Manufacturing QIPs face a three-year actual-capital requirement

The rule is about capital actually put into the project

Instruction No. 1555/26 does not replace the existing minimum thresholds with a single figure. Manufacturing QIPs must reach or exceed the minimum that applies to their activity under the Negative List linked to Cambodia's investment-law framework.

For this test, investment capital excludes land value and working capital. A project can therefore have a large overall budget and still fall short if the qualifying capital remaining after those exclusions is below its applicable minimum.

The instruction also directs relevant CIB departments to review and verify compliance as part of their ongoing oversight. KPMG's summary of the instruction says failure to meet the minimum investment-capital requirement may lead to withdrawal of the QIP Registration Certificate.

The three-year clock depends on when the QIP was registered

Manufacturing QIPs registered before 27 August 2026 have up to three years from the instruction date to fully implement the required investment capital.

For QIPs registered after 27 August 2026, the three-year period runs from the date on the project's QIP Registration Certificate. The deadline is therefore project-specific rather than one common future date for the entire manufacturing sector.

This is also why the instruction should not be read as a new general capital rule for every Cambodian company. Its scope is manufacturing QIPs within the investment regime, and its purpose is to reinforce compliance with the minimum already applicable to each qualifying activity.

What manufacturing investors should take from the change

The useful comparison is between the applicable regulatory minimum and qualifying capital actually invested, not simply the total project value. The relevant threshold still has to be identified for the specific investment activity; the instruction itself does not provide one universal amount for all manufacturing QIPs.

Supporting records also become more important when CIB checks whether the project has implemented the required capital. For an ordinary homebuyer or property owner, the instruction does not create a separate obligation: it is a compliance rule for manufacturing QIPs, not a new condition on private property purchases.