Airbnb and Short-Term Rentals in Cambodian Condominiums
A Phnom Penh apartment may rent for USD 650 per month under a normal one-year lease.
A similar unit may be advertised online for USD 55 per night.
Multiplying the nightly price by 30 produces more than USD 1,600 and makes short-term rental appear obviously more profitable.
The owner is not selling 30 identical nights.
They are managing:
- occupancy;
- pricing;
- check-in;
- cleaning;
- linen;
- platform fees;
- guest messages;
- deposits;
- damage;
- refunds;
- immigration registration;
- condominium rules.
When vacancy rises, gross revenue can quickly move closer to ordinary rent while operating expenses remain substantially higher.
The deeper difference is regulatory.
Long-term residential letting and systematic tourist accommodation are not necessarily the same activity.
A strata title gives the owner rights over the private unit, subject to law and the building’s internal regulations.
It does not automatically convert the apartment into a licensed mini-hotel.
This article provides general information, not legal, tax, insurance or tourism-business advice. The correct licensing, FPCS, tax, building and insurance treatment should be confirmed for the specific unit and operator before launch.
A platform is a sales channel, not a permit
Airbnb, Booking.com, Agoda and similar platforms connect hosts and guests.
The platform may verify:
- identity;
- payment method;
- listing standards;
- reviews;
- cancellation policy.
Publishing a listing does not prove:
- tourism licence;
- company or business registration;
- tax registration;
- building approval;
- fire compliance;
- lawful foreign-guest registration;
- insurance;
- a tenant’s right to sublet.
A platform account answers:
“Can this offer be published?”
Cambodian law and the building’s rules answer:
“Can this service be operated from this apartment?”
An owner should not treat a neighbour’s active listing as legal confirmation.
The neighbour may:
- be operating without review;
- use a licensed operator;
- have a different agreement;
- be in another category of building.
The right to lease a private unit has limits
Sub-Decree No. 126 recognises the private unit as separately owned property and allows the co-owner to use and lease it within the legal and regulatory framework.
That right does not permit use that:
- damages the structure;
- threatens safety;
- interferes with other owners;
- breaches the internal regulations;
- misuses common property;
- changes the building’s approved use without required approval.
Short-term rentals can increase:
- unfamiliar users;
- access-card turnover;
- lift use;
- luggage movement;
- cleaning traffic;
- noise complaints;
- security workload;
- use of common amenities.
Management may therefore see the activity not only as private income but as a repeated use pattern affecting the whole building.
The owner’s economic interest and the co-owners’ common interest must be reconciled through valid rules rather than informal practice.
When ordinary letting starts to resemble tourist accommodation
Cambodia’s Tourism Law regulates tourism activities and includes tourist accommodation services.
Detailed licensing and classification are handled through the Ministry of Tourism and implementing rules.
The general law does not create one simple nationwide line such as:
- fewer than seven nights means hotel;
- more than 30 nights means lease.
The factual model matters.
Indicators of tourist accommodation can include:
- nightly advertising;
- repeated short stays;
- frequent check-in and check-out;
- cleaning between stays;
- linen and toiletries;
- guest support;
- reception or concierge;
- several managed units;
- one business brand;
- additional hospitality services.
The more of these features are present, the harder it becomes to describe the operation as an ordinary residential lease.
A single owner-managed apartment may be treated differently from a company operating 50 units in several towers.
Small scale should not be assumed to create an exemption unless the relevant authority confirms it.
A tourism licence may not be the only registration
The Tourism Law makes clear that a tourism licence does not replace other business, tax or sector requirements.
Depending on the structure, the operating map can include:
- tourism licence;
- commercial registration;
- tax registration;
- patent tax;
- accommodation tax;
- VAT or income-tax obligations;
- local authority requirements;
- fire and safety compliance;
- immigration guest registration;
- employment compliance;
- insurance.
The exact combination depends on:
- owner;
- operator;
- number of units;
- services;
- location;
- business form.
It would be excessive to apply a full hotel checklist automatically to every private stay.
It would be equally unsafe to assume that one apartment creates no regulated activity.
Building rules can stop the model before the state does
Even where the public regulatory framework permits the activity, the building’s internal regulations may restrict short-term stays.
Relevant provisions can include:
- minimum lease term;
- prohibition on hotel use;
- guest-registration rules;
- subletting restrictions;
- access-card procedures;
- maximum occupancy;
- quiet hours;
- commercial activity;
- use of amenities;
- move-in charges;
- additional deposits;
- penalties;
- owner liability.
A receptionist’s statement that Airbnb is prohibited should be supported by the current rule or valid resolution.
The opposite statement—everyone does it here—is not legal protection.
Rules may also change after purchase.
An investor whose return depends on short-term rental is relying partly on continuing support or tolerance from the building’s governance system.
Residential condos, serviced apartments and condo-hotels are different products
A normal residential condominium is designed primarily for owners and long-term residents.
A serviced-apartment building usually has:
- central operator;
- reception;
- housekeeping;
- accommodation systems.
A condo-hotel or rental-pool project is designed around hospitality operation from the beginning.
Airbnb in an ordinary residential tower attempts to add a hotel-like service model to a residential governance structure.
That may be possible.
It is not automatically cost free.
| Issue | Ordinary condominium | Hospitality model |
|---|---|---|
| Reception | Residents and normal guests | Repeated arrivals |
| Guest records | Limited | Core operating function |
| Cleaning | Private arrangement | Systematic service |
| Insurance | Residential baseline | Accommodation use |
| Security | Stable resident access | Frequent guest turnover |
| Tax | Rental profile | Tourism-business profile |
A buyer should not apply the nightly rate of a professional serviced apartment to a conventional condominium without comparing:
- permissions;
- staffing;
- platform costs;
- occupancy;
- cleaning;
- insurance;
- guest services.
Foreign guests must be registered properly
The General Department of Immigration uses the Foreigners Present in Cambodia System to record the presence and accommodation address of foreign nationals.
The Tourism Law also requires managers of hotels and tourist accommodation services to register relevant guest information.
A practical operating procedure should state:
- who holds the FPCS account;
- who enters the guest;
- deadline;
- identity documents collected;
- data storage;
- late check-in procedure;
- responsibility after outsourcing;
- address confirmation;
- protection of passport data.
The platform does not complete these duties automatically for the owner.
If a property manager says that it handles registration, the management agreement should expressly include:
- FPCS;
- guest records;
- record retention;
- compliance evidence.
The owner and operator should not leave responsibility undefined
A common structure is:
- owner supplies the apartment;
- local manager creates the listing;
- cleaner handles check-in;
- reception issues the access card;
- platform receives the guest’s money;
- manager transfers net revenue.
After a complaint, nobody considers themselves the legal accommodation operator.
The contract should identify:
- legal operator;
- listing account holder;
- party contracting with the guest;
- tourism-licence holder;
- taxpayer;
- FPCS responsible person;
- payment recipient;
- deposit holder;
- insurance policyholder;
- damage-decision authority;
- emergency contact.
An owner can delegate daily operations.
They should not leave legal responsibility entirely ambiguous.
Where the manager relies on its own licence, confirm whether the licence covers:
- that company;
- that branch;
- that address;
- that activity.
A long-term tenant cannot automatically create an Airbnb business
An owner may lease the apartment for one year.
The tenant may then list it by the night during holidays.
Cambodian Civil Code principles restrict transfer of lease rights and subletting without the landlord’s permission, subject to the specific agreement and applicable rules.
A lease should therefore address:
- subletting;
- platform listings;
- paying guests;
- maximum guest stay;
- commercial use;
- sharing keys;
- income;
- internal regulations;
- breach;
- removal of the listing.
Permission to receive ordinary personal guests is not the same as permission to run a continuous short-term-rental business.
The owner should retain control over:
- photographs;
- listing;
- future bookings;
- access codes.
After the lease ends, the tenant should be required to remove all listings and cancel or transfer future bookings lawfully.
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Contact usor on TelegramThe economics begin with occupancy, not the nightly rate
Assume a nightly price of USD 55 and occupancy of 70%.
For a 30-day month:
30 × 70% × USD 55 = USD 1,155 gross revenue
Deductions can include:
- platform commission;
- management fee;
- cleaning;
- laundry;
- utilities;
- internet;
- toiletries;
- maintenance;
- furniture replacement;
- service charge;
- tax;
- vacancy;
- refunds;
- access fees;
- damage.
The owner may receive a net result much closer to USD 700–850, or lower, depending on the building and operator.
A long-term tenant paying USD 650 may also cover:
- electricity;
- water;
- internet;
and creates much less turnover.
Short-term rental wins only where occupancy, price and operations remain strong enough to overcome the additional cost and volatility.
Cleaning fees are not automatically owner profit
Some platforms show the guest a separate cleaning charge.
That does not mean the full amount belongs to the owner.
The charge may be paid to:
- cleaner;
- operator;
- platform;
- laundry supplier.
A low nightly price combined with a high cleaning fee may also reduce conversion or create poor reviews.
The owner should see:
- cleaning invoice;
- frequency;
- linen cost;
- emergency cleaning;
- replacement standards;
- who keeps any difference.
Seasonality can distort the annual model
A high rate during:
- festival;
- conference;
- holiday;
- major event;
is not the annual average.
The forecast should consider:
- high and low season;
- weekdays and weekends;
- monsoon periods;
- event spikes;
- new hotel supply;
- platform ranking;
- review score;
- cancellation policy;
- minimum stay.
A new listing often needs an introductory discount to build reviews.
One poor review can reduce future occupancy.
The model should be built month by month rather than from the best weekend.
Many identical apartments create internal competition
A large condominium may contain dozens of almost identical studios or one-bedrooms.
Guests compare:
- price;
- review;
- floor;
- view;
- furniture;
- cleaning fee;
- cancellation;
- host response;
- amenity status.
One manager may operate 20 units in the same building.
That creates allocation questions:
- Which listing receives the lead?
- Does the manager prioritise developer inventory?
- Are prices coordinated?
- Is a higher-commission unit favoured?
- How are corporate stays allocated?
The owner-management agreement should explain booking allocation and conflicts.
Otherwise, the manager can direct demand towards the unit that benefits it most.
Short-term guests create additional common-area cost
Frequent turnover increases:
- lift usage;
- reception work;
- security checks;
- access-card replacement;
- luggage movement;
- common cleaning;
- pool attendance;
- complaint handling.
A building may respond with:
- guest fee;
- operator charge;
- additional deposit;
- access restrictions;
- higher contribution.
The legality and voting procedure should be reviewed.
The economic issue is real.
Long-term residents do not necessarily want to subsidise a private hospitality business.
A well-run building should calculate incremental cost rather than react only through emotion.
Insurance must match the actual use
A normal residential policy may assume:
- owner occupation;
- long-term tenant;
- ordinary household risk.
Repeated paying guests change the exposure.
The owner should check:
- short-term-rental disclosure;
- business use;
- guest injury;
- theft;
- malicious damage;
- contents;
- loss of rent;
- unoccupied periods;
- platform protection;
- master building policy;
- public liability;
- cleaner and contractor liability.
Platform host protection is not equivalent to comprehensive local insurance.
It can have:
- exclusions;
- limits;
- documentation requirements;
- claim deadlines.
Written confirmation from the insurer is stronger than a platform marketing page.
Tax treatment depends on the actual activity
Cambodian tax materials distinguish property-rental tax and accommodation tax.
The correct treatment can depend on:
- ordinary rental versus accommodation business;
- who operates;
- who receives guest money;
- legal form;
- taxpayer registration;
- gross or net basis;
- VAT;
- platform commission;
- withholding;
- filing frequency.
The operator agreement should answer:
- who issues receipts;
- who files;
- who pays;
- what records are supplied to the owner;
- whether tax is deducted before distribution.
A line stating tax deducted without returns or receipts does not prove compliance.
Foreign owners should obtain current advice for their specific operating model.
Building rules can change after purchase
A building may initially tolerate nightly stays.
Two years later, owners may adopt a 30-day minimum term.
The investor’s model changes immediately.
Whether the new rule can be challenged depends on:
- original internal regulations;
- voting threshold;
- approved building use;
- proportionality;
- owner rights;
- adoption procedure;
- developer representations;
- existing contracts;
- mandatory law.
A residential building’s informal tolerance provides less certainty than a condo-hotel or serviced-apartment structure designed and licensed for hospitality.
Short-term-rental history does not always transfer on resale
One buyer may see an active Airbnb operation as a benefit.
Another may see:
- worn furniture;
- unresolved tax;
- complaints;
- future bookings;
- operator dependence;
- reviews attached to a host account;
- non-transferable listing;
- uncertain licence;
- building-rule risk.
A sale may require the parties to close or transfer:
- platform listing;
- bookings;
- guest communications;
- deposits;
- cleaning contracts;
- payout accounts;
- tax records;
- access cards;
- insurance;
- licences.
The phrase turnkey Airbnb business should be supported by evidence that the operating system can lawfully transfer.
Worked comparison
Assume:
Long-term lease
- rent: USD 650 per month;
- one-month vacancy every two years;
- tenant pays utilities;
- limited management.
Short-term model
- ADR: USD 55;
- occupancy: 65%;
- gross monthly revenue: approximately USD 1,073;
- platform and manager: 20%;
- utilities and internet: USD 140;
- cleaning and linen: USD 120;
- replacement and consumables: USD 60;
- service charge and tax: additional.
The apparent gross advantage may narrow substantially.
If occupancy falls to 45%, the model can become weaker than the ordinary lease while retaining higher workload.
The figures are illustrative.
The purpose is to compare net income and operating risk, not the headline rate.
When short-term rental can make sense
The model is stronger where:
- the building expressly permits it;
- the licensing route is confirmed;
- FPCS works reliably;
- demand exists throughout the year;
- the operator is professional;
- the unit is differentiated;
- cleaning is efficient;
- insurance covers the activity;
- tax is modelled;
- net income clearly exceeds long-term rent.
It is weaker where:
- building rules are uncertain;
- many identical listings exist;
- the owner lives abroad;
- seasonality is high;
- the manager controls all data;
- hospitality costs are high;
- the expected net premium is small.
What to check before buying for Airbnb use
A focused due-diligence package can include:
- internal regulations;
- owner or board resolutions;
- written management confirmation;
- approved building use;
- tourism-authority confirmation;
- operator licence;
- business and tax registration;
- FPCS procedure;
- insurance;
- management agreement;
- sample guest terms;
- fee schedule;
- historical occupancy;
- owner statements;
- complaint history;
- proposed rule changes.
Where half the model depends on oral answers, the risk remains high.
Conclusion
A foreign owner’s right to lease a private unit does not automatically include the right to operate a tourist-accommodation business from it.
Cambodia’s Tourism Law treats tourist accommodation services as regulated activity and gives the Ministry of Tourism authority over licensing and standards.
FPCS adds guest-registration obligations for foreign visitors.
Tax and insurance depend on the real operating structure.
The condominium’s internal regulations form a separate gate.
Even a properly licensed operator must comply with the building’s common-property, security and governance rules.
Airbnb can generate more gross revenue than a long-term lease.
The owner should compare net income after:
- vacancy;
- cleaning;
- utilities;
- platform fees;
- management;
- tax;
- furniture wear;
- rule-change risk.
An active listing is not proof of legal permission.
A stronger strategy is built on written building approval, a confirmed licence route, reliable guest registration, transparent management and appropriate insurance.
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Find a propertyor on TelegramSources
- Kingdom of Cambodia — Law on Tourism, 10 June 2009.
- General Department of Immigration — Foreigners Present in Cambodia System.
- Royal Government of Cambodia — Sub-Decree No. 126 on the Management and Use of Co-Owned Buildings, 12 August 2009.
- JICA Legal and Judicial Development Project — Civil Code of Cambodia, including rules on transfer of lease rights and subletting.
- General Department of Taxation — current materials on Tax on Property Rental and Accommodation Tax.
- Kingdom of Cambodia — Law on Insurance, 2014.
Frequently asked
Can a foreign owner rent out a Cambodian condominium by the night?
Ownership of a private unit and the right to lease it do not automatically authorise hotel-style operation. The owner should check the building’s internal regulations, tourism-business requirements, guest registration, tax treatment and the legal role of the operator.
Is a licence required for Airbnb activity in Cambodia?
Cambodia’s Tourism Law treats tourist accommodation services as a regulated tourism activity, while detailed categories and licensing are handled by the Ministry of Tourism and local tourism departments. The treatment of one apartment should be confirmed with the competent authority rather than inferred from an active platform listing.
Who registers foreign guests?
The Tourism Law requires managers of tourist accommodation to record guest information, while the General Department of Immigration uses the Foreigners Present in Cambodia System. The operating agreement should identify the person responsible for registration and record keeping.
Can a condominium prohibit short-term rentals?
Use of a private unit remains subject to the internal regulations, safety requirements and the rights of other co-owners. The validity of a restriction depends on the building documents, adoption procedure and the nature of the activity.
How is Airbnb different from an ordinary long-term lease?
Short-term activity involves repeated guest turnover, nightly marketing, check-in, cleaning and hospitality services. It can create different licensing, tax, insurance, immigration and building-management risks.