On 18 August 2026, the Non-Bank Financial Services Authority, acting through the Accounting and Auditing Regulator (“ACAR”), issued Prakas No. 063 on the Obligation to File Annual Financial Statements and Submit Financial Statements for Independent Audit (Prakas 063), replacing Prakas No. 563 dated 10 July 2020 (Prakas 563). Prakas 063 was followed by an implementation notification (Notice No. 033/26) issued by ACAR on 26 August 2026, and gives effect to the high-level decision reached at the 19th Royal Government–Private Sector Forum.
Prakas 063 introduces a revised compliance framework for the filing and independent audit of financial statements in Cambodia. It aims to enhance accounting and auditing standards while providing greater flexibility for obligated persons. Unlike Prakas 563, which focused primarily on the independent audit requirement, Prakas 063 establishes a more comprehensive regime by covering both the obligation to undergo an independent audit and the filing of annual financial statements. It also introduces updated audit thresholds, streamlined procedures, and a new framework of administrative sanctions for non-compliance.
The key highlights of Prakas 063 are set out below.
Mandatory Independent Audit Criteria
1. Mandatory Audit – Expanded Categories
Under Prakas 563, mandatory independent audit applied only to public enterprises, public accountable entities and Qualified Investment Projects (“QIPs”). Prakas 063 significantly widens the mandatory audit net: independent audit is now automatically required for the following entities, regardless of size:
- Public enterprises and Public accountable entities (e.g., listed companies, banks, MDIs, insurance companies, securities firms, mutual funds);
- QIPs;
- Branches of foreign companies; (new)
- Casino operators; and (new)
- Residential/commercial building developers (licensed by the Real Estate Business and Mortgage Regulator or competent authorities) with annual turnover of KHR 8 billion (~USD 2 million) or more. (new)
2. Size-Based Audits – Materially Higher Thresholds
Under Prakas 563, an enterprise was required to have its financial statements independently audited where it met at least 2 of 3 criteria: annual turnover of KHR 4 billion or more, total assets of KHR 3 billion or more, or an average of 100 or more employees.
Prakas 063 retains the “2 out of 3” test, but revises the thresholds and, for the first time, differentiates the turnover threshold by business sector, as summarised below:
| Previous Threshold (Prakas 563) | New Threshold (Prakas 063) | |
|---|---|---|
| Criterion 1 – Annual Turnover | KHR 4 billion (approx. USD 1 million) or more | Commercial: KHR 20 billion (approx. USD 5 million) or more Manufacturing: KHR 30 billion (approx. USD 7.5 million) or more Services: KHR 8 billion (approx. USD 2 million) or more |
| Criterion 2 – Total Assets | KHR 3 billion (approx. USD 750,000) | KHR 10 billion (~USD 2.5 million) or more as of the closing date. |
| Criterion 3 – Employees | Average annual headcount of 100 or more. | Average annual headcount of 100 or more. (unchanged) |
Continuation rule for enterprises falling below the thresholds: Under Prakas 563, any enterprise that had once been audited was required to continue submitting its financial statements for audit for at least three further consecutive years, even if it no longer met the criteria. However, under the new Prakas 063, that three-year continuation obligation now applies only where the enterprise still has annual turnover of KHR 5 billion (approx. USD 1.25 million) or more – providing meaningful relief to enterprises whose turnover has genuinely declined.
3. Non-Profit Organisations (“NPOs”) – Two Distinct Audit Triggers
Under Prakas 563, an NPO was required to submit its financial statements for independent audit only where both of the following were met: total annual expenses above KHR 2 billion and 20 or more employees on average.
Prakas 063 splits this analysis into two distinct audit triggers – one at project level and one at organisation level. An NPO is now required to submit its financial statements for independent audit where either of the following triggers is met:
| Trigger | Threshold |
|---|---|
| Specific Projects | Individual project with total costs exceeding KHR 2 billion (~USD 500,000). |
| General NPO Operations | Annual total expenditures exceeding KHR 3 billion (~USD 750,000) (excluding audited project costs) AND an average of 20 or more workers employed during the year. |
A new audit frequency rule also applies to NPO projects: projects of 18 months or less require only one independent audit, while projects longer than 18 months must be audited every 12 months.
Exemptions and Regulatory Waivers – Now Codified in the Prakas Itself
For the first time, Prakas 063 codifies an express exemption regime for enterprises and NPOs, as follows:
- Exemption Requests (Enterprises): Enterprises subject to audit by reason of business type or size may apply to ACAR for an audit exemption where they have been inactive for 12 consecutive months following their last audited financial year, or where they no longer meet the general criteria and have turnover under KHR 5 billion (approx. USD 1.25 million). Exemption requests must be filed within 30 days of the accounting period end date, together with the applicable public service fees.
- NPO Exemption Notification: NPOs that no longer meet the audit thresholds must notify ACAR in writing within 30 days after the accounting period end date.
New Administrative Sanctions for Delayed Submissions
Previously, Prakas 563 dealt with penalties only by reference, pointing to Sub-Decree No. 79 dated 1 June 2020 on the fine on violation of the Law on Accounting and Auditing. Prakas 063, by contrast, introduces detailed monetary penalties.
For non-audited entities, late submission of annual financial statements (where a Financial Reporting Identification Number has already been obtained) attracts the following penalties:
| Entity Type | Fine | Maximum Penalty per Accounting Period |
| Enterprises | KHR 2,000,000 (approx. USD 500) per month | KHR 12,000,000 (~USD 3,000) |
| NPOs | KHR 1,200,000 (approx. USD 300) per month | KHR 7,200,000 (~USD 1,800) |
Enforcement and Penalty Escalation
- Fines must be paid within 30 days of receipt of the notification.
- Failure to pay within 30 days results in the penalty being doubled.
- Non-payment beyond 60 days results in the penalty being tripled.
- Non-payment beyond 90 days empowers ACAR to take direct enforcement action, including issuing formal reminder notices, summoning entity owners or heads, requesting inter-ministerial enforcement, or initiating proceedings through the courts or prosecutor’s office.
Effective Dates and Transition
- The financial statement submission obligations for unaudited and audited entities under prior frameworks remain in force from the signing date of Prakas 063 (18 August 2026).
- The revised independent audit obligations set out in Articles 8 to 11 must be implemented from the 2026 accounting year onwards.
- Existing guidelines issued under Prakas 563 remain in force until replaced by updated regulations.
DFDL Commentary:
Prakas 063 operationalises the Royal Government’s ongoing efforts to modernise Cambodia’s accounting and audit framework, building on the discussions at the 19th Royal Government–Private Sector Forum. By replacing Prakas 563, it introduces a clearer and more tailored compliance regime for enterprises and NPOs.
Key operational takeaways for businesses and NPOs include:
- New sectors captured by mandatory audit. Foreign branches, casino operators and larger real estate developers should assume they are within the audit net regardless of size.
- Higher thresholds bring genuine relief. Many enterprises previously caught by the KHR 4 billion turnover or KHR 3 billion asset thresholds under Prakas 563 will fall outside mandatory audit under the new commercial (KHR 20 billion), manufacturing (KHR 30 billion), services (KHR 8 billion) and asset (KHR 10 billion) tests.
- Manage the transition carefully. The 3-year continuation rule for filing Audited Financial Statement still applies where annual turnover is at least KHR 5 billion, and the new exemption process runs on a 30-day window from the enterprise year-end. This creates a transitional bridge before entities can exit mandatory audit obligations.
- NPO project structuring matters. Because project cost (KHR 2 billion) triggers audit independently of entity-level expenditure, NPOs should map their project pipeline against the new thresholds and audit-frequency rules.
Overall, Prakas 063 raises transparency and standardises accounting practices across Cambodia. Enterprises and NPOs should promptly review their financial metrics, workforce headcount and project costs to confirm their regulatory status for the 2026 accounting year and beyond.
How DFDL Can Help
DFDL’s Cambodia tax and accounting team can assist obligated persons in assessing whether they fall within the new filing and audit obligations, structuring exemption requests to ACAR, and putting compliance processes in place ahead of the 2026 filing and audit cycle. Please reach out to your usual DFDL contact for tailored advice.
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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