Cambodia extends six-month relief for overdue annual company declarations

The relief narrows penalties, not the filing duty

Notification No. 2463 allows an eligible company with several missed ADCE filings to pay the late-filing penalty for only the most recent outstanding year. Public service fees, however, remain payable for each year in which the declaration was not filed.

A September DFDL update gives a useful example: if ADCEs for 2023, 2024 and 2025 are all outstanding, the late penalty would apply to the 2025 filing, while the filing fees would still be due for all three years. The relief therefore reduces the penalty burden without wiping out the underlying compliance work.

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Companies have three conditions to meet within the window

The published guidance says companies must, within six months of the 10 July notification, pay the penalty for the latest missed ADCE, pay the official filing fee for every outstanding year, and participate in the shareholder or owner background-check process linked to anti-money-laundering compliance and corporate transparency.

The sources reviewed describe the period as six months from the notification date instead of giving a separate calendar cut-off. Companies relying on the relief should therefore confirm the live deadline in the Ministry of Commerce system before filing. A company that does not regularise its outstanding ADCEs and satisfy the conditions may be classified as inactive, with possible consequences for its registration status and corporate rights.

There has also been a practical change since the July relief was announced. DFDL reported on 7 September that access to the Ministry of Commerce Business Registration System had moved to CamDigiKey, Cambodia's digital identity platform, following an MOC notification dated 23 August.

Businesses registered before 31 July 2026 must complete an account ownership claim before they can manage their existing company records under the new access system. That does not replace or shorten the ADCE relief itself, but it can add a preliminary access step for a company trying to clear overdue filings during the six-month window.