Between the keys and the title: what you own before registration

Possession · documents · fit-out and letting · status control · updated July 2026

You have the keys, the apartment feels like yours — but in the register it is not yours yet. This gap is the psychologically hardest part of a purchase: formally nothing is happening, and the anxiety grows. Here is the honest version: what you actually hold during this period, what you can do with the unit and what is risky, which evidence to collect now so you do not have to reconstruct the story later, and how to tell an ordinary procedural pause from a situation that needs your intervention.

Keys and title are two different things

Handover of the unit and registration of ownership are two separate events, and the time between them can be significant. At handover you receive possession: access, keys, the ability to use the apartment and the duty to maintain it. Registration is an entry in the official register and a title document issued in your name.

Two more legal statuses sit between the keys and the title

Treat four outcomes as separate: physical handover of the apartment, permission to occupy the building or the relevant part, cadastral creation of the private unit, and registration of the transfer into your name. Keys evidence access and possession. An occupancy certificate concerns lawful use of the construction. Unit registration creates the official cadastral object. Transfer registration records the buyer as its owner.

None of those documents proves the other three. Ask the handover file to identify the number and date of the permanent or provisional occupancy certificate, the status of the co-owned parcel and private-unit registration, and the exact state of your own transfer case. The phrase “titles are being processed” is not meaningful until those stages are separated.

One non-obvious consequence follows. During the gap your position rests on the contract and on proven payments, not on the public register. Everything you do in this period should strengthen that position rather than dilute it: keep the documentary trail, avoid creating disputed facts, and do not take irreversible steps you will have to explain later.

We deliberately give no duration for this period. It depends on the type of property, the status of the project, the completeness of the documents and on who is running the process. Anyone quoting you a universal timeline for Cambodia is quoting from memory — ask for a written plan and a named owner of the task instead of a number.

Start the clock from acceptance of the named service, not from key handover

There is no single statutory duration for the whole gap, but individual public services can have their own timeframes. Article 20 of Sub-Decree No.126 states a maximum of 20 working days for certain updates following a sale, exchange, gift or succession of a private unit. The current MLMUPC service catalogue separately shows 15 days for registration of ownership transfer over an ordinary private unit. Neither figure measures the full journey from SPA or handover to a title in the buyer’s hands.

Ask for the official service name, receiving authority, formal acceptance date, receipt or case number, and every period during which correction was required. The occupancy regime is useful process evidence: Sub-Decree No.226 says a receipt is issued only when the filing is sufficient and excludes correction time from the decision period. Apply the same control discipline to title work — first prove that the official clock has actually started.

Maintain a project-level title-blocker register

After handover, ask the developer to separate the remaining work into two lists: items required from the individual buyer and actions the project owner must complete for the tower as a whole. Each project-level blocker should have an owner, current status, latest supporting correspondence or receipt, next action and next reporting date.

“Titles are being processed” does not show whether a procedure has started or where it stopped. A useful register distinguishes not yet prepared, filed, returned for correction, waiting on a third party and closed. The buyer can then monitor movement after handover without repeatedly resubmitting personal documents that have already been accepted.

Do not treat occupancy permission as a substitute for title

Occupancy permission and registration of the private right answer different questions. The former records the administrative basis for using the stated part of a development at a particular date; it does not by itself register the buyer as owner of the unit. Place its type, date and physical scope in the post-handover timeline as a separate milestone rather than marking title transfer complete.

Ask the developer to connect that milestone to the next registration action: which project filing can now proceed, what still remains before the individual title, who submits it and what receipt or reference the buyer will receive. Where the permission is provisional, record the unfinished project elements and the event expected to support final status.

An assignment before title must replace the buyer across the whole chain

Before registration, the asset being transferred is normally the buyer’s contractual position rather than an ownership entry already standing in the register. A side agreement between old and new buyers is not enough if the developer remains instructed to issue the title to the original buyer. Before assignment money moves, obtain any required written consent and a document that records the incoming buyer, the outgoing buyer’s release or continuing liability, and the developer’s recognition of the change.

Reconcile paid instalments, the remaining schedule, currency, deposit, incentives, rental or management promises, defect claims, keys, furniture, building charges and registration data. The developer should issue an updated account statement and confirm whose name now controls the title file. Where the incoming buyer is foreign, floor eligibility and available foreign quota must be checked again; an approval given to the first buyer does not answer those questions for the replacement buyer.

What you should be holding

This is your evidence pack for the whole gap. Assemble it now rather than "when needed" — recovering documents a year later from a developer whose account manager has changed is considerably harder.

Document	What it proves	What it does not prove
The sale and purchase agreement (SPA) with all annexes	Deal terms, obligations of the parties, unit specification	Registered ownership
Proof of every payment plus the schedule	What you paid, when, and to which account	That the account is fully settled, unless a separate confirmation exists
Handover record and snag list	The handover date, the condition of the unit, the defects recorded	That the defects have been fixed
Meter readings at handover	The point from which utilities are your responsibility	Absence of arrears from the earlier period
Building rules and management company documents	What may and may not be done in the unit and in the building	Consent for specific works — that is requested separately
Correspondence about registration status	That the process is running and who is responsible	The fact of registration itself
Copies of the passport and of the data filed for registration	The exact form in which your name went into the documents	That it matches the final title — that has to be checked

For what a buyer's file consists of in full, see the buyer document pack.

What you can do with the unit, and what is risky

There is no single answer for everyone here: almost every line is set by your contract and the building rules. The right sequence is to find the clause in the document first and act second.

Action	Where to look	What to bear in mind
Living in the unit	Handover record, building rules	Usually possible from handover; check that services and lifts are live and the building is in operation
Fit-out and furniture	SPA, warranty terms, management rules	Works may limit the warranty on the delivered unit; contractor access must be arranged
Structural alterations	SPA, building rules	Touching structure and services is restricted almost everywhere; get consent in writing
Letting	SPA, building rules, project terms	Check whether letting before registration is restricted and whether short-term letting is limited
Selling	The assignment clause of the contract	Registered ownership cannot be sold until it is registered; what is available is assignment, on its own terms
Mortgage or borrowing against the unit	Contract, lender requirements	Lenders normally rely on registered ownership; options before title are limited
Insurance	Insurer's terms	Clarify what is covered — the property, the fit-out, liability — and on what basis while there is no title

The key point: if the contract is silent on something, that is neither permission nor prohibition — it is uncertainty. Close it with a written answer from the developer or the management company before you act, not after.

Who pays for what during the gap

From handover the running costs normally pass to you: metered utilities, building charges, maintenance. Check three things in your own documents, though. First, from which date charges accrue — handover, building completion, or registration. Second, what the charge includes and whether there is a separate sinking fund. Third, whether there are arrears from the earlier period and who carries them.

A practical tip: take the first invoices and reconcile them against the contract and the rules. A discrepancy in the very first bill is the cheapest moment to raise a question.

Defects and warranty: the clock is already running

The gap is also the period in which warranty obligations for the delivered unit apply. The snag list drawn up at handover is the core document. As defects are fixed, insist on a record: what was done, when, by whom, with photos before and after.

Do not postpone claims until the title arrives. These are separate processes: fixing defects does not depend on registration, whereas proving later that a crack existed at handover will be far harder.

How to keep the registration under control

Anxiety in this period almost always comes from silence rather than from delay. Documents cure it.

Identify the case stage from evidence, not from the phrase ‘in process’

Use at least six distinct states: the building dossier has not been filed; the private-unit dossier has been filed; your individual transfer file is being prepared; a complete file has been accepted with a receipt or reference; corrections have been requested; or registration is complete while the final certificate is being produced or collected. Each state needs its own document, date, owner and next action.

A periodic message saying “no change” is not a status record. Keep the authority, case number, last evidenced action, correction notice, exact missing item, responsible party and next review date. If a reference belongs only to the project’s building-level application, do not present it as evidence that the buyer’s individual transfer has been accepted.

Establish who is running the process: the developer, their lawyer, your lawyer. The task needs one person with a name and a contact.
Ask in writing for the list of documents submitted and for confirmation of the filing.
Agree a reporting rhythm — a status update at an agreed interval, even when nothing has changed.
Reconcile the data that went into the filing: spelling of your name as per passport, passport number, unit number and area. A wrong letter costs more the later it is found.

Reconfirm available foreign quota before registration

Sub-Decree No.82 caps foreign ownership at 70 percent of the aggregate surface area of all private units in the co-owned building, not 70 percent of the apartment count. A sales-team assurance at reservation does not prove that capacity remains available when the transfer is registered, particularly where many foreign buyers are being processed together.

Request a dated written result showing total private-unit area, the area already registered or counted for foreign owners, the area of your unit, the calculation method and the person confirming it. Counsel should establish what official evidence or procedure is accepted for the particular filing. A sales spreadsheet and the nationality field in the developer’s CRM are not cadastral confirmation.

Keep all correspondence in one place. It is your timeline if a dispute appears later.
When the title document arrives, check it line by line against the contract and put the originals into safe storage.

For what official records can and cannot tell you, see the property registry and official records.

Red flags

Status questions are answered verbally and in general terms, with no written confirmation of the filing.

Check encumbrances and the release mechanism for your unit

The Land Law provides for registration of mortgages and other rights in the land register, while Article 20 of Sub-Decree No.126 requires a hypothec, pledge or perpetual lease over a private unit to be reflected in the cadastral record and certificate. If the project land, co-owned parcel or a created unit has been used as security, full payment to the developer does not by itself prove that your apartment is released.

Ask independent counsel for a dated official search at every registry level that is currently available and for the exact consent, repayment or partial-release mechanism needed before transfer. The written mechanism should identify the unit, release condition or amount, creditor, evidence of release and point at which filing or completion may proceed. Where a unit record does not yet exist, the search should be made at the available project level and its limitation stated expressly.

Nobody can name the person responsible: the developer points to the lawyer, the lawyer points back.
Your name or the unit data in the filed documents differ from the contract, and you are told it will be "corrected later".
An extra "processing" payment is requested with no written basis in the contract and no receipt.
You are asked to sign documents changing the deal terms in exchange for faster registration.
The management company charges for a period before handover, or without reference to any document.
You are encouraged to let or assign the unit around the contract terms, "because everyone does it".

What to do if something goes wrong

Stop the irreversible: sign nothing new and pay nothing further until you understand the picture.
Assemble the file: contract, payments, handover record, all status correspondence.
Request a written explanation with specifics — what was filed, where it sits, what is blocking it, what is needed from you.
Hand the pack to an independent lawyer who reads documents rather than paraphrasing market practice.
Record the agreed remediation plan in writing, with an owner and a review date.
If the issue touches payments, align your schedule with it: do not pay the next instalment in the dark.

Not sure where your registration has stalled? We can review your document pack, help you frame a written request to the developer and identify what a lawyer needs to check.

Ask about your unit or message us on Telegram

Frequently asked questions

If I have the keys, is the apartment already mine?

The keys mean possession has been handed to you: you can enter, use the unit and you are responsible for its condition. Registered ownership does not come from keys — it comes from an entry in the register and a title document issued in your name. Until that entry exists, your position rests on the contract and on proven payments, not on the public register. These are different things, and confusing them is expensive: most unpleasant surprises at resale are built on exactly this difference.

Can I renovate and let the apartment before the title is issued?

Often you can in practice, but this is set by your contract and the building rules, not by a general rule. Check what the SPA and the management rules say about alterations, fit-out, contractor access and about letting before registration. Works may affect the developer's warranty on the delivered unit, and letting before registration may conflict with the contract. Get written confirmation from the developer or the management company before works start and before you sign any lease.

Can I sell the apartment while the title is not yet issued?

You cannot sell registered ownership until ownership is registered in your name. In practice what is being discussed is an assignment of contractual rights, and that is a separate procedure with its own conditions: developer consent, an assignment fee, timing limits and limits on who may buy. All of them come from your contract. If a quick exit is part of your plan, read the assignment clause before you buy, not after.

How do I know the registration process is actually moving?

By documentary traces, not by verbal assurances. Ask for written confirmation of the filing, a reference for it, the list of documents submitted, and the name of the person responsible on the developer's or the lawyer's side. If nobody can answer a status request with a document, that is your answer. Record every request and every reply in writing so the period has a history rather than recollections.

Sources

Transaction support practice in Phnom Penh · NovAsia corpus on handover and title registration · checked July 2026. Stated plainly as unconfirmed: the typical or maximum duration of the gap between handover and registration, any statutory filing deadlines, the level of duties and fees for registration, and any Cambodia-wide rule on whether a unit may be let, assigned or mortgaged before registration are not confirmed in this review. All of the above is set by your contract, the building rules and the applicable procedure, and must be checked against your own documents by an independent lawyer. This content is for general information only and is not legal advice.