Prakas 063 changes Cambodia’s filing and audit rules

Filing deadlines and audit tests now sit in one framework

Entities that are not required to undergo an independent audit must file their annual financial statements with the Accounting and Auditing Regulator (ACAR) within three months and 20 days after financial year-end. Audited entities have six months and 20 days to file their audited financial statements together with the independent auditor’s report.

Prakas 063 also expands the categories that face a statutory audit requirement. Public enterprises, public-interest entities and Qualified Investment Projects remain within the regime, while branches of foreign companies and casino operators are expressly added. A licensed business constructing houses or buildings for sale is also subject to the specific Article 8 audit rule once annual turnover reaches KHR 8 billion, stated in the regulation as roughly US$2 million.

Other businesses are assessed under a two-out-of-three test. The turnover threshold is KHR 20 billion for commercial businesses, KHR 30 billion for manufacturing and KHR 8 billion for services; the other two tests are total assets of at least KHR 10 billion and an average workforce of at least 100 employees. Meeting only one of those three general tests does not, by itself, trigger the Article 9 audit requirement.

For a property buyer, an audit is evidence — not a guarantee

The new framework gives buyers and investors a more precise compliance question to ask when reviewing a Cambodian developer: is the contracting or project company required to have an independent audit under Prakas 063, and if so, can it produce the relevant audited statements and auditor’s opinion? That can be useful evidence when assessing the financial position of the legal entity behind a transaction.

It should not be treated as a substitute for project-level due diligence. An audit does not establish land title, confirm that construction permits are valid, guarantee delivery, or prove that money paid by a buyer is protected. The company named in the financial statements should also be matched against the entity that owns the project, receives payments and signs the sale or investment agreement.

Timing matters as well. The revised audit obligations under Articles 8 to 11 apply from the 2026 accounting period, so a company should not be treated as non-compliant merely because its 2026 audited statements are not available before the statutory completion and filing deadlines. Businesses with mixed activities may also need ACAR guidance on which sector classification applies when determining the relevant turnover threshold.

Late filing now carries a clearer penalty framework

Prakas 063 sets out administrative penalties for delayed filing more explicitly than the previous regime. For enterprises, late filing can attract a penalty of KHR 2 million for each month of delay, capped at KHR 12 million for an accounting period. Separate figures and tests apply to not-for-profit entities.

ACAR followed the Prakas with Notification No. 033/26 on 26 August 2026. Earlier implementing guidance issued under Prakas No. 563 remains in force until it is replaced, so a company’s position can depend on more than a single turnover figure. Legal status, business category, assets, workforce, prior audit status and applicable ACAR guidance can all affect the answer.