On 25 May 2026, the Royal Government of Cambodia has issued Sub-Decree No. 102 on Penalties for Violations of the Law on Accounting and Auditing (the “Sub-Decree 102”), introducing a comprehensive framework for non-compliance with accounting and auditing obligations. It is designed to strengthen enforcement of the governing law by clearly defining offences and corresponding fines, while also establishing the relevant authorities, measures, and procedures for the imposition and administration of penalties.
Key features:
Broad scope of application
Sub-Decree 102 applies to audited and non-audited enterprises, non-profit organizations, and licensed accountants and auditors operating in Cambodia.
Defined violations and compliance obligations
Sub-Decree 102 sets out various violations, including failure to maintain proper accounting records, failure to submit annual financial statements to the Accounting and Auditing Regulator (“ACAR”), and intentional misreporting of financial information.
Significant financial penalties
Sub-Decree imposes substantial fines for non-compliance. Notably:
- Audited enterprises may be subject to fines of up to KHR 60 million for failure to submit annual financial statements to ACAR.
- Non-audited enterprises may face fines of up to KHR 50 million for similar violations.
Additional penalties apply for non-compliance with accounting standards, improper record keeping, and failure to comply with language and currency requirements.
The penalties for each non-compliance are provided below:
| No. | Offense / Violation | Audited Enterprise | Non-audited Enterprise | NGO Audited | NGO Non- audited |
|---|---|---|---|---|---|
| 1 | Failure to submit annual financial statements to ACAR | 60,000,000 riels ($15,000) | 50,000,000 riels ($ 12,500) | 36,000,000 riels ($ 9,000) | 27,000,000 riels ($ 6,750) |
| 2 | Failure to submit annual financial report for independent audit | 20,000,000 riels ($ 5,000) | Not applicable | 1,600,000 riels ($ 400) | Not applicable |
| 3 | Failure to keep / maintain accounting records | 10,000,000 riels ($ 2,500) | 10,000,000 riels ($ 2,500) | 6,400,000 riels ($ 1,600) | 5,000,000 riels ($ 1,250) |
| 4 | Incorrect accounting records | 5,000,000 riels ($ 1,250) | 5,000,000 riels ($ 1,250) | 3,200,000 riels ($ 800) | 2,500,000 riels ($ 625) |
| 5 | Non-compliance with accounting standards | 10,000,000 riels ($ 2,500) | 8,000,000 riels ($ 2,000) | 6,000,000 riels ($ 1,500) | 5,000,000 riels ($ 1,250) |
| 6 | Failure to use financial statements for fiscal obligations | 10,000,000 riels ($2,500) | 8,000,000 riels ($ 2,000) | 4,800,000 riels ($ 1,200) | 4,000,000 riels ($ 1,000) |
| 7 | Failure to maintain accounting documents within the legal time limit | 10,000,000 riels ($ 2,500) | 10,000,000 riels ($ 2,500) | 8,000,000 riels ($ 2,000) | 6,000,000 riels ($ 1,500) |
| 8 | Obstruction of accounting and auditing compliance implementation | 10,000,000 riels ($ 2,500) | 10,000,000 riels ($ 2,500) | 6,000,000 riels ($ 1,500) | 3,000,000 riels ($ 750) |
| 9 | Intentional misreporting of annual financial information | 10,000,000 riels ($ 2,500) | 10,000,000 riels ($ 2,500) | 8,000,000 riels ($ 2,000) | 6,000,000 riels ($ 1,500) |
| 10 | Failure to use Khmer riel in annual financial report filed with ACAR | 2,000,000 riels ($ 500) | 2,000,000 riels ($ 500) | 2,000,000 riels ($ 500) | 2,000,000 riels ($ 500) |
| 11 | Failure to use Khmer language in financial statements filed with ACAR | 2,000,000 riels ($ 500) | 2,000,000 riels ($ 500) | 2,000,000 riels ($ 500) | 2,000,000 riels ($ 500) |
| 12 | Using accounting periods different from those specified by law without ACAR approval | 2,000,000 riels ($ 500) | 2,000,000 riels ($ 500) | 2,000,000 riels ($ 500) | 2,000,000 riels ($ 500) |
Note: “NGO Audited” refers to audited non-profit entities, and “NGO Non-audited” refers to non-audited non-profit entities. “Not applicable” means the specific independent audit submission penalty is not listed for that category in the Sub-Decree.
USD equivalents are calculated using the exchange rate USD 1 = KHR 4,000
Enhanced enforcement and inspection powers
ACAR is designated as the competent authority to enforce Sub-Decree 102 and may conduct inspections and impose penalties. The Sub-Decree introduces progressive penalties, with fines increasing in cases of repeated violations.
Penalty escalation and enforcement mechanisms
Sub-Decree 102 provides for escalating penalties depending on the frequency of non-compliance and imposes strict consequences for non-payment, including increased fines and potential legal action.
Effective date
Sub-Decree 102 will generally come into force six months from its date of issuance, with certain provisions becoming effective after one year.
Practical implications
Sub-Decree 102 represents a significant strengthening of Cambodia’s enforcement regime for accounting and auditing compliance. Businesses and professionals should review their accounting practices, ensure timely submission of financial statements, and confirm compliance with applicable accounting standards and regulatory requirements to mitigate potential exposure to penalties.
Bookkeeping services, required to be undertaken by a licensed firm in Cambodia, are provided by Mekong Accounting Services Co., Ltd, a member of the DFDL group, a corporate member of the Kampuchea Institute of Certified Public Accountants and Auditors and licensed by the Accounting and Auditing Regulator of Cambodia.
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.
