Businesses issuing e-wallets that are neither banking and financial institutions nor licensed payment service institutions should act now. In its Notification No. 14.026.1075 on the Obligations of Business Owners Issuing Electronic Money (E-Wallet Accounts) for Payment for Products or Services Within a Single Network, dated 6 August 2026 (the “Notification“), the National Bank of Cambodia (the “NBC“) requires each affected issuer to file a written notification with the NBC within 90 days, i.e, by 4 November 2026. Failure to notify exposes issuers to enforcement action, including sanctions under the Law on Banking and Financial Institutions of 1999 (the “LBFI“).
Background and legal basis
The Notification is directed at non-financial businesses (for example, coffee shops, restaurants, gyms, transport operators, entertainment centres and fuel stations) that let customers open e-wallet accounts through a mobile application (a “Mobile App“) or a membership card and load monetary balances redeemable only for goods or services within the issuer’s own network. The NBC refers to this as “Single-Purpose E-Money“.
Two provisions of Cambodian law underpin the Notification. First, under the LBFI, providing means of payment to customers forms part of the operations of banking and financial institutions and requires an NBC licence. Second, Article 20, paragraph 1 of the Prakas on the Management of Payment Service Institutions of 2017 (the “PSI Prakas“) prohibits any legal person, other than a banking and financial institution or a licensed payment service institution, from issuing electronic money. A related but distinct provision, Article 4, paragraph 2 of the same PSI Prakas, excludes from the Prakas’s scope payment instruments that can be used only in the premises of the issuing institution or within a limited network. Issuers should keep this scope-exclusion conceptually separate from the Article 20(2) notification exemption on which the Notification is centred.
The notification-only route under Article 20(2)
As a facilitation measure for micro, small and medium non-financial enterprises and to encourage innovation, Article 20, paragraph 2 of the PSI Prakas allows the NBC to waive the licensing requirement for legal persons issuing e-money on a limited scale, subject to a prior written notification and to the conditions summarised below. Two features of this route deserve attention. First, it is discretionary: the PSI Prakas provides that the NBC “may waive” the licensing requirement. Second, neither the PSI Prakas nor the Notification expressly states that submitting the notification alone completes the process. Issuers should therefore treat the notification as a step that opens, rather than concludes, the NBC’s assessment, and prepare for follow-up queries or conditions.
To qualify for the notification-only route, an issuer must satisfy all of the following conditions:
- the maximum balance of each account does not exceed KHR 200,000 (approximately USD 50) or its equivalent;
- the aggregate balance across all accounts does not exceed KHR 800,000,000 (approximately USD 200,000) or its equivalent;
- the e-money is redeemable only for products or services provided by a single person. The Notification refers to a “single person”, while Article 20(2)(c) of the underlying PSI Prakas refers to a “single legal person”. We read this as requiring that all payments funnel to one juridical entity (whether a natural person operating a business in their own name, or a single company), rather than a group of affiliated entities, a franchise network or a multi-merchant scheme; and
- any further conditions imposed by the NBC are complied with.
Key restrictions on Single-Purpose E-Money
The NBC has emphasised that e-wallet accounts held with non-licensed businesses are not savings accounts, that issuers are strictly prohibited from paying interest on account balances, that the e-wallet may be used only within the issuer’s own network and not with any third-party merchant or platform. Issuers should therefore audit their customer-facing terms, in-app disclosures and marketing materials to remove any wording suggesting that the e-wallet is a savings or interest-bearing product, to make clear that customers should not maintain balances above the KHR 200,000 per-account cap, and to ensure all disclosures reflect that the e-wallet is redeemable only within the issuer’s own network and cannot be used with any third party.
Enforcement risk
The Notification states that non-compliance may result in measures “in accordance with the procedures provided under the laws and regulations in force”. In practice, that includes Article 31 of the PSI Prakas, which routes sanctions through Articles 52 and 54 of the LBFI, together with any consequences that flow from unlicensed issuance of a means of payment under the LBFI itself. Issuers whose business model exceeds the Article 20(2) parameters (for example, balances above the KHR 200,000, approximately USD 50 or the aggregate balance across all accounts of KHR 800,000,000, approximately USD 200,000 caps, or e-money that can be spent across multiple merchants or networks) cannot rely on the notification-only route, and should assess whether a full payment service institution licence (which carries a minimum registered capital requirement of KHR 8,000,000,000, approximately USD 2 million) or another form of NBC authorisation is required.
Practical steps
Affected issuers should: (i) confirm that their programme meets all four conditions in Article 20(2), in particular the balance caps and the single-person test; (ii) prepare and file the written notification with the NBC on the sample form annexed to the Notification, well ahead of 4 November 2026; (iii) review customer terms, in-app disclosures and marketing materials to remove any deposit or interest connotation; and (iv) where the programme falls outside Article 20(2), initiate licensing discussions with the NBC, or restructure the programme so that it can be brought within the notification exemption (or within the scope-exclusion in Article 4(2) of the PSI Prakas).
Please do not hesitate to reach out should you require assistance in assessing the availability of the notification-only route, evaluating your notification obligations, or preparing and submitting the notification to the NBC.
The information provided here is for information purposes only and is not intended to constitute legal advice. Legal advice should be obtained from qualified legal counsel for all specific situations.
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