Cambodia introduces a notification regime for some closed-loop e-wallets

Which programmes fall within the notification route

For the notification-only route, the balance on each individual account must not exceed KHR 200,000, while the aggregate balance across all accounts issued by the business must not exceed KHR 800 million. The stored value must be usable only for goods or services provided by the same issuer.

A programme that exceeds those limits or allows customers to spend funds across third-party merchants may fall outside this limited route. In that case, the operator may need to assess whether a payment service institution licence or another form of NBC authorisation is required. Filing a notice should therefore not be treated as automatic approval for any prepaid-wallet model.

The notification is dated 6 August and provides a 90-day period. DFDL and JBL Mekong calculate 4 November 2026 as the end date when counting from the date of the notice. Some legal summaries also describe the period as running from receipt of the notification, so an affected operator should confirm the deadline that applies to its own filing with the NBC.

What customers should understand

For customers, the most important distinction is that these balances are not savings accounts or bank deposits. The NBC has also stated that issuers must not pay interest on money held in these accounts. Someone using a retailer's or service provider's prepaid wallet should therefore understand who holds the funds and whether the balance can be used anywhere outside that operator's own network.

The measure does not amount to a ban on electronic wallets in Cambodia. Nor does it, by itself, rewrite the rules for ordinary bank accounts, transfers or licensed payment services. It is a targeted compliance step for a narrower category of closed-loop prepaid programmes operated by non-financial businesses.