressed penalties only by reference to Sub-Decree No. 79 dated 1 June 2020. The Prakas instead sets out detailed monetary penalties. For non-audited entities that have already obtained a Financial Reporting Identification Number, late submission of annual financial statements attracts:

– Enterprises: KHR 2,000,000 (approximately USD 500) per month, up to KHR 12,000,000 (approximately USD 3,000) per accounting period
– NPOs: KHR 1,200,000 (approximately USD 300) per month, up to KHR 7,200,000 (approximately USD 1,800) per accounting period

Fines must be paid within 30 days of receipt of the notification. Failure to pay within 30 days results in the penalty being doubled, and non-payment beyond 60 days in its being tripled. Where payment remains outstanding beyond 90 days, ACAR may take direct enforcement action, including issuing formal reminder notices, summoning the entity’s owner or head, requesting inter-ministerial enforcement, or initiating proceedings through the courts or the prosecutor’s office.

Effective Dates and Transition
The financial statement submission obligations for audited and non-audited entities under the prior framework remain in force from the signing date of the Prakas (18 August 2026). The revised independent audit obligations under Articles 8 to 11 apply from the 2026 accounting year onwards. Existing guidelines issued under Prakas 563 remain in force until replaced.

Implementation Considerations
The revised thresholds will remove a considerable number of enterprises from the mandatory audit net. An entity previously caught by the KHR 4 billion turnover or KHR 3 billion asset tests may now fall outside the regime, particularly in the manufacturing sector where the turnover threshold has risen to KHR 30 billion. Enterprises should reassess their position against the sector-specific thresholds for the 2026 accounting year rather than assuming continuity with prior years. The sector classification itself – whether an enterprise is “commercial”, “manufacturing” or “services” for this purpose – may not be self-evident for enterprises with mixed activities, and the implementation notification and any subsequent ACAR guidance should be consulted on this point.

Two further points warrant attention. First, branches of foreign companies are now subject to mandatory audit regardless of size. Foreign-invested groups operating in Cambodia through a branch rather than a subsidiary should assume they are within the audit net even where their financial metrics would not otherwise trigger it. Second, the exemption process runs on a 30-day window from the accounting period end date, which is short in practice. Enterprises intending to exit the audit regime should identify that requirement well before their year-end, and should bear in mind that the three-year continuation rule continues to apply where turnover remains at or above KHR 5 billion.

Falling outside the audit requirement does not remove the obligation to file annual financial statements with ACAR. Non-audited entities remain subject to the filing deadline of three months and 20 days after year-end, and the new monthly penalties for late filing apply to them specifically. The Prakas does not specify whether the 20-day period is counted in calendar days or working days; a conservative reading treats it as calendar days.

For Assistance
Enterprises and non-profit organizations operating in Cambodia should review their turnover, total assets, headcount and, for NPOs, project costs against the new thresholds, and consult their legal, tax or accounting advisors on the filing and audit obligations applicable for the 2026 accounting year.