NovProperty purchase risk register for Cambodia
This is not a list of scary scenarios but a working decision tool. For each risk: what can go wrong, which signs are visible before payment, what reduces the risk and what residual risk remains after checks. The filter below lets you view risks by category.
Write the risk as cause, event and consequence
Each entry should state what creates the uncertainty, which event may occur and how it would affect the buyer's objective. For example: because the final balance has no confirmed funding source, the buyer may miss a contractual payment, creating exposure to penalties, termination and loss of part of the money already paid.
Do not combine several causes and consequences in one line merely because they concern the same project. Separate entries are easier to assign, evidence and close independently. ISO 31000:2018 describes a process of identifying, analysing, evaluating, treating, monitoring and communicating risk.
Checks reduce risk but do not remove it. We do not publish numerical probabilities — no reliable source supports them.
A risk and an event that has already happened need different treatment
A risk concerns an event that may still occur. If money has already gone to an unverified account, a due date has passed, signed annexes conflict or handover is already late, the matter is no longer a future scenario; it is an issue requiring current action.
The UK Government Teal Book defines an issue as an unplanned event that has happened and requires management. When a risk occurs, create an issue entry with the fact, date, immediate action, responsible person and resolution deadline. Preserve the original risk as realised rather than simply marking it closed.
Risk Register
Showing all 8 risks
Prioritise without inventing percentages
Risks can still be compared qualitatively. Record the potential effect on money, rights, timing and use of the property; how soon the event could occur; how quickly its effect becomes irreversible; and whether the decision can be reversed after it happens.
A non-refundable reservation before the SPA is available may need earlier action than a larger potential cost several years later. The Teal Book recommends considering impact, probability to the extent supported by evidence, velocity and how consequences change over time. Qualitative levels should therefore carry an explanation rather than become a pseudo-precise score.
Unclear title route, floor or quota
The buyer signs documents for a unit where the title route, eligible floor or foreign quota is unclear.
No specific unit reference, unclear strata-title timing, answers like "we'll register it later".
Request the title route, floor and quota confirmation, cadastral unit references and a lawyer review.
Give every risk an owner, action and trigger
The risk owner is accountable for understanding the risk and deciding whether the response is sufficient. The action owner performs a defined check: counsel reviews title and SPA, the bank confirms the payment route, an engineer investigates a technical matter and the buyer decides whether the residual risk is acceptable. These roles may belong to different people.
Add a next-review date, early trigger and escalation condition. A trigger may be a new SPA draft, changed payee, approaching final balance, delayed handover or offer expiry. The Teal Book recommends named risk and action owners and continuous updating as the risk changes.
Off-plan buyers still depend on developer performance until registration.
"What is the title route and when will I receive an individual or strata title? Confirm the eligible floor and quota."
Brand is not the legal seller
The marketing brand differs from the legal seller, landowner or payment recipient.
Invoices from a different company, different names across invoice, brochure and SPA.
Cross-check brand, seller, land rights, signatory authority, permits and invoices.
Public online verification can be limited, so document-led verification remains.
"Who is the legal seller and payment recipient? Show the land rights and permits."
Imbalanced obligations in the SPA
Buyer default is described in detail, while developer delay, defects, area changes or refund deadlines are vague.
"Standard contract", refusal to share a draft SPA before payment.
Review SPA clauses before a non-refundable payment: delay, defects, area, refund, assignment, termination.
A mitigation is complete only when it has evidence
“Check the developer” or “keep a reserve” does not establish that risk has fallen. For each response, identify the required outcome: an official register extract, legal report, executed SPA clause, bank quotation, approved budget or engineering report. Then assess whether that evidence actually reduces the original cause.
Residual risk is what remains after the response. The Teal Book says responses and controls should be monitored for effectiveness and changed where they do not have the intended effect. A document that merely repeats the seller's statement does not become independent verification because it has been filed.
Negotiation power and enforcement depend on the project and counterparty.
"Provide the draft SPA. Where are delay, defects, area change and refund set out?"
Cannot fund future payments
The buyer can pay the deposit but not future installments or the handover balance.
No cash-flow plan, the final payment is underestimated.
Stress-test income drop, USD exposure, bank charges, the final payment and a reserve.
Test dependencies and combined scenarios
One response can reduce one risk while increasing another. A longer instalment plan lowers immediate cash pressure but extends currency exposure; delayed handover can coincide with reduced income; weak rent can force a sale while the developer is still discounting new units.
The Teal Book recommends managing risks both individually and in aggregate because repeated causes and dependencies can create a larger viability risk. Build at least one combined downside case and test whether payments, reserves, holding period and exit rights remain workable.
Building management and common costs are a separate risk
Scenario: after handover, service charge rises, reserves are inadequate, major work requires a special assessment, reporting is weak or unsold units do not bear the expected share of costs. Early signs include no internal rules, operating budget, identified manager, rate-change process or governance for major works.
Risk reduction includes obtaining the building rules, service-charge calculation, first operating budget, reserve and special-assessment rules, manager authority, common-area insurance and owner reporting process. Sub-Decree No. 126 on co-owned buildings and Cambodia's foreign-ownership law connect the private unit to common areas and co-owner obligations. Residual risk remains because future costs, management quality and other owners' behaviour cannot be fully controlled.
Close a risk with a reason and a route to reopen it
Close a risk where its period has passed, the cause has been removed, the event is no longer possible or the event occurred and moved to the issue log. Preserve the prior status, date, basis, evidence and decision-maker. Deleting closed entries removes the history of why the transaction was considered acceptable.
Reopen the dependent risk when the unit, SPA, seller, account, timeline, stage, financing route or management model changes. The 2025 AQuA Book recommends assumptions and decisions logs with dates, reasons, authors and approvals, allowing the decision to be reconstructed after documents or conditions change.
Exchange rates and personal cash flow can change.
"Show the full payment schedule and the size of the handover balance."
Completion slips past the timeline
Completion moves beyond the marketing timeline.
No long-stop date, grace period or clear refund remedy.
Fix the target date, grace period, long-stop date and suspension/termination/refund terms.
No Cambodia-wide automatic penalty or refund rule was verified.
"What are the target date, grace period and long-stop date? What happens on delay?"
Clean acceptance before logging defects
The buyer signs a clean acceptance before defects are recorded.
No inspection right, no photo defect list, no rectification deadline.
Secure the inspection right, representative authority, a photo defect list and a rectification process.
Warranty duration and procedure remain contract-specific.
"Is there an inspection right before signing acceptance, and a clear rectification process?"
Brochure yield taken as a fact
The buyer treats a brochure yield as a market fact.
"Guaranteed return" without a payer, calculation base, definition of "net" and default remedy.
Identify the obligated entity, calculation base, start date, taxes, definition of "net" and default remedies.
The counterparty may not perform, and market rent may be lower than expected.
"Who guarantees the GRR, how is net calculated and what happens on the guarantor's default?"
Exit depends on a quick resale
The exit depends on a quick resale to another foreign investor.
Short holding horizon, reliance on appreciation, no next-buyer profile.
Define the likely next buyer, competing supply, developer discounts and resale friction.
Phnom Penh's secondary market can be thinner than mature markets.
"Who is the likely next buyer and what competing supply is on the market?"
Want to break a specific project down by risk? Send the SPA, price list and project documents — we will help build a practical risk register for your decision.
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Does a risk register remove purchase risk?
No. The register helps you see the scenario, early signs, mitigations and residual risk. Checks reduce risk but do not remove it entirely.
Why are there no numerical probabilities?
No reliable source for per-risk numerical probabilities was verified. The register uses qualitative descriptions, without invented percentages.
Who should review the SPA and title route?
Final review of the SPA, title route, seller authority, payments, delays, defects and remedies should be done by a qualified lawyer or transaction adviser in Cambodia.
Sources
NovAsia research on registry and title route, investment and the SPA, delay and cancellation, defects and handover, and reading the brochure and price list · checked July 7, 2026. Numerical probabilities for buyer risks were not verified. This information is for general orientation and is not legal advice.